The Digital Services Act brought online stores within the scope of accessibility requirements

The Digital Services Act has been updated, and the new amendments have brought online shops, e-books, certain passenger transport and banking services, as well as services providing access to audiovisual content and communications services. The amendments to the Digital Services Act stem from the EU Accessibility Directive. Services must comply with the accessibility requirements from 28 June 2025, when the transition period ended.

If the Digital Services Act means your business is now subject to accessibility requirements, but you’re not sure how accessible your online service is – don’t worry, we’ve got you covered! In this article, we’ll explain who the changes affect, how they’ll impact you, and where to start when it comes to meeting accessibility requirements.

What is the EU Accessibility Directive?
Amendments to the Digital Services Act brought new services and service providers within the scope of accessibility requirements
When did the amendments to the Digital Services Act come into force?
What do the changes to the accessibility requirements under the Digital Services Act mean for online retailers, and how should they go about implementing them?
- Where should you start if you’re not sure how accessible your shop is?
An accessibility statement will be mandatory from now on
The Digital Services Act paves the way for a more inclusive digital world
- Shall we get started?

What is the EU Accessibility Directive?

The aim of the EU Accessibility Directive is to improve the accessibility of products and services for all users, including people with disabilities and older people. Since 1 February 2023, Finnish national legislation has required public authorities, public organizations and providers of public services to make their services accessible (see the Act on the Provision of Digital Services). The Digital Services Act has now extended the accessibility requirements to cover a wider range of services and service providers.

A service governed by the Digital Services Act must be implemented in accordance with the Web Content Accessibility Guidelines (WCAG) set out in the Accessibility Directive. The WCAG 2.2 guidelines provide a detailed description of the technical and content-related requirements necessary to ensure a minimum level of accessibility.

Amendments to the Digital Services Act brought new services and service providers within the scope of accessibility requirements

The updates to the Digital Services Act promote digital equality and ensure that an increasing number of people can access digital services on an equal footing. As a result of these changes, a wider range of digital service providers must take better account of the needs of different users and ensure that their products and services are accessible to as many people as possible.

As a result of the changes, the following have now come within the scope of the accessibility requirements:

Online shops available to consumers
- The regulations apply to all online shops where consumers can purchase goods and services via the internet (excluding micro-enterprises).
E-books
- The scope of the new regulations covers e-books, as well as the associated websites and mobile applications used for reading and accessing them.
Some passenger transport services
- In addition to public transport, accessibility requirements are being extended to cover the private sector. Passenger transport includes, for example, rail, bus and air transport, as well as scheduled commercial maritime transport.
Consumer banking services
- The scope of the regulation will be broadened to cover various digital banking services, such as consumer payment services, basic payment accounts, credit, wealth management and investment advice.
Services providing access to audiovisual content
- An audiovisual content service refers to a service that provides television broadcasts or on-demand programs to the public, such as Netflix and Yle Areena.
Communications Services
- Communication services refer to instant messaging apps aimed at consumers, such as WhatsApp, Signal and Messenger.

The Digital Services Act does not apply to micro-enterprises. Micro-enterprises are businesses with fewer than 10 employees and an annual revenue or balance sheet total of no more than 2 million euros. Although micro-enterprises are not obliged to comply with accessibility requirements, the Regional State Administrative Agency encourages these businesses to provide their services in accordance with them. Accessible online services are, after all, in everyone’s interest, so it is worth taking these requirements into account even if you are not covered by the law. When you design a digital service with accessibility requirements in mind, you boost your business by offering a pleasant user experience to all types of users. Accessible websites and other online services promote equality and offer a competitive advantage that can help you expand your market share!

When did the amendments to the Digital Services Act come into force?

The services mentioned must comply with the general accessibility requirements and obligations set out in the Digital Services Act from 28 June 2025. The services must meet both the general accessibility requirements and the additional service-specific requirements, and they are also subject to additional obligations regarding the accessibility statement.

What do the changes to the accessibility requirements under the Digital Services Act mean for online retailers, and how should they go about implementing them?

If your business does not fall into the micro-enterprise category and your online store is aimed at consumers, the Digital Services Act therefore requires your online store to comply with the new accessibility requirements from 28 June 2025.

Where should you start if you’re not sure how accessible your shop is?

The first step is to have a professional carry out an accessibility audit
- If you are unsure whether your online store meets the necessary accessibility requirements, we recommend an accessibility audit, during which we will assess your current accessibility status. For example, an accessibility audit carried out by one of our Hurja accessibility experts will provide you with detailed information on the current state of accessibility of your website or other online service, and how you can start to improve– all presented in an easy-to-understand format!
  - An accessibility audit will help you:
    - A comprehensive overview of the current state of accessibility and the areas requiring improvement in order to meet the requirements
    - Mandatory accessibility statement. Online store must henceforth include an accessibility statement containing the necessary information on the accessibility status of the service. If you already have an accessibility statement, we will update it as necessary.
    - A comprehensive report on the accessibility audit and its findings. The report contains the necessary suggestions for improvements for the developers, enabling them to rectify any accessibility issues with the help of the report.

