The Act on the Provision of Digital Services includes service-specific additional requirements and obligations for certain services. The additional requirements and obligations apply to the following digital services intended for consumers: e-commerce services, e-books, certain passenger transport and banking services, services providing access to audiovisual content and communication services. The services must comply with the accessibility requirements of the Act on the Provision of Digital Services after the transition period, from 28 June 2025 onward. The obligations stem from the EU Accessibility Directive and aim to promote equality in an increasingly digital society.
Service-specific additional requirements
The above-mentioned services within the scope of Chapter 3a of the Act on the Provision of Digital Services must meet the general accessibility requirements and obligations laid down in the Act on the Provision of Digital Services. These requirements are described on the Requirements of the Act on the Provision of Digital Services page . (External link) In addition, Chapter 3a of the Act on the Provision of Digital Services lays down obligations and service-specific additional requirements that these specific services must fulfil.
Further provisions on service-specific additional requirements are laid down in the relevant Government Decree (External link) (in Finnish). The following section provides information on new service-specific additional requirements and additional obligations related to the accessibility statement.
Additional requirement for e-commerce
The service provider shall provide information on the accessibility of products and services in its online shop where such information has been provided by the economic operator responsible for those products and services, such as the manufacturer or importer.
Additional requirement for e-books
E-books must be accessible so that they can be read and processed. This means that when providing e-books, the service provider must ensure:
- that when an e-book contains audio in addition to text, it then provides synchronised text and audio
- that e-book digital files do not prevent assistive technology from operating properly
- that the user has according to their choices, access to the content, the navigation of the file content and layout including dynamic layout, the provision of the structure, flexibility and choice in the presentation of the content
- alternative renditions of the content and its interoperability with a variety of assistive technologies, in such a way that it is perceivable, understandable, operable and robust
- that e-books are discoverable by providing information through metadata about their accessibility features
- that digital rights management measures do not block accessibility features.
Additional requirement for consumer banking services
When providing retail banking services, the service provider must ensure that the information concerning the provision of the services is understandable in accordance with the B2 language proficiency level of the Common European Framework of Reference for Languages of the Council of Europe.
Additional requirement for communication services
As an additional requirement, communication services must provide:
- a real-time text feature in addition to voice communication
- full interactive features when video is provided in addition to voice communication.
These additional requirements apply to interpersonal communication services.
Additional requirement for services providing access to audiovisual content
The additional requirements for services providing access to audiovisual content are as follows:
- Electronic programme guides must be provided that are perceivable, operable, understandable, and robust, and that include information on the availability of accessibility features.
- It must be ensured that the accessibility features of audiovisual content services are delivered in full, with sufficient quality and accuracy, synchronised with audio and video, and in a way that allows the user to control their presentation and use.
Additional obligations related to the accessibility statement
Services within the scope of the Act on the Provision of Digital Services must have an accessibility statement describing the state of accessibility of the service. In addition, the accessibility statement must include the following information for the following digital services intended for consumers: e-commerce services, e-books, certain passenger transport and banking services, services providing access to audiovisual content and communication services.
- A general description of the service
- The service provider must provide information on the product needed to use the service
- If the use of a digital service requires the use of a product in order to function, the service provider must also provide information on how the product in question relates to the digital service, what accessibility features it has and how it works with assistive devices and other arrangements that assist the use of the service.
- The service provider must provide information on the fulfilment of additional service-specific requirements
- The service provider shall publish a description of how additional service-specific requirements concerning the service in question have been taken into account in the service.
More information on the accessibility statement and how to prepare one is available on the page Information about the accessibility statement. You will also find a tool on this page to help you draft the accessibility statement.
Transition period for amendments to the Act on the Provision of Digital Services
Services falling within the scope of the Act on the Provision of Digital Services from now on must comply with the accessibility requirements and service-specific additional requirements after the transition period, i.e., from 28 June 2025 onward.
However, if a service agreement concerning a service falling within the scope of the Act on the Provision of Digital Services from now on has been concluded before the end of the transition period on 28 June 2025, the agreement may remain unchanged until the agreement expires. However, the agreement may not be extended unchanged for more than five years from the end of the transitional period.
This also means that as of 28 June 2025, new service agreements will no longer be allowed for services that do not comply with the accessibility requirements and service-specific additional requirements of the Act on the Provision of Digital Services.
What to do if accessibility requirements cannot be met?
Deviation from accessibility requirements
The service provider may deviate from the accessibility requirements of the Act on the Provision of Digital Services if, based on its accessibility assessment, it can demonstrate that compliance with the accessibility requirements places a disproportionate burden on its digital service or if compliance would fundamentally alter the basic nature of the service. Information about a disproportionate burden is available on the Information about the accessibility statement page :
The assessment of disproportionate burden shall take into account the following:
- Ratio of the costs of compliance with accessibility requirements to the operational and capital expenditure for the economic operator.
- Ratio of the net costs of compliance with accessibility requirements to the net turnover of the economic operator.
- Cost-to-benefit ratio. When assessing this, particular attention shall be paid to the needs of persons with disabilities to use the service.
A new assessment shall be carried out by the service provider whenever the digital service is changed, when requested by the supervisory authority, or at least every five years. The assessment carried out shall be documented. Documentation must also be kept for five years after the provider has provided the digital service.
However, no exception can be made to the accessibility requirements or additional service-specific requirements if the service provider receives funding granted for improving accessibility, and this funding originates from external public or private sources, not from the service provider’s own resources.
Notification of shortcomings in accessibility and grounds for derogation
If the digital service does not meet the accessibility requirements, the service provider must inform the supervisory authority of the shortcomings in compliance and the corrective measures it intends to take.
If the service provider invokes a disproportionate burden or a fundamental alteration of the nature of the service, it must notify the supervisory authority of the details concerning the derogation.
You can find more detailed instructions for reporting accessibility shortcomings on this page.
Useful links
The Act on the Provision of Digital Services (in Finnish) (External link)