Sweden's PTS is already investigating named retailers
28 supervisory investigations, opened since October 2025, into e-commerce accessibility. H&M, IKEA, and Coop are among the companies named. Here is what PTS is actually doing, and what it means if your organisation sells into Sweden.
What PTS actually started doing in October 2025
Sweden's Post and Telecom Authority, PTS, launched a systematic e-commerce inspection programme in October 2025. This is not a complaint-response process. PTS is proactively testing online retailers against EN 301 549, using a combined methodology: automated WCAG 2.1 AA scans, manual keyboard-only navigation testing, and screen reader testing.
PTS has opened 28 supervisory investigations to date, with the full list published on 3 March 2026. Named companies span fashion, furniture, food retail, and specialist retail: H&M, IKEA, Coop, ICA, and Systembolaget are among the organisations under investigation. This information is a matter of public record, not a leak or a rumour: PTS's approach is deliberately proactive and public, not quiet.
No fine has been issued against any of these companies yet. An investigation is not a fine, and none should be described as one. What has happened is real and unusual: a national regulator systematically testing named, identifiable retailers, in public, using a defined methodology. That is a meaningfully different posture than most EU markets have shown so far.
Complaints are already coming in from real users
Alongside the proactive inspections, PTS has received 124 public complaints: 110 concerning services, 14 concerning products. This detail matters beyond the raw number. It confirms that Swedish consumers already know accessibility rights exist under the EAA and are willing to use the complaint mechanism, not just wait for regulators to find problems on their own.
Sweden's existing accessibility culture, shaped by decades of disability rights legislation predating the EAA, means expectations here were already higher than in many other EU markets before the EAA existed at all. The complaint volume reflects that baseline, not a sudden shift in awareness.
The penalty structure, and why the market ban matters more than the fine
The maximum administrative fine under Swedish EAA enforcement is SEK 10,000,000, approximately €900,000, among the highest ceilings in the EU. But the fine is not necessarily the sharpest consequence available to PTS.
PTS also holds market ban authority: it can prohibit the sale or distribution of a non-compliant product or service within Sweden entirely. For a retailer with meaningful Swedish revenue, losing market access, even temporarily, is frequently a more severe commercial consequence than the fine itself. A fine is a cost. A market ban is a revenue stop.
What this means if you sell into Sweden
Three things are true at once, and worth holding together rather than separately. First, no fine has landed yet, anywhere in Sweden, against any company. Second, the investigation phase is real, active, and already names specific companies publicly. Third, the review is explicitly continuing into 2026, which means the 28 current investigations are very unlikely to be the final number.
If your organisation sells consumer-facing digital products or services into the Swedish market, the honest question is not whether PTS's approach is real. It demonstrably is. The honest question is whether you know where your own product stands against the same methodology PTS is already using: automated testing, manual keyboard navigation, and screen reader testing, specifically.
The gap between "no fine yet" and "not at risk" is smaller than it looks. An active, named, methodical investigation programme is the stage immediately before enforcement, not evidence that enforcement isn't coming. Companies already under review did not expect to be selected either.
How this fits into the broader EAA enforcement picture
Sweden's posture is one of several distinct enforcement pathways active across the EU right now. The EAA fines and penalties comparison covers how Sweden's approach compares to Ireland's criminal liability track, the Netherlands' audit-based approach, and other active markets. For a full methodology on auditing your own product against the same standard PTS is testing against, the audit guide covers the complete process.
Find out where you stand against Sweden's own testing methodology
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