Who has to comply
Public-sector since 2019 (DOS); private-sector consumer services from 28 June 2025.
Sweden is a high-trust, heavily digital market where consumers expect polished, accessible services, and card-and-BankID commerce is near-universal. A foreign seller reaching Swedish consumers falls under the 2024 EAA transposition on the country-of-consumption basis. Because DIGG publishes results and Swedish consumers are quick to file structured complaints, a cross-border store with an obviously missing accessibility statement or broken keyboard flow is more likely to be reported here than in less digitally engaged markets.
What the law actually requires
DOS + EAA-lag sets the technical bar at WCAG 2.1 Level AA via EN 301 549. On top of it, Lagen om tillgänglighet till digital offentlig service lists these operational duties:
- 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.
Enforcement is shared between DIGG (the Agency for Digital Government), which runs annual sampling and monitoring of the public sector and issues the statement template, and Konsumentverket, the consumer agency, for private-sector consumer services. DIGG's model is sampling-based with annual review cycles and can escalate to cease-and-desist orders and penalty payments tied to turnover. Sweden's approach is methodical and transparency-oriented rather than aggressive, with published guidance and templates that covered operators are expected to follow closely.
Reading the DOS + EAA-lag at the source
The law is cited as Lagen om tillgänglighet till digital offentlig service + Tillgänglighet till digitala produkter och tjänster (Lagen om tillgänglighet till digital offentlig service). Enforcement: DIGG (Myndigheten för digital förvaltning) and Konsumentverket. Key date: 28 June 2025. For the exact wording, read the official reference for Sweden listed under Sources below.
Sources
- DIGG guidance
- European Accessibility Act (Directive (EU) 2019/882) · European Commission
Links checked 12 October 2026. Not legal advice. Methodology · About Certvo
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.