Service-specific requirements and obligations | Traficom
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Service-specific requirements and obligations

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.

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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. 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 (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:

  1. that when an e-book contains audio in addition to text, it then provides synchronised text and audio
  2. that e-book digital files do not prevent assistive technology from operating properly
  3. 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
  4. 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
  5. that e-books are discoverable by providing information through metadata about their accessibility features
  6. 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:

  1. a real-time text feature in addition to voice communication
  2. 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:

  1. Electronic programme guides must be provided that are perceivable, operable, understandable, and robust, and that include information on the availability of accessibility features.
  2. 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.

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