Forlæns

Digital Accessibility in Denmark: A Practical Guide to Legislation (EAA)

Man sitting at a desk in a cozy office, working on a computer with accessibility icons on the screen; outside the window, a small town hall with the Danish flag can be seen.

First published: 19 June 2025
Last updated: 20. May 2026

This guide is intended as a living document and will be updated as new information becomes available in this field.

Foreword

On 28 June 2025, a new set of rules took effect in Denmark. For the first time, many private businesses offering digital products and services are required to make them accessible. This change is the result of the European Accessibility Act (EAA), a new piece of EU legislation implemented in Denmark through Act no. 801 of 7 June 2022.

I have written this guide to help you understand what this change means.

If you work with digital accessibility in Denmark – as a business owner, developer, designer, or consultant – this report is for you. It may also be useful to professionals in other EU countries who want to see how the EAA is being implemented here.

The EAA marks a shift in the way accessibility is regulated. For many years, Denmark had no binding national rules for digital accessibility. Only recently did public websites and apps become subject to legal accessibility requirements, and up until now, private companies have largely been outside the scope of these demands.

Starting in June 2025, a broad range of services and products will need to comply with accessibility standards. This applies to, among other things, online stores, online banking, e-books, smart devices, ticket machines, and digital transport services. For many businesses in Denmark and the rest of the EU, this will be the first time accessibility becomes a legal obligation.

In short: For many companies in Denmark, digital accessibility is no longer optional.

This guide explains what the law says, what it means in practice, and how you can prepare. I’ve tried to write in clear language, with references to the legal texts and examples that illustrate how the rules could be applied in reality.

I’m not a lawyer, and this guide is not legal advice. It’s written by someone who works professionally with accessibility and is for anyone who wants to understand how the EAA is being introduced in Denmark. The goal is to bring a bit of clarity to what we know so far.

Finally, it’s worth noting that this guide is a living document. The law has been passed, but interpretation and enforcement are still evolving. Lawsuits and specific examples may change how the rules are understood in the future.

If you notice anything unclear or incorrect, please feel free to email me at tobias@forlæns.dk.

Thank you for reading—and for helping to promote accessibility in Europe.

—
By Tobias Christian Nyhuus Jensen, co-chair of the Nordic Accessibility Community Group. Based on research conducted through the group.

1. A new era for digital accessibility in Denmark

From good intentions to obligation

For many years, digital accessibility in Denmark was mostly based on voluntary efforts. Some businesses and public authorities took the initiative to create inclusive digital solutions, often motivated by a sense that it was the right thing to do, or because of customer expectations. However, many companies chose not to do anything to ensure accessibility—and until recently, there were also no laws requiring them to do so.

This is now changing. With the introduction of the European Accessibility Act (EAA), Denmark is entering a new phase where accessibility is not just encouraged, but becomes a legal requirement for many products and services offered by companies.

What is the EAA, and why does it matter?

European Accessibility Act is an EU directive (Directive 2019/882), which was adopted in 2019. It sets accessibility requirements for a wide range of products and services, with the aim of ensuring that people with disabilities can use digital content, services, and devices—and that these requirements are consistent across all EU countries.

In Denmark, the EAA has been transposed into national law through Act no. 801 of 7 June 2022. This law describes the specific obligations for Danish companies, including who is covered, what must be accessible, and how to document that the requirements have been met.

The EAA matters because it moves accessibility out of the “nice to have” category and makes it a legal obligation that businesses must comply with. It introduces new expectations for user experience, design, and technical implementation—and sets out possible consequences if the requirements are not met.

2. Covered businesses and services

Who is affected—and why?

Up until now, accessibility legislation in Denmark has primarily applied to public websites and apps, based on separate EU regulation for the public sector. (Directive 2016/2102) These rules do not apply to most private companies, which has left a large part of the digital sphere without requirements.

This is exactly what the EAA aims to address. For the first time, it extends legally binding accessibility requirements to the private sector as well. It covers consumer-facing websites and mobile apps within the following areas:

  • E-commerce platforms and marketplaces (e.g., online clothing stores, food delivery sites)
  • Banks, payment, and financial services (e.g., mobile banking apps, money transfer apps)
  • E-books and e-readers
  • Smart devices and self-service terminals (e.g., voice assistants in the home, digital terminals in department stores)
  • Ticketing solutions and transport services (e.g., travel apps, ticket machines at stations)

See the detailed list under 3. Examples of products and services covered by the law.

