June 28, 2025 marks a critical milestone for Greek businesses offering products or services to the public via websites. On this date, Part B of Law 4994/2022 enters into full force, incorporating Directive (EU) 2019/882 (European Accessibility Act) into national legislation. This new obligation brings documented compliance requirements as well as significant penalties for non-compliant entities.
This is a practical compliance guide for businesses, as well as for consumers who seek accessibility as a right.
Who falls under the scope of the Law?
Law 4994/2022 applies to:
➤ Manufacturers, importers, and distributors of products such as:
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Payment terminals, computers, operating systems,
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E-book reading devices,
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Self-service machines (e.g., ATMs, ticketing kiosks).
➤ Websites of service providers to the public, including:
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Banking or financial services,
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E-commerce (e.g., eshops, marketplaces),
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Electronic communications (telephony, VoIP),
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Ticket sales and transport bookings (ferries, airlines, buses),
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Digital book services (e.g., e-books),
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Automated information services via technical devices.
Who is NOT Subject to the Law?
The law does not apply to purely informational websites with no commercial character or services within its scope. Examples include:
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Personal blogs,
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News portals or online magazines (if not offering paid e-subscriptions),
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Corporate websites without online functionalities or services.
What Must Compliant Entities Do?
1. Assess Products & Services
Identify how and where products/services may exclude users with disabilities. Accessibility must be integrated at the design stage (“accessibility by design”).
2. Technical Adaptation & Compatibility
Ensure that products and services:
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Are compatible with assistive technologies (e.g., screen readers, Braille),
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Offer navigation without a mouse,
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Provide multi-sensory content (audio, visual, tactile).
3. Declaration of Conformity
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Draft a Declaration of Conformity,
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Maintain a technical documentation file,
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Publish clear, accessible compliance information.
4. CE Marking (for products)
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Products must bear the CE mark before entering the market,
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Marking must be accompanied by relevant documentation and available to authorities.
5. Staff Training & Public Information
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Train staff on handling accessibility requirements and customer support for persons with disabilities.
Practical Examples
| Sector | Obligation | Example |
|---|---|---|
| Banking Services | Accessible ATMs & mobile banking | Voice instructions, screen reader-compatible e-banking |
| E-Commerce | Accessible web design | Keyboard navigation, alt-text for product images |
| eBooks & Readers | Alternative reading formats | Adjustable font size, text-to-speech support |
| Self-Service Devices | Accessibility for persons with disabilities | Proper device height, tactile buttons, NFC voice guidance |
| E-Ticketing/Bookings | Barrier-free ticketing and seat selection | Screen reader-friendly interfaces, descriptive seat selection options |
Compliance Standards – How is Compliance Presumed?
Compliance is presumed if:
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WCAG 2.1 Guidelines (at least AA level) are met,
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The EN 301 549 European standard for ICT is applied,
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Future Common Technical Specifications issued by the European Commission are adopted.
Sanctions & Administrative Fines
According to Article 26 of Law 4994/2022, competent authorities may impose:
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Administrative fines up to €100,000,
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Suspension of service operations or product availability in serious cases,
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Withdrawal orders and public disclosure of non-compliance.
The severity of penalties depends on:
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The seriousness and duration of the violation,
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The number of affected individuals,
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Any recurrence or negligence in compliance.
What Can Consumers Do?
Consumers have the right to:
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Request accessible versions of information (audio, tactile, easy-to-read),
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File complaints to competent authorities (e.g., EETT, Consumer Secretariat, Ministry of Transport),
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Request adjustments or corrections if services/products are inaccessible.
Next Steps for Businesses
With the compliance deadline set for June 28, 2025, businesses are advised to:
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Conduct accessibility audits on websites, apps, and devices,
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Provide staff training and client awareness,
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Work with specialized legal and technical consultants (if not already initiated).
Conclusion
Law 4994/2022 introduces a regulatory shift: from minimal compliance to inclusion by design. Accessibility is no longer a recommendation — it is a legal obligation and a strategic advantage for businesses committed to sustainability, accountability, and competitiveness.