---
title: "The Polish Accessibility Act - who it actually covers, what it requires, and where to start"
url: "https://wzor.biz/en/blog/polski-akt-o-dostepnosci-kogo-dotyczy-czego-wymaga/"
description: "Since 28 June 2025, online stores, consumer banking and e-books in Poland must be digitally accessible. Here is who the act covers, what it really requires - and why the word “WCAG” does not appear in it."
lang: "en"
---
[UX audit](https://wzor.biz/en/blog/category/ux-audit/)

# The Polish Accessibility Act \- who it actually covers, what it requires, and where to start

 [![](https://wzor.biz/_astro/patryk-korycki.D95uAkaq_Z1DJTgc.webp) Patryk Korycki CEO, Business Analyst](https://wzor.biz/en/team-and-partners/patryk-korycki/)

Published 3 August 2026 11 min read

![WCAG 2.2 and EAA 2025 - digital accessibility](https://wzor.biz/_astro/wcag-eaa.BPoTw2GH_1b6CYk.webp)

The act has been in force since 28 June 2025, and most conversations about it still start from two false premises: that it is about an “accessibility statement”, and that the fine is 4% of turnover. Neither is true - the first comes from a different act, the second from the GDPR.

The **Polish Accessibility Act** - formally the [Act of 26 April 2024 on ensuring that economic operators meet the accessibility requirements of certain products and services](https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20240000731) (Journal of Laws 2024, item 731) - transposes the directive known as the European Accessibility Act into Polish law. This piece exists so that after reading it you know three things: whether the act applies to your company, what exactly you have to do, and what you do not have to do even though the market is selling it to you.

## Two acts that everyone confuses

Most of the confusion comes from the fact that Poland has **two separate digital accessibility acts**, and they address entirely different parties.

|     | Act of 4 April 2019 | **Polish Accessibility Act (2024)** |
| --- | --- | --- |
| **Who it covers** | public bodies - offices, schools, hospitals, municipal companies | **economic operators** - private companies |
| **In force since** | 2019/2020 | **28 June 2025** |
| **Scope** | websites and mobile apps | consumer products and services, including online stores |
| **Document** | **accessibility statement** on the site | accessibility information in the terms of service |
| **Standard** | WCAG 2.1 AA named in the annex | functional requirements, no standard named |

If you run a store, a bank or a streaming platform, **the accessibility statement does not apply to you** - it is an instrument from the act on public bodies. Your obligation is a different one: to describe in the terms of service (or an equivalent document) how the service meets the accessibility requirements. It sounds similar, it is not the same thing, and the templates circulating on the market mix the two up.

## Who it actually covers

The act has a **closed list**. It does not cover “all websites” - it covers the products and the services it names.

**Products:** computer hardware and operating systems (desktops, laptops, smartphones, tablets), payment terminals, self-service terminals (ATMs, ticket machines, check-in kiosks), consumer telecommunications terminal equipment (routers, modems), equipment for accessing audiovisual media services (set-top boxes, remotes) and e-book readers.

**Services:** electronic communications services, services providing access to audiovisual media services, selected digital elements of passenger transport services, consumer banking services (including helplines and helpdesks), e-book distribution and - by far the broadest in practice - **e-commerce**.

E-commerce here means a service provided at a distance, through a website or an app, by electronic means and at the individual request of a **consumer**, with a view to concluding a contract. Two things follow from that definition, and every client asks about both:

-   **A pure B2B store is out of scope.** The act protects consumers. If you sell exclusively to companies, through closed trade accounts, this act does not cover you. Watch out for mixed models: a store where a consumer can buy without registering is a consumer store, regardless of how much of your revenue comes from B2B.
-   **A brochure site is out of scope too** - provided you genuinely cannot conclude a contract through it. A contact form is not yet e-commerce. A configurator with a payment step is.

### The microenterprise exemption is narrower than it looks

**Microenterprises providing services** are exempt: fewer than 10 people employed **and** annual turnover or balance sheet total not exceeding the equivalent of EUR 2 million. Both conditions have to be met at once.

