EAA compliance in Sweden — PTS enforcement

Sweden’s implementation of the European Accessibility Act is enforced by PTS (Post- och telestyrelsen), the Swedish Post and Telecom Authority. PTS has taken a proactive approach to enforcement, actively inspecting organisations rather than waiting for complaints to be filed. Our detailed account of how enforcement is actually running in Sweden covers the inspection programme, the organisations under investigation, and what PTS can require.

On 15 October 2025, PTS launched a programme of systematic e-commerce inspections, examining the accessibility of online retailers. It opened seventeen cases in 2025 and eleven more on 3 March 2026, bringing the total to 28. It is a running programme rather than a single wave, and PTS says which companies come next is not yet decided. Among the organisations named are H&M, IKEA, Coop, ICA, and Systembolaget, spanning fashion, furniture, food retail, supermarkets, and specialist retail. Every one of them is a retailer. Our e-commerce guide sets out what the EAA requires of them. The programme remains at the investigation stage: PTS has not issued a penalty against any organisation on the list, and no administrative fine has been confirmed under any European Accessibility Act transposition in the seven markets we monitor.

Banking services are now under supervision too

On 8 September 2026, PTS announced it had begun the first supervision of banking services under the Act. The supervision is directed at larger actors established in Sweden, will run through 2026 and 2027, and PTS has said it will publish the names of the banks as new cases are opened.

The first stage does not begin with PTS testing anything. It begins with what the companies themselves reported about their deficiencies. PTS says it may then go on to check whether the websites and mobile applications are designed in a way that makes them perceivable, operable, understandable and robust.

Sweden’s law names no technical standard

Lag (2023:254) does not mention EN 301 549. Neither does Förordning (2023:676). Neither mentions WCAG.

What section 2 of the Act refers to instead is “a harmonised standard under Article 2(1)(c) of Regulation (EU) No 1025/2012”, the generic definition by cross-reference. No standard is named, because none has been cited for this law.

PTS describes what it assesses against directly: whether services are designed so that they are perceivable, operable, understandable and robust. Those are the four functional principles from the directive itself, not criteria from a standard. PTS’s own standards page describes the work of harmonising a standard against this law as still under way.

Conformance with WCAG 2.2 AA remains the most practical way to build an accessible service. In Sweden it is not what the law asks you to demonstrate.

Five authorities, not one

Förordning (2023:676) splits supervision across five bodies. 28 § gives PTS electronic communications, banking services and e-commerce services. 29 § gives Mediemyndigheten audiovisual media access services. 30 § gives Myndigheten för tillgängliga medier e-books. 31 § gives Konsumentverket and Transportstyrelsen elements of passenger transport.

If you sell online to Swedish consumers, your supervisor is PTS.

What PTS can do

PTS has broad enforcement powers under Lag (2023:254). The Act provides for an uppmaning, then a föreläggande with or without vite (sections 32 and 35), and separately for a sanktionsavgift (section 37). For products, where the operator does not correct the non-compliance, the market surveillance authority must ensure the product is withdrawn or recalled, or its supply prohibited or restricted (Regulation (EU) 2019/1020, article 16(5), applied by section 28 of the Act).

Sanktionsavgift and vite

Lag (2023:254) gives PTS two financial instruments, and the relationship between them matters. A sanktionsavgift can be imposed for breaching any of the duties listed in section 37. A vite can be attached to an order to put a breach right (section 35). Under section 38, a sanktionsavgift cannot be imposed for a breach covered by a föreläggande om vite where that breach is the basis of an application to have the vite imposed.

The maximum Sanktionsavgift is SEK 10,000,000. The figure that matters legally is the krona amount. No penalty decision has been published, and the first wave of supervisory investigations has not yet concluded. We will update this page when that changes.

Why Sweden enforces this way

PTS’s proactive inspection approach reflects the expectation that compliance obligations are known and acted on, not discovered through enforcement.

Organisations that have not yet engaged with EAA requirements should not assume that the absence of a complaint means no exposure. PTS is selecting organisations for inspection independently. Receiving a supervisory notice without prior warning is the experience of the companies named in the first wave.

The duty to tell PTS about a deficiency

Section 24 of Lag (2023:254) requires a service provider to keep its service accessible. If the service does not meet the requirements, the provider must take the measures needed to bring it into conformity and immediately inform the supervisory authorities in the member states where the service is provided. The notice must give detailed information about the non-conformity and the measures taken. A breach of section 24 can draw a sanktionsavgift (section 37).

Organisations operating in Sweden need two things in place: an active accessibility programme, and a process for responding to PTS contact promptly. Neither alone is sufficient.

Companies are reporting their own failures

The Act obliges economic operators to report accessibility deficiencies to the supervising authority. In its 2025 annual report, PTS records 322 such reports received from economic operators, alongside 114 complaints from the public. The 114 and the 124 below are counts taken at different dates, not a contradiction.

That number matters more than it first appears. When PTS announced its supervision of banking services in September 2026, it said the first stage would not begin with PTS testing anything. It would begin with what the companies had reported about their own deficiencies.

Source: PTS Årsredovisning 2025, report number PTS-ER-2026:1.

The microenterprise exemption, and it is written in euros

Section 2 defines a microenterprise as a company with fewer than ten employees and an annual turnover or annual balance sheet total not exceeding two million euro. Not kronor. The Act uses the directive’s currency without converting it.

Section 10 is unusually direct about what follows. Services provided by microenterprises “behöver inte uppfylla tillgänglighetskraven”: they need not meet the accessibility requirements. That is a full exemption for services, not merely relief from documenting an assessment. The products side of the same section gets only the documentation relief.

SFS 2026:1026 amends section 2, the definitions paragraph, with effect from 20 November 2026. The microenterprise threshold is unchanged. Anything quoting Swedish definitions after that date should be re-read against the amended section.

What Swedish enforcement means in practice

The companies named in the first 28 investigations were not selected because complaints were filed. PTS opened supervision on its own initiative. No penalty has been imposed on any of them.

Alongside its own-initiative inspections, PTS has received 124 public complaints so far under the EAA: 110 concerning digital services, primarily e-retail websites, and 14 concerning products including ATMs and ticketing machines. Nineteen companies, about 20%, received more than one. Product complaints are mostly about cash machines. The volume confirms that Swedish consumers are aware of their EAA rights and willing to exercise them. Own-initiative inspections and public complaints are two separate enforcement routes running simultaneously.

Supervision figures last checked 13 September 2026. The 28 e-commerce cases and the banking supervision are both live and will change.

Acting now rather than responding later

The pattern in Sweden, as in the Netherlands and Germany, is that enforcement moves faster than most organisations expect. PTS launched systematic inspections within months of the EAA taking effect. The organisations that started compliance work early are building a governance record. The organisations that have not yet started are not.

Acting now means setting your compliance position on your own timeline. Acting after a PTS notice means responding to theirs.