Sweden · SE
Sweden accessibility law: DOS + EAA-lag explained
Sweden's DOS Act covers the public sector and was extended to consumer services through the 2024 EAA transposition. DIGG monitors public-sector conformance with annual sampling.
- Primary law
- Lagen om tillgänglighet till digital offentlig service
- In force from
- 28 June 2025
- Standard
- WCAG 2.1 Level AA via EN 301 549
- Enforcement
- DIGG (Myndigheten för digital förvaltning) and Konsumentverket
Who has to comply
Public-sector since 2019 (DOS); private-sector consumer services from 28 June 2025.
If your service reaches consumers in Sweden, 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 Sweden 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, Sweden requires the following operational items, which auditors check first because they are simple to verify:
EN 301 549 / WCAG 2.1 AA
Accessibility statement following DIGG template
Annual self-assessment
Penalties and how enforcement actually works
Penalty payments tied to annual turnover; DIGG can issue cease-and-desist.
DIGG (Myndigheten för digital förvaltning) and Konsumentverket 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.
Most enforcement starts with a complaint or a routine sweep. The first signal is usually a written notice giving you 30–60 days to remediate before fines kick in.
Practical first steps for a Sweden 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 (Sweden regulators expect this discoverable)
Add a feedback channel and answer within the country-specified window
Re-scan after every major release; track regressions
Frequently asked questions
Does Sweden require user testing with people with disabilities?
It is recommended in DIGG guidance but not mandatory. Public-sector audits conducted by DIGG do include user testing.
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