Website accessibility law in Poland: who it covers

What law this is

Officially — the Act of 26 April 2024 on ensuring that certain products and services meet accessibility requirements. It is Poland's implementation of EU Directive 2019/882, better known as the European Accessibility Act. The obligations took effect on 28 June 2025.

The idea behind it is simple: goods and services people use every day should also work for those who see poorly, cannot hear, cannot use a mouse, or take in information differently. For the web that means a site has to work for more than a person with good eyesight, a mouse and fast internet.

Who it covers

On the services side the law covers e-commerce, retail banking, telecommunications, passenger transport, audiovisual media services and e-book distribution.

For a site owner the key phrase is e-commerce. And that is not only the classic shop with a basket. The definition catches any site through which a contract is concluded at a distance: online booking with payment, selling courses and subscriptions, reservations, an ordering app.

Who it does not cover — and where the trap is

Micro-enterprises are exempt when it comes to providing services. A micro-enterprise means fewer than 10 employees and annual turnover or balance sheet total no higher than EUR 2 million. Most small firms in Poland fit that definition, and that is usually where the reading stops. It should not — the exemption is narrower than it looks.

Three situations where it does not save you:

• You are a manufacturer. The services exemption does not carry over to products. If your firm makes something on the list of covered goods, the obligations stay.
• The company grew. The criterion is assessed on the facts, not on what the business looked like when the site was launched. A tenth employee or one good year turns the exemption into an obligation, and reworking a live site costs more than building a new one properly.
• You work with a large client. Formally the requirement is theirs, not yours, but in tenders and contracts accessibility increasingly appears as a separate clause. Losing a deal over it stings more than a fine.

And separately: the exemption concerns the law, not your customers. Millions of people in Poland live with limits on sight, hearing or motor control, and half of all accessibility barriers get in the way of everyone else too. Video captions get read on public transport with the sound off; large high-contrast text helps anyone looking at a phone in bright sun.

What a website actually has to do

The law points to the European standard EN 301 549, and that one points to WCAG 2.1 at level AA. This is the international set of accessibility requirements; version 2.2 already exists, but 2.1 is what the regulations are anchored to.

Strip away the language of standards and the requirements come down to four things.

• Visible. Enough contrast between text and background, a layout that survives zooming to 200%, and information that is never carried by colour alone.
• Audible and readable. Images have text descriptions, video has captions, audio has a transcript.
• Operable. The whole site works from the keyboard, without a mouse. You can see where the focus is. Nothing hijacks control or flashes in a way that can trigger a seizure.
• Understandable. Forms explain what they want and what went wrong; the site behaves predictably; headings and structure reflect the real hierarchy rather than being picked by font size.

Five places where sites usually fail

From checking other people's sites, the set of mistakes repeats almost word for word.

• Grey text on white. Fashionable and unreadable. You need a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text. Light grey hints under form fields almost never pass.
• The site does not work from the keyboard. The menu only opens on mouse hover, a modal cannot be closed from the keyboard, a dropdown traps you inside. One minute with the Tab key settles it.
• Images with no alt text — or the opposite. An empty alt on a meaningful image loses information. But an alt reading "image1.jpg", or a careful description of a decorative flourish, hurts as well: a screen reader will read all of it out.
• Forms that complain in red. A red border with no text says nothing to someone who cannot distinguish colours or who is using a screen reader. An error has to be spelled out in words and tied to the specific field.
• Video without captions. The company story playing on the home page is content that simply does not exist for part of your audience.

How to check your own site in fifteen minutes

This will not replace a full audit, but it shows whether you have a problem at all.

• The Tab key. Open the home page and move through the site using Tab alone, without touching the mouse. Reach a form, fill it in, submit it. If you lose the focus anywhere, get stuck, or cannot tell where you are — that is a failure.
• Zoom to 200%. Press Ctrl and plus a few times. Text should reflow, not run off the edge or overlap itself.
• Black and white. Look at the site without colour, using the relevant filter in your display settings. If part of the meaning disappeared — required fields, statuses, links inside text — then that information was resting on colour alone.
• An automated check. Chrome has Lighthouse built in; its Accessibility tab produces a list of formal errors. Keep in mind that automation catches roughly a third of the problems and can never judge whether an image's alt text makes sense.
• A screen reader. On Windows that is Narrator, started with Ctrl+Win+Enter. The first thirty seconds will tell you more about your site than most reports.

What you risk, and how an inspection starts

Supervision rests with the President of PFRON, and in specific sectors with the relevant authorities: UKE for telecommunications, the Financial Ombudsman for financial services. Anyone can report a lack of accessibility — there is no special procedure and no status requirement for the person reporting.

The fine is set according to the gravity of the breach, the number of people affected and its scale, but it is capped: no more than ten times the average salary and no more than 10% of annual turnover. It must be paid within 14 days of the decision becoming final, and the money goes to the Accessibility Fund.

One detail usually calms people down: first comes an order to remedy the breach and a deadline to do it, and the fine only follows if that is ignored. So there is no fatal risk here — but "they probably will not notice" has stopped working.

What fixing it costs

The range is wide, and the honest answer depends on what already exists.

If the site runs on a modern template with no improvisation in the markup, accessibility usually comes down to adjusting colours, adding descriptions and sorting out the forms. That is a few days of work. If the site is seven years old, was assembled in a builder on absolute positioning, and its menu opens on hover — building a new one is cheaper than repairing every screen separately.

So the first step is not a quote, it is a check. Fifteen minutes against the list above shows the scale; after that the money conversation becomes concrete. Reference points for the cost of the work are on the Pricing page.

What to do this week

• Work out whether the law applies to you: do you sell anything through the site, and do you fit the micro-enterprise criteria — fewer than 10 people and up to EUR 2 million.
• Walk the site with the Tab key and zoom to 200%. Two minutes, and you will see immediately how bad it is.
• Check the forms: are errors spelled out in words, is it clear which field is required.
• If you sell into other EU countries, look at their penalties. Poland's ceiling is among the milder ones in the Union; in Spain and Hungary the figures run into hundreds of thousands of euros.
• If you are unsure — write to us, we will look at the site and say plainly whether it needs rebuilding. Contact.

In short

The law has applied since 28 June 2025. Micro-firms are exempt for services, but the exemption stops working once the company grows or acts as a manufacturer. The requirements come down to WCAG 2.1 AA: visible, audible, operable from the keyboard, understandable. An inspection starts with a complaint, the fine follows an ignored order, and the ceiling is 10% of turnover.

And the part legal write-ups rarely mention: an accessible site indexes better and is more comfortable for everyone. The requirements for heading structure, image descriptions and meaningful links overlap almost word for word with what search engines reward — more on that on the SEO page.

Victor Parhimchik, founder of the IT Deweloper web studio