The logic is simple: If a product or service is digital and used by the public, it must be accessible to everyone – including people with disabilities.

Microenterprises (defined as companies with fewer than 10 employees and an annual turnover below 2 million euros) are, in most cases, exempt. However, if a small business manufactures physical products specifically covered by the law – such as e-readers, payment terminals, or ticket machines – the requirements may still apply.

All e-commerce websites that are not microenterprises must comply with the EAA’s accessibility requirements.

Timeline and transition

The EAA comes as no surprise. The directive was adopted in the EU in 2019, and Danish legislation was passed in 2022. Companies have had a transition period to understand the rules and prepare.

Key dates:

  • 7 June 2022: Act no. 801 is adopted in Denmark
  • 28 June 2025: EAA rules become mandatory for most products and services (see 5. Exemptions for what can wait until 2030)
  • 28 June 2030: Deadline for making the remaining products and services accessible (see details under 5. Exemptions)

Fictional example: Overlooked requirements

A Danish software company launches a new payment platform in 2026, but only later realizes that both the mobile app and terminal hardware fall under the EAA. Without built-in accessibility or proper documentation, the product cannot be sold in the EU until changes are made – delaying the sales of the payment solution and damaging the company’s credibility.

3. Examples of products and services covered by the law

Here are concrete examples of products and services covered by the EAA. This list is drawn directly from Annex 1 of the directive and Danish law:

Digital services

  • E-commerce platforms
    • Webshops where consumers buy goods directly
    • Online marketplaces that facilitate sales from third parties
  • Financial services
    • Online banking and mobile banking apps
    • Payment apps used by consumers
  • Transport services
    • Apps for travel planning, ticket sales, or passenger information
    • Websites offering electronic ticketing
  • Audio-visual media services
    • Streaming platforms for films, series, or news
    • On-demand TV services
  • E-book services
    • Portals that sell or lend e-books to consumers

Digital products

  • Computers and operating systems
    • Laptops and tablets with installed OS
  • Payment terminals
    • Card reader terminals in stores
  • Self-service machines
    • Ticket machines at stations
    • Check-in kiosks at airports
  • Smartphones
    • Mobile phones with advanced software
  • E-readers
    • Dedicated devices for reading e-books
  • Smart TVs and accessories
    • Equipment for accessing streaming content

Regardless of whether a company offers products, services, or both, the rules apply when users interact with them through a digital interface.

4. Implementation in Denmark

How the Danish law is structured

The Danish law consists of “sections” and “annexes”:

  • Sections 1–7: These define which products and services are covered, and who is required to comply.
  • Annexes 1–6: These describe the functional accessibility requirements, methods for conformity assessment, expectations for technical documentation, and the necessary content for the company’s accessibility statement.

The law refers indirectly to EN 301 549 as the harmonised standard underlying the technical accessibility requirements. This means that the EU has officially recognized the standard as a way to demonstrate compliance with the law.

Foreign companies and the Danish market

Danish law applies to companies that offer products or services on the Danish market—regardless of where the company is based. This means that companies from other EU countries or from outside the EU must still comply with Danish regulations if they target Danish consumers.

This is particularly relevant for e-commerce, transport booking platforms, and online financial services that operate across languages and regions.

Fictitious example: American software company with Danish customers

An American software company runs an online platform where Danish consumers can purchase concert tickets. Since 2025, the website has been subject to the EAA, because it offers electronic ticket sales directly to Danish customers.

Even though the company is outside the EU, the service must still be accessible and comply with the rules to be offered on the Danish market. The company therefore chooses to review its design and prepares an accessibility statement in Danish.

5. Exceptions

Who is covered?

The EAA applies to a wide range of private companies offering digital products and services to the public. This includes, among others:

  • E-commerce providers
  • Banks and financial platforms
  • Publishers of e-books and digital content
  • Transport and ticketing systems
  • Manufacturers of hardware (e.g., payment terminals and smart devices)

In short: If a product or service falls under the law and is used by consumers, accessibility is now a legal requirement.

Exceptions

Microenterprises:

According to § 6, subsections 2–3, microenterprises are exempt from the law. This applies to companies with:

  • Fewer than 10 employees, and
  • An annual turnover or balance sheet total under 2 million euros

However, smaller companies can, of course, choose to voluntarily comply with the requirements. This can be an advantage if they plan to grow, operate internationally, or sell to larger companies that demand accessibility from their suppliers. Additionally, accessibility can be a way to reach more customers, improve the company’s reputation, and demonstrate a commitment to including all users.

