Portugal accessibility law: DL 83/2018 + EAA explained

Who has to comply

Public-sector since 2018; consumer services from 28 June 2025.

Portugal is a mid-sized western-European market with a strong tourism and cross-border online-retail flow, so many foreign stores sell into it in euros. Under DL 83/2018 as extended by the EAA transposition, a non-EU seller reaching Portuguese consumers is covered on the country-of-consumption basis. A Portuguese-language accessibility statement is expected, and cross-border sellers commonly rely on Portugal's public AccessMonitor tool to self-check, which the regulator itself uses as a reference point.

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, Portugal requires the following operational items, which auditors check first because they are simple to verify:

• EN 301 549 / WCAG 2.1 AA

• Portuguese-language accessibility statement

Penalties and how enforcement actually works

Administrative fines per DL 83/2018; EAA-specific penalties added by transposition.

Enforcement is centralised in AMA (Agência para a Modernização Administrativa), which runs the well-known AccessMonitor automated evaluation service and administers the public-sector regime. Portugal's approach is tool-assisted and monitoring-oriented: AMA's AccessMonitor gives both regulators and operators a common automated baseline, so obvious machine-detectable failures are easy for the agency to surface. Administrative fines under DL 83/2018 plus EAA-specific penalties back the regime, and the presence of a public scoring tool means low-hanging violations are unusually visible.

Practical first steps for a Portugal 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 (Portugal regulators expect this discoverable)

• Add a feedback channel and answer within the country-specified window

• Re-scan after every major release; track regressions