Polish Accessibility Act – new standards of equal access to products and services

On 28 June 2025, the new Polish Act on ensuring that certain products and services meet accessibility requirements by economic operators entered into force.

The Polish Act on the Accessibility implements Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on accessibility requirements for products and services, also known as the European Accessibility Act (EAA).

The purpose of the regulation is to ensure equal access to products and services for persons with disabilities and with special needs.

Persons with disabilities are defined as those that have long-term impaired physical, intellectual and sensory abilities, which, in interaction with various barriers, may hinder their full and effective participation in social life on an equal basis with others.

The obligation to adapt products and services to the new regulations applies to manufacturers and their authorised representatives, as well as importers, distributors and service providers.

However, the new regulations do not apply to micro-entrepreneurs.

Accessibility requirements apply to the following products placed on the market after 28 June 2025:

  • general purpose computer hardware systems
  • payment terminals and self-service terminals intended for the provision of services covered by the Act, such as ATMs and cash deposit machines, ticket and check-in machines, interactive terminals intended for providing information,
  • consumer terminal devices used for the provision of telecommunications services and access to audio-visual media services,
  • e-book readers.

The scope of services covered by the Accessibility Act includes:

  • electronic communications services
  • services providing access to audio-visual media services,
  • services accompanying transport services of air, bus, rail and waterborne passenger transport services (websites, mobile applications, electronic tickets and electronic ticketing services, self-service terminals, delivery of information)
  • consumer banking services,
  • e-books and dedicated software,
  • e-commerce services.

The requirements that products and services must meet are specified in Annex I to the EAA and indicated in the Polish Accessibility Act. They concern, among other things, the scope and method of providing information, including instructions for use, a user interface enabling people with disabilities to access the product, perceive it, operate it and understand how it works and control it, as well as providing technical support services or call centre. In addition, functional criteria have been formulated for the use of products or services by blind people, visually impaired or otherwise print-disabled, deaf and hard of hearing, without vocal capability, with limited manipulation or strength, with the risk of triggering photosensitive seizures or with limited cognition.

The Accessibility Act provides for a system of complaints that consumers can submit in the first instance to the economic entity responsible for ensuring the accessibility of the product or service.

The President of PFRON is responsible for market supervision in this respect and is authorised to carry out controls and take intervention measures or to refer the matter to supervisory bodies of individual markets such as the President of the Office of Electronic Communications, the Financial Ombudsman, the President of the Office of Rail Transport or the President of the Civil Aviation Authority.

Manufacturers and service providers who fail to comply with accessibility requirements or fail to cooperate with the relevant authorities to clarify the matter may face sanctions in the form of fines. The fine may amount to up to ten times the average monthly salary in the national economy for the preceding year, but not more than 10% of the turnover achieved in the financial year preceding the year in which the fine is imposed.

It should be emphasised that the new regulations do not apply to products placed on the market before 28 June 2025, existing service contracts, provided that they may be valid until 28 June 2030 as well as content published on websites and in applications before the date of entry into force of the regulations.