Transition periods related to Chapter 3a of the Act on the Provision of Digital Services
Under Chapter 3a of the Act on the Provision of Digital Services, digital services intended for consumers, i.e. e-commerce, e-books, certain passenger transport and banking services, services providing access to audiovisual content and communication services must comply with the accessibility requirements and service-specific additional requirements as of 28 June 2025.
If a service agreement concerning a service referred to in Chapter 3a was concluded before 28 June 2025, the agreement may continue in its original form until it expires. However, such agreements may not be extended beyond 28 June 2030, by which time the service must meet the applicable requirements.
This means that from 28 June 2025 onwards, it will no longer be possible to enter into new service agreements that do not comply with the accessibility requirements and service-specific additional requirements.
The accessibility requirements and additional requirements under the Act on the Provision of Digital Services do not apply to:
- content of digital services that has been archived before 28 June 2025
- pre-recorded time-based media published before 28 June 2025
- office file format documents available in digital services and published before 28 June 2025.
Intranets and extranets
Intranet and extranet websites and mobile applications used in the workplaces of public authorities and bodies governed by public law must comply with the accessibility requirements of the Act on the Provision of Digital Services if the site or application has been completely revised on or after 23 September 2019.
Therefore, when acquiring new or updating existing intranet and extranet services, the public authorities and bodies governed by public law referred to in the Act must ensure that such services comply with the accessibility requirements once they are made available to users.
These requirements apply only to intranet and extranet websites and mobile applications used in the workplaces of public authorities and bodies governed by public law. The Act does not impose accessibility requirements on intranet and extranet services used in the workplaces of private entities.
Archived content
As a rule, the Act on the Provision of Digital Services does not apply to content on websites and mobile applications that has been archived before 23 September 2019.
Archived content refers to content in a digital service that is no longer modified after being archived and is not needed for active administrative processes, such as the handling of official matters.
However, if the content is needed for processing an ongoing matter within a public authority, the requirements of the Act apply also to archived content.
Videos and audio broadcasts
Videos and audio broadcasts published on websites have been required to comply with the accessibility requirements since 23 September 2020.
Older videos and audio broadcasts published before this date do not need to be removed from websites or made retrospectively accessible. However, such older non-accessible videos and audio broadcasts must be mentioned in the accessibility statement.
Documents
Documents published in digital services must be accessible in accordance with the requirements of the Act on the Provision of Digital Services.
However, the requirements of the Act do not apply to office file formats published before 23 September 2018.
If, however, a document published before 23 September 2018 is needed for determining or exercising a party’s rights, obligations, or entitlements, the provisions of the Act apply.