Sweden’s accessibility law for products and services

The Swedish Act on the accessibility of certain products and services implements the European Accessibility Act and took effect on 28 June 2025. It covers areas including e-books, e-commerce services and certain consumer banking services. It does not say that every PDF from every business is covered.

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Microenterprises providing services have a specific exemption. Do not assume an identical exemption from all product requirements. Transitional provisions also address certain older documents and contracts. Read the provision that applies to the actual situation.

The year 2030 is not a general postponed deadline for all PDFs. It appears in defined transitional arrangements.

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The statutory definition has two elements: fewer than ten employees, and annual turnover or annual balance-sheet total not exceeding two million euros. Calling a business “small” is not enough; the evidence needs to establish the definition.

Under section 10, services supplied by microenterprises need not meet the accessibility requirements. The relief for microenterprises handling products is different: it concerns specified documentation and notification duties for the section 7 assessment. It does not remove every product requirement.

A small agency remediating documents for a larger service provider therefore cannot use its own size as the answer to the client’s obligations. Assess the correct operator and product or service. Their contract may also require accessible material regardless of the supplier’s size.

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The transitional provisions distinguish content, products and service contracts. Point 2 excludes, among other things, document file formats on websites and apps published before commencement on 28 June 2025. Archived content has a separate condition concerning updates or edits after commencement. Identify the provision relevant to the particular content.

Point 3 concerns products already lawfully used to provide similar services. Point 4 concerns services under contracts concluded before commencement. These contain the 27 June 2030 limit. It is not a general permission to publish new inaccessible PDFs until 2030.

Record publication date and document function. Distinguish an unchanged older edition from a new document containing new terms. An exception assessment needs to identify what was assessed, rather than rely on an old filename.

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For consumer service terms, begin with three questions: which service does the document concern, how does the customer use it, and who keeps it current? Then record the requirement being assessed. This is more useful than sorting documents solely by the .pdf extension.

• The part of the service the document belongs to.
• The provision you consider applicable.
• Any exception and the reasons it applies.
• Assessment results for the file the customer actually receives.

Start with an inventory for the covered service. A banking service may involve pre-contract information, terms, instructions and notices. Record when each document is created, who receives it and how it is delivered. Choose checks based on its content, including tables, charts and interactive fields.

Keep this separate from the DOS Act. LPTT starts from specified products and services, whereas DOS concerns digital services supplied by defined public actors. One organisation may need to examine several regimes. A review report should identify its target clearly.

Sections 7–8 address requirements causing disproportionate burden or a fundamental change in the product or service. The assessment needs reasons and must follow the applicable documentation and notification duties, taking the specific microenterprise provisions into account. This is different from a PDF supplier considering a file difficult to remediate.

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