EAA enforcement in Sweden: PTS supervision and sanction fees

Which law applies

Lag (2023:254) transposes the Directive. Its duties for products and services apply from 28 June 2025, and e-commerce services are expressly covered. The law defines a microenterprise in Section 2 and exempts microenterprises that provide services in Section 10.

The Directive exempts microenterprises that provide services: fewer than 10 staff and an annual turnover or balance sheet total of EUR 2 million or less (Article 4(5)). Both conditions have to hold. Everyone above that line who sells to consumers online is in scope from 28 June 2025.

The Act itself describes outcomes (perceivable, operable, understandable, robust) rather than naming WCAG. In practice authorities and courts measure websites against the harmonised European standard EN 301 549, whose web chapter in version 3.2.1 maps to WCAG 2.1 level AA. Working to WCAG 2.2 AA covers those criteria plus the six new level A and AA criteria WCAG 2.2 added.

Who enforces it for online shops

The government designated the Swedish Post and Telecom Authority, PTS, as supervisor for e-commerce, electronic communications and banking services under the law. Other agencies cover areas such as audiovisual media.

How a complaint reaches a shop

Anyone can report an inaccessible service to PTS through its online form or the email and phone number on the PTS page. PTS also opens planned supervision on its own initiative, which is how the first e-commerce cases started.

Fines and other sanctions

Section 39 of Lag (2023:254) lets the authority charge a sanction fee (sanktionsavgift) of SEK 10,000 to SEK 10,000,000, set by the seriousness and scope of the breach. PTS can also issue orders to fix defects.

What has actually happened so far

• October 2025, first e-commerce supervision. PTS announced its first supervision under the new law, aimed at larger online sellers established in Sweden. It reviews websites only, not apps, and looks at three parts of each site: the home page, a product page and the search function (PTS).
• Later, a second round. PTS announced it was reviewing the accessibility of a further 11 e-commerce services (PTS). We could not load the full text of that release to confirm its date and details.
• No published sanction fee against a named shop as of 1 October 2026.

What to do if you sell into Sweden

If you sell to consumers in Sweden and you are above the microenterprise line, the defensible position is the same as everywhere else in the EU: fix the barriers in your own code, keep dated evidence of what you tested and changed, and publish the accessibility information the law asks for.

1. Scan your key templates (home, category, product, cart, checkout, account) for the failures a script can verify. Our free scan does this for up to 10 pages.
2. Test the purchase journey with a keyboard only and with a screen reader. A script cannot judge whether alt text makes sense or a checkout error is announced.
3. Fix the issues in the theme or codebase, not with an overlay widget. Overlays vs code fixes explains why.
4. Publish the service information the Act requires, in an accessible format. See what an EAA accessibility statement must contain.
5. Re-test after every redesign, theme update or new app, and keep the reports.

A Fix Sprint covers steps 1, 2, 3 and 5 for a fixed price. None of this is legal advice, and no audit can promise that a regulator or court will agree with it. It is the work that makes a complaint easy to answer.