Disproportionate burden:

A company can be exempted from some or all accessibility requirements if it can document that meeting them would create a disproportionately large burden.

This could, for example, be the case if compliance would require extremely large investments or technical changes that the company realistically cannot bear.

The exemption is not granted automatically. The company itself must prepare a well-reasoned assessment showing why the requirements cannot be met without extreme strain. The documentation must be kept, produced upon request, and updated if circumstances change.

How to apply for an exemption

If your company believes that meeting the requirements would pose a disproportionate burden or fundamentally alter the nature of the product or service, you can apply for an exemption.

The Danish Safety Technology Authority provides:

  • A self-service form at virk.dk to submit your application
  • A template for documenting your justification

They can be found here: sik.dk/erhverv/tilgaengelighed-produkter-og-tjenester

To be approved, you must be able to document that the requirements:

  • Require extensive changes that would alter the fundamental characteristics of your product or service, or
  • Impose a disproportionately large burden on your company (financial, technical, or otherwise)

Documentation is mandatory. Authorities may request to see it at any time.

Transition period until 2030

The law includes a transitional arrangement, meaning that some products and certain services only need to meet the requirements from 28 June 2030.

Note: In general, both new and existing digital services—such as webshops, streaming services, online banking, e‑books, and other apps/online platforms—must comply with accessibility requirements from June 28, 2025.

The transitional arrangement applies only to the following:

  • Products that were marketed before June 28, 2025.
    Example: A payment terminal model launched in 2024 may continue to be sold and used until 2030 without meeting the new accessibility requirements.
  • Services delivered using products that were lawfully put into use before June 28, 2025.
    Example: A bus company uses a digital ticketing platform that was installed on its servers in 2024. The software itself (the product) is no longer for sale, but the service—selling tickets using this solution—can continue until 2030.
  • Services delivered under contracts signed before June 28, 2025.
    Example: In 2024, a municipality enters into a multi-year agreement for a digital library platform and can continue unchanged until the contract expires, but no later than 2030.

These products and services may continue unchanged until June 28, 2030. After this date, they must meet the requirements or be withdrawn from the market.

If there are no major changes to products or services, or if new contracts are signed, the law will apply immediately—not just from 2030.

Fictitious example: A niche hardware product with disproportionate burden

A small Danish company manufactures specialized payment kiosks for small harbors and campsites. The kiosks were designed in 2016 and run on a custom operating system without internet connectivity.

To upgrade them to fully comply with EAA accessibility requirements (e.g. compatibility with screen readers), the company would need to develop entirely new hardware and software and replace over 500 units currently in operation.

In total, the cost would exceed the company’s entire annual revenue. Therefore, they prepare a documented assessment stating that this would constitute a disproportionate burden. This is submitted to the Danish Safety Technology Authority as an application for exemption. Whether the exemption is actually granted is up to the authorities.

6. Documentation

What documentation is required?

To legally market a product or service covered by the regulations in Denmark, companies must be able to document their compliance with the requirements. This includes:

  • CE marking and EU Declaration of Conformity:
    • Physical products covered by the EAA (e.g., payment terminals, e-readers, ticket machines) must bear the CE mark, demonstrating that they meet the accessibility requirements. This must be supported by a formal EU Declaration of Conformity confirming that the product complies with EN 301 549 and the EAA requirements. (Stated in § 5 and Annex 3 of the Danish law.)
  • Technical documentation:
    • Companies must prepare and retain internal documentation showing how they comply with accessibility requirements. This documentation must be kept for at least five years after the product or service is launched or significantly updated. The requirement applies to both physical products and digital services.
  • Accessibility statement:
    • Services and software must have a clear and publicly available accessibility statement. The format can vary, but the content must cover the points listed in Annex 4 to the Danish law: which accessibility requirements are met, how compliance has been assessed, and how people can get help with accessibility.

Think of accessibility documentation as quality control for inclusion. It demonstrates that you have tested your product, removed barriers, and made it usable for everyone.

How to write an accessibility statement

The purpose of the statement is to explain how the service meets the legal requirements and give users a clear way to report issues.

