EAA compliance in Finland — what businesses need to know

The European Accessibility Act became enforceable in Finland on 28 June 2025 under the Act on Accessibility Requirements for Products and Services (568/2023).

Any organisation providing covered digital products or services to consumers in Finland is in scope, regardless of where the organisation is headquartered.

The enforcement authority: Traficom

Traficom (the Finnish Transport and Communications Agency, known in Finnish as Liikenne- ja viestintävirasto) is the designated supervisory authority for EAA compliance in Finland. Traficom receives complaints from users, investigates them, and has the authority to impose penalties where an organisation is found to be non-compliant.

Traficom also conducts its own market surveillance independently of complaints. An organisation does not need to have received a complaint to be subject to a Traficom investigation.

Enforcement in the Nordic region: the Norway case

In June 2025, Norway’s accessibility regulator, Tilsynet for universell utforming av IKT, inspected HelsaMi, a patient portal operated by Helseplattformen AS and used by 425,000 residents of Mid-Norway. It found 119 individual failures across 12 of the 14 legal requirements and ordered them corrected.

When that deadline passed with 64 outstanding, the regulator issued a decision on coercive daily fines of NOK 50,000, with a final deadline of 19 December. A follow-up test that day found six failures still remaining. The fines began the next morning. A further test on 23 December found everything corrected and the supervision was concluded. The penalty ran for two days: NOK 100,000.

Norway sits outside the EU. Its requirements come from the Equality and Anti-Discrimination Act and the regulation on universal design of ICT, which predate the European Accessibility Act and apply to public and private sector alike. The mechanism is not the same law, but it shows what a daily accruing penalty does: months of missed deadlines, and then a fix in three days once the meter started.

How the complaint pathway works

A user who encounters an accessibility barrier on a digital product or service in scope can file a complaint directly with Traficom.

Once a complaint is received, Traficom investigates. If it finds non-compliance, it can require the organisation to remediate. The organisation has the opportunity to respond and provide evidence of its compliance position. This is precisely why having documented compliance activity matters.

Traficom can also initiate an investigation without a user complaint, based on its own market surveillance programme.

What compliance requires

EAA compliance in Finland has four mandatory elements:

• Technical conformance. In practice this means WCAG 2.1 Level AA for web and mobile content, the level EN 301 549 sets out. How the standard relates to the Act explains the detail. EN 301 549 V4.1.1, which incorporates WCAG 2.2, was published on 2 September 2026, and ETSI’s project schedule targets its citation in the Official Journal for 16 December 2026. We track whether EN 301 549 has been cited under the Accessibility Act and date every check.
• A published accessibility statement. A mandatory public declaration of your current conformance level, what is not yet accessible, and your remediation plan.
• Active governance. A named owner for accessibility within the organisation, a regular testing rhythm, and a process that continues to function regardless of team changes. Governance is what turns a one-time audit into ongoing compliance.
• Documentary evidence. Dated assessments, remediation records, and a compliance process that demonstrates the organisation has been actively managing its obligations, not simply asserting them.

Documentary evidence is particularly important in Finland’s enforcement environment. Because complaints can arrive promptly, organisations need to be in a position to respond quickly and substantively. Evidence of active compliance management is what distinguishes a defensible position from one that is not.

Which organisations are covered

The standard EAA scope applies in Finland: e-commerce, banking and financial services, electronic communications, audiovisual media services, and transport services provided to consumers. Organisations based outside Finland that offer covered services to Finnish consumers are in scope on the same basis as Finnish-based organisations.

The microenterprise exemption applies where an organisation has fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million. Both conditions are required simultaneously. Meeting one but not the other does not qualify an organisation for the exemption. Organisations that believe they may qualify should verify this position before relying on it.