Three caveats that decide the matter in practice:

1.  **The exemption covers services, not products.** If you place any of the products listed above on the market, being a microenterprise does not release you - it only limits your administrative obligations.
2.  **It is an exemption, not a deferral.** Cross the threshold in the next financial year and the obligation starts to apply - and adapting an interface is not a one-week job.
3.  **A statutory exemption is not the same as no risk.** A customer who cannot complete an order does not check your headcount first.

## What the act requires - and why the word “WCAG” is not in it

This is where most material on the market oversimplifies. **The act does not order you to “implement WCAG”.** It orders that websites and mobile apps be **perceivable, operable, understandable and robust** - the four principles that form the backbone of [WCAG](https://www.w3.org/TR/WCAG22/).

The mechanism is the same as in other product safety law: the statute states a functional requirement, and conformity is demonstrated through a **harmonised standard**. That standard is the European **EN 301 549**, which carries the WCAG criteria up to the level of regulation. The practical consequences:

-   **The reference level is AA**, not AAA. AAA is not a target or a “better version of compliance” - it is a set of criteria that the W3C itself does not recommend requiring for entire sites.
-   **Design to WCAG 2.2, report against the version in the standard.** WCAG 2.2 is a superset of 2.1: meet 2.2 and you meet 2.1 automatically. The reverse does not hold - 2.2 added criteria on focus visibility, target size and authentication that does not rely on memory, among others. Doing “2.1 only” because that is what an older version of the standard says means deliberately stepping several years back on a product that will live longer than that.
-   **Conformance is a state, not a one-off project.** Every new component shipped can break it.

## What the act does not require

Just as important, because this is where the most money is spent for no effect.

**It does not require an accessibility widget.** Overlays - the floating icon with contrast and font-size sliders - do not make a site conformant. They patch a layer that users of assistive technology already configure at the system level, and they can interfere with screen readers by stealing focus and substituting labels. Conformance is assessed on the page’s code, not on the presence of a widget.

**It does not require an external audit.** The act requires the service to **be** accessible and requires you to be able to describe how you ensure that. An audit is the fastest route to both, but it is a tool, not a legal obligation.

**It does not require conformance at any cost.** There is an exception: **disproportionate burden** or a **fundamental alteration** of the nature of the product or service. It is not a box to tick, though - relying on it requires a documented assessment, specific to the entity and independent of its size. An assessment that is not written down does not, in practice, exist.

**It does not require a certificate.** There is no state accessibility certificate, and anyone selling you one is not selling you conformance.

## Fines, complaints, and the 30 days that decide

Supervision rests primarily with the **President of the PFRON Management Board**, alongside sectoral authorities (the Financial Ombudsman for financial services, the President of UKE for communications, among others) and customs authorities for products.

**The fine is up to ten times the average monthly salary in the national economy for the previous year, as announced by the President of Statistics Poland - and no more than 10% of the turnover achieved in the preceding year.** The amount depends on, among other things, the gravity of the infringement, the number of non-compliant products or services and the number of people affected. The “4% of turnover” repeated online comes from the GDPR and does not apply here.

In practice, though, the **complaints procedure** matters more than the rate, because it is what sets everything else in motion:

-   a consumer who considers a service inaccessible files a complaint **directly with the service provider**, indicating which requirement was not met.
-   the provider has **30 days** to handle it (60 days in particularly complex cases, after informing the complainant).
-   **failure to respond within the deadline means the complaint is upheld** - the consumer is found right by operation of law.
-   independently of that, a report can go to PFRON, which has 30 days to handle it or pass it to the competent authority.

That is the sentence worth remembering instead of the fine: **a missed deadline loses the case without it ever being considered on the merits.** Before you fix anything in the interface, check whether anyone in the company would even receive such a complaint and answer it in time.