The statement should:

  • Describe the service in accessible terms – what it does, who it is for, and the formats in which it is available.
  • Explain how users can make use of the service, especially with assistive technologies (e.g., screen readers, keyboard navigation, or alternative input methods).
  • Summarise the relevant legal requirements (based on Annex 1 of the law), indicate which are met and which are not, and explain the reasons for any shortcomings as well as whether improvements are planned.
  • Describe how accessibility has been evaluated – for example, through internal reviews, third-party evaluation, or user testing.
  • Provide a contact option where users can get help, give feedback, or file complaints. This could be an email, form, or phone – it must work, be monitored by the company, and be accessible to people with varying needs. Ideally, offer several contact options to accommodate different needs or preferences.

Language and presentation:

  • Use simple and clear language that everyone can understand.
  • Ensure that the statement itself is accessible – compatible with screen readers, uses legible fonts, offers good contrast, and has a clear layout.
  • Keep it updated, especially when new changes affect the accessibility of the product or service.
  • Make it easy to find – not hidden in small links or buried deep in help sections. The statement is often placed as a link at the bottom of the website.

Inspiration:

As a practical starting point, you can use the Nordic Accessibility Community Group’s GitHub template, which follows the EAA’s requirements and Annex 4 of the law.

Notification obligation for products

If you as a manufacturer or importer become aware that a product does not comply with the requirements, you must immediately rectify the situation – and, if necessary, recall the product – and also notify the authorities in the member states where the product is present. (Source: Directive (EU) 2019/882, Article 7, section 8)

Fictional example: A statement that fits the brand

A Danish company launches a new mobile app where customers can transfer money, pay bills, and manage their accounts. As part of their EAA obligations, they publish a clear accessibility statement.

Instead of hiding the statement deep within their support pages, they place a link directly in the app’s settings menu and present the statement in plain, easy-to-understand Danish and English. The statement matches the visual style of the brand, with readable fonts, clear layout, and accessible colors.

By integrating the statement as part of the user experience, they both meet legal requirements and build trust with customers who have accessibility needs, who can quickly see that the company takes inclusion seriously.

7. Which standard should you follow?

The EAA describes what needs to be accessible but does not refer to a specific technical standard with detailed criteria. Until the official harmonized standard is in place, you can use any standard that fully meets the requirements of the law.

In practice, this means:

  • Use WCAG 2.2 AA for digital content.
  • Use EN 301 549 as a framework for software, services, and physical products.

The current version of the EN 301 549 standard, version 3.2.1, officially applies only to legislation covering public websites and apps. It does not directly cover the EAA. A new version, 4.1.1, is on the way and is expected to become the official standard for the EAA in 2026. Once it is published in the EU Official Journal, companies can use it as the simplest way to document that they are complying with the rules.

Until then, it makes the most sense to build solutions based on WCAG 2.2 (levels A and AA) and use EN 301 549 as a reference.

7. Oversight, complaints, and enforcement

Who oversees compliance?

In Denmark, responsibility for overseeing and enforcing the accessibility rules in Act no. 801 of 7 June 2022 is divided among several authorities:

  • Sikkerhedsstyrelsen is the main supervisory authority for most products and services.
  • Other authorities may be involved depending on the sector, for example:
    • Finanstilsynet
    • Søfartsstyrelsen
    • Trafikstyrelsen
    • Energistyrelsen
    • Justitsministeriet

Source: Sikkerhedsstyrelsen – New requirements for accessibility in products and services

How is compliance with the law monitored?

The authorities use a combination of:

  • Internal inspections and risk assessments
  • Spot checks
  • Review of documentation (e.g. technical material and accessibility statements)

Sikkerhedsstyrelsen may also publish guidance so companies can understand expectations before inspections take place.

The law does not require an external auditor to certify compliance. Companies are expected to assess and document themselves that they meet the requirements. However, some may choose third-party audits as an internal safeguard or in connection with tenders.

Complaints and sanctions

Consumers and users can submit complaints about inaccessible products or services to the relevant authority via a new section called “Accessibility” under the “Private” tab at sik.dk.

If a company does not comply with the requirements, authorities may:

  • Issue formal warnings or orders to improve
  • Impose fines
  • Order that illegal products or services be withdrawn or removed from the market

As a rule, companies are given the opportunity to address issues before stricter sanctions are imposed. In cases of repeated or serious violations, authorities may require products to be removed from the market or access to services to be blocked. This can mean products are recalled or that online platforms are temporarily shut down until the issues are resolved. If violations persist or are severe, the sanctions can be increased.

Fictional example: A webshop responds to an inspection

A medium-sized Danish webshop receives a letter from the Danish Safety Technology Authority following a routine spot check. The webshop lacks an accessibility statement, and important steps in the checkout process do not work with a screen reader.

