Sweden accessibility law: DOS + EAA-lag explained

Who has to comply

Public-sector since 2019 (DOS); private-sector consumer services from 28 June 2025.

Sweden is a high-trust, heavily digital market where consumers expect polished, accessible services, and card-and-BankID commerce is near-universal. A foreign seller reaching Swedish consumers falls under the 2024 EAA transposition on the country-of-consumption basis. Because DIGG publishes results and Swedish consumers are quick to file structured complaints, a cross-border store with an obviously missing accessibility statement or broken keyboard flow is more likely to be reported here than in less digitally engaged markets.

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

• EN 301 549 / WCAG 2.1 AA

• Accessibility statement following DIGG template

• Annual self-assessment

Penalties and how enforcement actually works

Penalty payments tied to annual turnover; DIGG can issue cease-and-desist.

Enforcement is shared between DIGG (the Agency for Digital Government), which runs annual sampling and monitoring of the public sector and issues the statement template, and Konsumentverket, the consumer agency, for private-sector consumer services. DIGG's model is sampling-based with annual review cycles and can escalate to cease-and-desist orders and penalty payments tied to turnover. Sweden's approach is methodical and transparency-oriented rather than aggressive, with published guidance and templates that covered operators are expected to follow closely.

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

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

• Re-scan after every major release; track regressions