Poland accessibility law: Ustawa 4/2019 + Ustawa EAA explained

Who has to comply

Public-sector since 2019; consumer services from 28 June 2025.

If your service reaches consumers in Poland, EAA enforcement applies the same way it does to a domestic provider. The "country of consumption" rule means a Shopify store run from outside the EU but selling into Poland is covered. There is no carve-out for non-EU sellers.

What the law actually requires

The technical baseline is WCAG 2.1 Level AA via EN 301 549. EN 301 549 references WCAG 2.1 Level AA in full and adds a few requirements specific to mobile apps and documents. Beyond the technical bar, Poland requires the following operational items, which auditors check first because they are simple to verify:

• EN 301 549 / WCAG 2.1 AA

• Polish-language accessibility statement

• Feedback procedure with 7-day response

Penalties and how enforcement actually works

Up to PLN 10,000 per infringement under public-sector law; EAA brings turnover-linked penalties.

Ministerstwo Cyfryzacji and UOKiK runs the audits. They start with the largest covered services and move down. The first cycle of EAA audits in 2025–2026 will focus on visible non-compliance — missing accessibility statements, obvious WCAG violations on the homepage, lack of feedback channel — because those are cheap to detect. Deep technical audits come later.

Practical first steps for a Poland site

If you are starting now and want to land before enforcement, run an automated audit, fix the high-impact issues (contrast, labels, keyboard, focus), publish an accessibility statement, and set up a feedback inbox. That sequence covers 80% of what auditors look for in a first sweep.

• Run a baseline scan to know your current score

• Fix critical and serious issues in priority order — these are the ones cited in complaints

• Publish a public accessibility statement on a stable URL (Poland regulators expect this discoverable)

• Add a feedback channel and answer within the country-specified window

• Re-scan after every major release; track regressions

Accessibility law in nearby jurisdictions