Instead of disputing the critique, the company voluntarily chooses to update the platform, publish a clear accessibility statement, and submit documentation to the authority. The case closes without a fine, and the company strengthens its reputation in the process.

8. Common pitfalls – and how to avoid them

Uncertainty about what is covered

One of the biggest challenges for companies is figuring out whether the law applies to them. Some are unsure whether their product qualifies as a “service” under the EAA. Others are not aware that the law applies when the company is not based in Denmark but offers services to Danish consumers or operates within the EU.

Tip: If your product is digital, aimed at consumers, and falls within one of the categories mentioned in the law, you should generally assume that the EAA applies until proven otherwise.

Misunderstanding the capabilities of automated tests

Automated accessibility tools are useful for identifying many common technical issues, such as missing image descriptions, low color contrast, or incorrect heading levels. Automated tests are especially valuable for large websites where it’s unrealistic to manually test every page.

But automated tests should be seen as a starting point. They cannot assess the entire user experience or find every issue with screen readers, keyboard navigation, or cognitive barriers. Many accessibility problems are only revealed through manual testing and feedback from real users.

Tip: Use automated tools to catch the obvious errors – but always follow up with manual testing of a representative sample of pages and systematic review according to the accessibility standards EN 301 549 or WCAG.

The problem with “one-click” overlays

So-called “AI accessibility widgets” or overlay tools are often marketed as quick fixes that can make your website legally compliant in an instant, without you having to change any code. In reality, they add a script on top that tries to adjust the site in real time (for example, by adding missing labels).

But overlays rarely meet legal requirements—and can actually make things worse. They may interfere with screen readers, break keyboard navigation, or hide real issues without actually fixing the underlying code.

In the US, overlays have been at the center of lawsuits. They were involved in around 30% of web accessibility cases in 2023. In 2025, one provider was fined 1 million dollars by the Federal Trade Commission for misleading compliance claims. (Source)

In the EU, the European Disability Forum has stated that overlays “cannot replace actual compliance” with EU law. (Source)

Tip: Avoid relying on overlays. Genuine accessibility comes from designing and building your product to work for everyone—not from patching it after the fact with quick scripts.

From cost to business value

Some companies might see EAA compliance as just another bureaucratic obligation. But accessibility has strategic value. It improves usability for everyone, reduces legal risks, and can unlock new markets.

Tip: Think of accessibility as part of your product quality—not just a checklist. See more: The Business Case for Digital Accessibility (W3C)

Guidance for Danish businesses

The Danish Safety Technology Authority has published targeted guidance for Danish businesses on how to understand and meet EAA requirements. Here you’ll find practical advice on documentation and accessibility expectations.

Tip: See sik.dk/erhverv/tilgaengelighed-produkter-og-tjenester for the latest Danish guidance for your industry.

Fictional example: A tech startup takes a proactive approach

A small Danish startup develops custom logistics software. As they grow and begin offering cloud-based services across the EU, they realize their platform is likely subject to the EAA.

Instead of treating accessibility as a one-off task, they make it part of their quality assurance. They train testers in EN 301 549, appoint an internal accessibility lead, and create a checklist to review both design and technical documentation.

When a major retail client asks for accessibility documentation, the startup is ready – and stands stronger against competitors.

9. The first time you work with accessibility

If this is your first experience with accessibility, don’t worry. Here’s how you can get started:

  • Start with the users: Can everyone – including those with impaired vision, hearing, mobility, or cognitive challenges – use your service?
  • Learn the basics of the Web Content Accessibility Guidelines (WCAG): The guidelines are free online and are used worldwide. See more at: WCAG Quick Reference (W3C)
  • Use tools, but don’t rely on them blindly: Automated tests offer great help and are especially important for large websites, but they won’t find everything.
  • Ask real users: Testing with people who use assistive technologies reveals actual barriers in practice.
  • Read the guidance from your country: In Denmark, the Danish Safety Technology Authority provides useful resources. See more at: sik.dk/erhverv/tilgaengelighed-produkter-og-tjenester

Working with accessibility doesn’t have to be perfect from the start – but you do need to begin somewhere. The sooner you ask the right questions, the easier it becomes to find good answers.

Thank you for helping to create a more accessible Europe.

10. Resources and guidance

This section compiles the most relevant legal texts, templates, and practical guides for working with the European Accessibility Act in a Danish context.

Legal texts and policy

Guides and templates