Website and online store accessibility in Poland in 2026: who the law covers and who it doesn't

Does the law cover my website

The Polish act covers selected products and services offered to consumers. The services include telecommunications, retail banking, e-books, services related to passenger transport, and e-commerce services. For a small business, the last category is the one that matters.

The act defines e-commerce services as "services offered or provided at a distance through websites and mobile devices, by electronic means and at the individual request of a consumer for the purpose of concluding a contract." A few practical conclusions follow. The simplest test: can an individual customer buy or book something through the site.

• An online store selling to individual customers falls within the definition.
• A site where a guest books and pays for a stay or an appointment is also used to conclude a contract at a distance, so by definition it is an e-commerce service.
• A business-card site that only informs and lists a phone number or email is not used to conclude a contract, so the definition alone does not bring it into scope. The line can be blurry with order or inquiry forms, so such cases are worth assessing individually.
• Selling only to businesses: the act covers services offered or provided to consumers.

The microenterprise exemption

Article 4(1) of the act says plainly that it does not apply to services offered or provided by microenterprises. This includes microenterprises running an online store or online bookings.

The act itself does not define a microenterprise. The EU directive it implements defines one as an enterprise employing fewer than 10 persons with an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. Article 7 of the Polish Entrepreneurs' Law sets similar thresholds and looks at at least one of the last two financial years. If a business is close to the thresholds, it is worth confirming with an accountant or a lawyer.

The exemption covers services, not the products covered by the act, such as payment terminals or e-readers. The act also tasks the minister responsible for regional development with preparing guidelines and tools that help microenterprises provide accessibility. So a microenterprise does not have to meet the requirements, but it can treat them as good practice and adopt them step by step.

What the law requires from a store or booking site

The act does not mention WCAG by name. It requires the site and the information about the service to be perceivable, operable, understandable and compatible, delivered through more than one sense, with a suitable font, sufficient contrast and alternatives for non-text content (Article 12). For e-commerce, Article 18 adds accessible identification, security and payment functions, and passing on accessibility information about the products sold where the obliged party, such as the manufacturer, has provided it.

A service that conforms to a harmonised standard is deemed to meet the requirements to the extent the standard covers them (Article 20). The Polish Ministry of Digital Affairs points to EN 301 549 and states that the version in force is V3.2.1 from 2021, with an update expected to be completed in the third quarter of 2026. In September 2026, EN 301 549 V4.1.1 was published, with its web requirements aligned to WCAG 2.2: conformance with WCAG 2.2 Level AA is equivalent to meeting the requirements of clause 9 of the standard. The new version gives a presumption of conformity with the directive only once it is cited in the Official Journal of the EU, and I could not confirm that as of this writing.

In practice, WCAG 2.2 Level AA is a sensible target. W3C encourages using the latest version, and content that meets WCAG 2.2 also meets WCAG 2.1 and 2.0.

The second duty is accessibility information. The service provider publishes, in its terms of service or an equivalent document, information about the service, the information needed to use it, and a description of how the service meets the accessibility requirements (Article 32). This information must itself be accessible. If the service does not meet the requirements, the provider must promptly notify the Minister of Digital Affairs and describe the corrective measures. The ministry provides a template, and one notice can cover all the affected services.

Exceptions: older content, third-party content, disproportionate burden

The requirements apply only to the extent that they do not require a fundamental alteration of the basic nature of the service and do not impose a disproportionate burden on the business (Article 21). This is not a loophole without paperwork. The business assesses it against the criteria in the act, including the ratio of costs to sales revenue and the benefit for persons with special needs. The assessment must be documented and kept for 5 years after the service stops being offered, and if the business does not meet the requirements on that basis, it must promptly notify the supervisory authority in writing. When relying on disproportionate burden, the assessment is repeated at least every 5 years and whenever the service changes.

Separately, the act excludes several types of content and provides a transition period for contracts. If a site has older materials, it is worth reviewing them against this list before starting to fix them:

• pre-recorded audio and video and document files published before June 28, 2025 (Article 86),
• archived content that has not been updated or edited since June 28, 2025,
• content the business does not fund, create or control (Article 4),
• service contracts concluded before June 28, 2025, which may continue unchanged until they expire, but no later than June 28, 2030 (Article 85).

Who enforces it, how complaints work, and the penalties

E-commerce services are supervised by the minister responsible for computerization, that is the Minister of Digital Affairs. The supervision system is coordinated by the President of the Management Board of PFRON (the State Fund for Rehabilitation of Disabled Persons), who can also carry out inspections.

If an inspection finds gaps, the authority calls for corrective action and sets a deadline of no more than 120 days to submit evidence. It can also issue a decision banning the service for up to 180 days. Under Article 73, the fine for a service provider is "up to ten times the average monthly salary in the national economy for the previous year," as announced by the President of Statistics Poland, "but not more than 10% of turnover" from the previous financial year. The amount depends on factors such as the seriousness of the violation, the number of non-compliant services and the number of people affected.

According to the Polish parliament's legal database, the act has not been amended so far. I could not confirm in official sources any information about the first fines imposed on online stores, so I give no examples.

Consumer complaints go to the business first. It is worth listing an address for reporting accessibility problems on the site and deciding who will answer them on time:

• a complaint can be filed in writing, orally, or electronically if the business has designated such a channel,
• the business replies within 30 days, or in particularly complex cases by a new deadline no later than 60 days from receiving the complaint,
• if the business misses the deadline, the complaint is deemed accepted as requested, and the request must be fulfilled within 6 months,
• regardless of the complaint, anyone can file a notice with the President of PFRON, who reviews it or forwards it to the competent authority within 30 days.

Where to start: a checklist for stores and booking sites

I check sites in order, starting with whatever blocks a purchase or booking and moving on to smaller fixes. This list does not replace a full audit, but it shows where the work usually begins:

• The purchase or booking flow, from choosing a product or date to payment, completed using only the keyboard.
• Visible focus: at every step you can see which element is active.
• Forms: every field has a label, and errors are described in text that says what to fix, not just with a red border.
• Contrast of text, prices and buttons measured with a tool, including on mobile.
• Alt text for product and interior photos, with decorative elements hidden from screen readers.
• Login, codes and the payment widget, because the act explicitly lists identification, security and payment functions.
• Accessibility information in the terms of service or an equivalent document, plus a channel for reporting problems.

How to measure it and what to do next

Automated tools such as axe or Lighthouse quickly catch some of the problems. W3C points out, however, that tools cannot check all accessibility aspects automatically, human judgment is required, and results can be misleading. That is why after an automated test I go through the site manually: with the keyboard, zoomed in, and with a screen reader.

For an apartments website in Warsaw, I measured accessibility with axe-core and made fixes based on the results. For new stores and booking systems I run this check before launch, and for existing sites I can prepare a list of fixes ordered by priority. Just send a message through the contact form.

Frequently asked questions