Portugal accessibility law: DL 83/2018 + EAA explained

Who has to comply

Public-sector since 2018; consumer services from 28 June 2025.

If your service reaches consumers in Portugal, 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 Portugal 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, Portugal requires the following operational items, which auditors check first because they are simple to verify:

• EN 301 549 / WCAG 2.1 AA

• Portuguese-language accessibility statement

Penalties and how enforcement actually works

Administrative fines per DL 83/2018; EAA-specific penalties added by transposition.

AMA (Agência para a Modernização Administrativa) 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 Portugal 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 (Portugal 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