Check out our work: Ava Academy’s website accessibility audit paved the way toward more equitable educational services

Please note: The new WCAG 2.2 accessibility guidelines have already been published. Compliance is not yet required by law, but it will be in the future (probably within the year). Even if your online store is currently accessible in accordance with the WCAG 2.1 guidelines, please note that when WCAG 2.2 comes into force, you will probably need to make further changes to your service. We are already carrying out accessibility audits using the WCAG 2.2 , ensuring that, once accessibility fixes have been implemented, your online store is ready for both the entry into force of the WCAG 2.2 guidelines and the amendments to the Digital Services Act.

Following the accessibility audit, any accessibility issues identified must be rectified on the online store
- Following the accessibility audit, any accessibility issues must be rectified and the accessibility statement updated to reflect the changes made.

The choice is between revamping the online store or launching a new one:
- If your online store is now outdated and you are planning to revamp it or set up a completely new one: be sure to take the new accessibility requirements (amendments to the Digital Services Act and WCAG 2.2) into account during implementation.
- If you wish, we at Hurja can design and build a fully accessible online store for you.

Check out our work: UX/UI design of the Lakitutka web service’s new user interface with accessibility in mind

An accessibility statement will be mandatory from now on

So, if your business falls within the scope of the Digital Services Act in the future, you will be required to have an accessibility statement on your website that describes the accessibility of your service. The accessibility statement describes the current state of the service’s accessibility, any deviations from it, and how users can provide feedback on accessibility.

In the accessibility statement, the service provider must also provide information on, for example, the equipment required to use the service, if the use of the digital service requires a specific device, such as a GPS. The service provider must also provide information in the accessibility statement on how the device in question connects to the digital service, what its accessibility features are, and how it works in conjunction with assistive technologies and other arrangements that support the use of the service.

The service provider must also provide information on how any additional service-specific requirements have been taken into account. Furthermore, the accessibility statement must describe how the service has taken into account the additional requirements applicable to that service. At Hurja, the accessibility statement is included in the accessibility audit. Without accessibility testing and auditing, it is generally not possible to produce an accessibility statement, as the statement must be able to describe the state of the digital service’s accessibility in relation to the criteria.

The accessibility statement includes:
- General information, i.e. an overview of the digital service, such as its name, a description of its purpose and details of the service owner/administrator.
- A new requirement: information on how to use the service and what functions it offers, as well as any instructions on how to use the service. The service provider must also provide information on compliance with any additional service-specific requirements.
- Information on the current state of accessibility, i.e. a description of the service’s current accessibility status
  - Which accessibility criteria and level (e.g. WCAG 2.2 Level AA) must the service comply with?
  - information on how well the service meets the accessibility criteria – e.g. fully, partially or not at all – as well as more detailed information on any non-compliance.
    - a description of the issue and a statement of which criteria have been breached, e.g. “Not all images have adequate alt text. (WCAG 1.1.1)”
- If desired, you can also describe the measures that have been taken to improve accessibility, such as the technologies used to ensure that the website’s content is easily accessible to all users.
- Contact details and feedback
  - the company’s contact details (email and/or telephone number) so that users can report accessibility issues or provide feedback on accessibility
  - as well as the contact details of the supervisory authority (Regional State Administrative Agency for Southern Finland, Accessibility Monitoring Unit) for the purpose of lodging complaints, should the user’s feedback not be addressed satisfactorily and/or within two weeks, or should the user receive no response at all.
  - The law stipulates that feedback must be dealt with appropriately. This means that the service provider must process the feedback received and take the necessary measures to improve accessibility.

The Digital Services Act paves the way for a more inclusive digital world

The amendments to the Digital Services Act represent a step toward a more inclusive and user-friendly digital world. The aim is to ensure that everyone can benefit equally from online resources, regardless of their abilities or background. In this way, we are laying the foundations for a better digital future that is open to all.

At Hurja, we possess extensive expertise in the principles, specific characteristics and best practices relating to the development of digital services. We possess technical, visual and content-related expertise, which we use to create impressive and accessible websites for our clients and to help ensure that existing services meet accessibility requirements.

One of the three priorities of Hurja’s corporate sustainability program is the UN Sustainable Development Goal: reducing inequality. Under this goal, our program includes, among other things, promoting digital equality, which we are advancing by increasing awareness and expertise in accessibility both internally and externally.

If your online store or other digital service will be subject to accessibility requirements in the future, it’s a good idea to start preparing well in advance. We’re here to help you through this process. Let’s begin the journey toward a more equal digital world with an accessibility audit, during which we’ll assess the current state of your service’s accessibility and determine how to rectify any shortcomings we find. So don’t worry – we’ll help you meet the new requirements. Get in touch!

Download accessibility guide