## Transitional periods - what can wait

The act provides two real buffers, and both are narrower than their popular summary (“we have until 2030”) suggests:

-   **Service contracts concluded before 28 June 2025** may continue unchanged **until 28 June 2030**. That covers an ongoing contract - not new customers and not new features.
-   **Self-service terminals in use before 28 June 2025** may be used for their economically useful life, **up to 20 years** from the date they were first put into use.

For an online store selling to new consumers today, neither buffer applies. The deadline passed on 28 June 2025.

## Where to start - four steps, in order

**1\. Establish the scope before you measure anything.** List which of your surfaces are a service under the act: the store, the customer panel, the mobile app, transactional email, the invoice PDF, the helpline. People audit the homepage and a category page, then lose on the payment step and on a PDF with no text layer.

**2\. Measure the state, but not with a scanner alone.** Automated tools (axe, Lighthouse, WAVE) catch a fraction of real problems - missing labels, contrast, attributes. They will not tell you whether the focus order makes sense, whether an error message is announced, whether a modal can be closed from the keyboard, whether a “read more” link means anything out of context. That takes walking the path with a keyboard and a screen reader (NVDA, VoiceOver) - the same work as a [proper UX audit](https://wzor.biz/en/blog/audyt-ux-strony-internetowej-kompletny-przewodnik-metody-etapy-koszty-i-roi/), against a different checklist.

**3\. Prioritise by the purchase path, not by defect count.** A hundred violations in the footer are worth less than one in the cart. A defensible order: payment → cart → product page → search and filters → registration and login → everything else.

**4\. Fix it in components, not in views.** A fix at the view level comes back next sprint. A fix in the [design system](https://wzor.biz/en/blog/design-system-co-to/) - an accessible button, a form field with a label and an error description, a modal with a focus trap, a visible focus ring - stays, and carries over to every screen after it. That is the only version in which conformance is not a recurring cost.

## Five mistakes that recur most often in stores

1.  **Focus invisible or removed.** `outline: none` in a CSS reset is the single most common cause of non-conformance. Someone navigating by keyboard stops knowing where they are.
2.  **Validation errors signalled by colour alone.** A red border with no text and no `aria-describedby` association does not exist for a screen reader, nor for someone who does not distinguish colours.
3.  **Contrast on secondary text.** Grey on light grey in captions, placeholders and sale prices. The threshold is 4.5:1 for body text and 3:1 for large text.
4.  **Carousels and modals with no keyboard support.** An element you can enter but cannot leave with Escape blocks the entire page.
5.  **Product images without meaningful alternative text** - or with a file name instead of a description. This also covers graphics carrying prices and promotion terms, because what disappears there is commercial information, not decoration.

None of these five is expensive on its own. What is expensive is finding them after the fact, in thirty places at once, under the pressure of a complaint deadline.

## This is not another GDPR

The Polish Accessibility Act is not another GDPR - it does not demand new documentation for everything, and it does not threaten fines at the percentage of turnover the market keeps repeating. It demands something harder to fake: that the product **can actually be operated**. That is design and front-end work, not legal work, and its side effect is an interface that is easier for everyone - because visible focus, readable contrast and a sensible error message are not an accommodation for a minority.

If you are unsure whether the act applies to your company, or you know it does and do not know how much work stands between you and conformance - [book a free consultation](https://wzor.biz/en/free-consultation/). We will walk through the scope, show what actually surfaces on your purchase path, and tell you plainly whether you need an audit or a fix in your components.

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About the author

## [Patryk Korycki](https://wzor.biz/en/team-and-partners/patryk-korycki/)

CEO, Business Analyst

Co-founder and CEO of the UX agency Wzór. For 9 years he has been running UX/UI projects for startups, software houses and large companies - from audits, research and business analysis, through product strategy, to delivery. He specialises in projects at the intersection of e-commerce, SaaS and fintech. An Interactive design practitioner - designing UX/UI directly in code.

[LinkedIn](https://www.linkedin.com/in/patryk-korycki/) [Book a consultation](https://wzor.biz/en/free-consultation/)

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