Who has to comply
Public-sector since 2019; consumer services from 28 June 2025.
Poland is the largest market in Central and Eastern Europe and a fast-growing e-commerce destination, so it is an increasingly common target for foreign sellers. Under the 2024 EAA implementation, a non-EU store selling to Polish consumers is covered on the country-of-consumption basis, with the EAA layering turnover-linked penalties on top of the older per-infringement fines. A Polish-language accessibility statement is expected, and cross-border sellers frequently overlook that the statement and feedback procedure must be genuinely usable in Polish, not just English.
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, Poland requires the following operational items, which auditors check first because they are simple to verify:
- EN 301 549 / WCAG 2.1 AA
- Polish-language accessibility statement
- Feedback procedure with 7-day response
Penalties and how enforcement actually works
Up to PLN 10,000 per infringement under public-sector law; EAA brings turnover-linked penalties.
Poland runs a dual structure: the Ministry of Digital Affairs (Ministerstwo Cyfryzacji) oversees the digital-accessibility regime, while UOKiK, the competition and consumer-protection office, brings the consumer-facing enforcement teeth. Enforcement is mostly complaint- and inspection-driven, and the law sets a concrete 7-day response window for the feedback procedure, which is an easy point of failure to check. UOKiK's involvement means non-compliance can be framed as a consumer-protection breach, broadening the potential penalty basis beyond the accessibility statute alone.
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 Poland 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 (Poland regulators expect this discoverable)
- Add a feedback channel and answer within the country-specified window
- Re-scan after every major release; track regressions