What Polish Businesses Need to Know About EAA Compliance

What the European Accessibility Act in Poland means for your business

The European Accessibility Act in Poland sets minimum accessibility requirements for certain products and services sold or offered on the Polish market. It springs from Directive (EU) 2019/882. Polish firms that make, sell, supply or procure in-scope goods and services must check whether the rules apply to them and prepare to show conformity.

Core facts you must know

• Legal basis: the EAA is an EU directive: Directive (EU) 2019/882.
• Key dates: the EU transposition deadline was 28 June 2022 and the EAA applies across member states from 28 June 2025. Businesses should use the 2025 date as the practical compliance target.
• Objective: to make certain products and services accessible to persons with disabilities so they can use them independently and on an equal basis.

Which products and services are likely in scope

The directive covers a range of goods and services that commonly create barriers. Typical categories to check are:

• Information and communication technology products and services, such as computers, smartphones and operating systems
• Consumer electronics and media devices
• Banking services and terminals, including ATMs and point of sale devices
• e-books and e-readers and related software
• e-commerce platforms and ticketing services to the extent the service is covered by the directive

This list is indicative. Whether a specific product or service is in scope depends on the national transposition and implementing measures. Check the Polish implementing law and guidance from the national authority.

Who is responsible

Responsibility depends on your role.

• Manufacturers must design and produce goods that meet accessibility requirements and keep technical documentation.
• Importers and distributors must verify that products they place on the market meet the rules.
• Service providers must make the service accessible and provide an accessibility statement and complaint process if the service is in scope.

How to determine if your product or service is in scope

1. Map the product or service features that affect ease of use for people with disabilities.
2. Compare those features to the typical categories listed above.
3. Consult the Polish implementing act and any national lists or guidance from the market surveillance authority.
4. If unclear, document your analysis and seek a legal or technical opinion.

Standards and technical references to use

European harmonised standards provide a practical route to conformity. The most used standard for ICT accessibility is EN 301 549. For web and mobile content, WCAG from the W3C is the technical reference that national standards and EN 301 549 rely on. Also use WAI-ARIA to improve assistive technology compatibility.

How to show compliance (practical steps)

1. Accessibility audit and gap analysis

Run a technical audit against EN 301 549 or the applicable standard. For web and apps, test against WCAG (use automated checks, manual testing with keyboard and screen reader, and real-user testing).

2. Technical documentation

Prepare documentation that explains how the product or service meets the requirements and records test results. Keep records for market surveillance inspections.

3. Accessibility statement and complaint process

Publish an accessibility statement in Polish. The statement should identify the scope, known limitations, contact details for accessibility queries and a clear way to submit complaints. Track and resolve complaints within the timelines set by national law.

4. Procurement and contracts

Update supplier contracts and procurement templates to require accessibility claims to be backed by evidence and documentation.

5. Training and governance

Assign a responsible person, train staff in accessibility basics and include accessibility checks in your development and QA cycles.

Testing methods and who can test

• Automated testing tools catch common issues quickly, but they miss many problems. Use them early and often.
• Manual testing with assistive technologies finds keyboard, focus and reading order issues.
• Include people with disabilities in usability testing. Their feedback finds real-world barriers.
• Consider an independent conformity assessment if you need formal evidence for buyers or regulators.

Enforcement and penalties (what to expect)

Enforcement is handled by national authorities. Sanctions, product recalls or orders to stop sales are possible when products or services do not comply. The exact procedures and penalties are set in Polish transposition law. Keep full documentation so you can demonstrate due diligence.

Common mistakes Polish businesses make

• Waiting until the deadline to start. Remediation is often more expensive than building accessibility in.
• Relying solely on automated scans and not doing manual tests or real-user testing.
• Publishing a vague accessibility statement without contact or a complaints procedure in Polish.
• Not updating procurement to require evidence from suppliers.

Quick 6-step implementation plan for SMEs

1. Decide if the EAA covers your product or service and document that decision.
2. Run a scoping audit using EN 301 549 and WCAG checks for digital products.
3. Fix the highest-impact issues first: keyboard access, readable text, clear labels and error handling.
4. Publish an accessibility statement in Polish and add a complaints contact.
5. Update supplier contracts and procurement templates to require accessibility evidence.
6. Schedule regular re-tests and keep technical documentation for inspections.

Cost considerations and business benefits

Costs vary widely by product and how early you start. Remediation can be sizeable for legacy systems. On the benefit side, accessible products reach more customers and reduce support calls. Document costs and expected gains as part of your business case.

Where to find technical and legal help

• Use the W3C resources for WCAG and WAI-ARIA guidance.
• Consult the official Polish government and standards bodies for national guidance and the exact text of the implementing law.
• Hire an accessibility consultant for audits and remediation plans when internal skills are limited.

Final checklist for compliance readiness

• Have you confirmed whether the EAA applies to your product or service?
• Do you have an accessibility audit and remediation plan?
• Is there an accessibility statement in Polish with a named contact?
• Have you updated procurement and supplier contracts to demand evidence?
• Are test results and technical documentation stored and available for inspection?

Start now if you have not already. Use EN 301 549 and WCAG as your technical references. Keep records and make the accessibility statement visible in Polish. That will put you in the best position when national enforcement begins.