Website Accessibility Requirements: Does Finnish Law Apply to You?

Can a customer request a quote without using a mouse? Does a visitor using a screen reader understand what to enter in each form field? Does a button stand out from its background? Accessibility determines whether customers can complete their tasks on your website or encounter a barrier.

Website accessibility requirements do not apply to all business websites in the same way. A website that simply introduces a company is generally outside the scope of the law. An online shop serving consumers, or another specifically regulated digital service, may be covered.

First, establish what service your business provides and which obligations apply to it. Then check your customers’ most important user journeys and plan how to address any issues you find. This guide walks you through those steps.

What do website accessibility requirements mean?

An accessible website can be used by visitors who cannot see its content, hear audio or use a mouse. They need to be able to find the information they need, understand it and complete their tasks.

Accessibility depends on a website’s technology, structure, content and functionality. Visual changes alone cannot achieve it.

Accessibility in practice

A business’s appointment booking form might highlight missing information with a red border. If colour is the only way the error is indicated, someone with a colour vision deficiency may find it difficult to notice. A customer using a screen reader might receive no indication of the error at all.

In an accessible form, the error is described in text, and the message is also associated with the correct field in the code. The user is told how to correct the information. This allows the customer to continue rather than having to guess why the booking failed.

The same principle applies to menus, purchases and contact options: people need to be able to use them in different ways.

How does WCAG apply to websites?

WCAG, or the Web Content Accessibility Guidelines, is an international set of guidelines for making web content accessible. It covers areas such as text contrast, keyboard navigation, alternative text for images and form functionality.

The guidelines are based on four principles. Content must be perceivable, interfaces operable and information understandable. The technical implementation must be robust enough to work with different browsers and assistive technologies.

WCAG has three levels: A, AA and AAA. Meeting WCAG 2.1 Level A and AA criteria is a key basis for the web content requirements of Finland’s Act on the Provision of Digital Services. Technical compliance is linked to the European standard EN 301 549, which also includes requirements beyond WCAG, for example for documents.

WCAG 2.2 includes newer criteria that are worth incorporating into design work. However, the latest WCAG version is not automatically the standard required by law. Website procurement and accessibility assessments should therefore specify the standard being used and refer to current guidance from the relevant authority.

Do accessibility requirements apply to your business?

In Finland, the key legislation is the Act on the Provision of Digital Services. It applies to the public sector and to certain services provided by private businesses.

Since 28 June 2025, the requirements have applied more widely to certain services offered to consumers. This extension covers consumer-facing online shops, for example.

Your industry or the name you give your website is not the only deciding factor. You need to establish what service is provided online, who it is intended for and on what grounds the service provider might fall within the scope of the law.

A standard business website versus a digital service covered by the law

A digital service does not just mean an online shop. A website or mobile application can also qualify as a digital service under the Act, but not all such services fall within its scope.

A business website that presents services, staff and contact details is generally not subject to accessibility requirements simply because it is online. However, obligations may arise because of factors such as the service provider’s public-sector status, funding or specific industry.

In a consumer-facing online shop, the customer can enter into a contract online. An accessibility assessment covers not only the purchase itself but also related steps, such as selecting a product, verifying identity and making a payment.

A contact form alone does not automatically make an informational business website an e-commerce service under the law. However, an online booking or order may be part of entering into a consumer contract. The assessment must therefore be based on the actual customer journey, not the label given to the website.

When planning a website for your business, establish at the outset whether its purpose is to introduce the business, generate enquiries or let customers complete transactions. This also helps identify accessibility obligations.

A decision path for assessing your situation

The following questions can help you make an initial assessment:

1. Is the service provider a public-sector organisation, or does it fall within the scope of the Act on other grounds? Certain private organisations and publicly funded services may also be covered. Legal business structure alone does not determine this.
2. Do you offer consumers an online service specifically defined in the law? These include e-commerce services, consumer banking services and certain services relating to electronic communications, passenger transport, e-books and access to audiovisual media services.
3. Does the microenterprise exemption apply to the service provider? Microenterprises providing services are exempt from the accessibility requirements introduced by the extension of service obligations in 2025. A microenterprise has fewer than 10 employees and annual turnover or an annual balance sheet total of no more than €2 million. This is not a blanket exemption from all obligations under the Act.
4. Is it only an informational business website or a service aimed at business customers? The extension covering consumer services does not, on its own, bring these within scope. Other possible grounds for application must still be checked.

This decision path helps clarify your situation, but borderline cases require a more detailed assessment. Check the current scope, exemptions and references to standards in Traficom’s accessibility supervision guidance and the up-to-date text of the Act on the Provision of Digital Services on Finlex.

Are there exemptions or limitations?

The law includes exclusions for certain older content, archives and third-party content, for example. Whether they apply depends on specific conditions. An appointment booking system built by an external supplier is not automatically excluded from the requirements if the business has procured it as part of its service.

In some situations, an exemption based on disproportionate burden may be invoked. This requires a reasoned assessment: difficulty making the changes or a lack of budget does not automatically qualify. For the new consumer service obligations, an exemption relating to a fundamental alteration of the service may also need to be considered.

The law also contains transitional provisions that may apply to existing service contracts, for example. However, an old website does not receive a blanket exemption simply because of its age.

What should you check on your website first?

Start with the customer’s most important task: buying a product, booking an appointment, requesting a quote or finding the terms of service.

Test the entire user journey from start to finish. The homepage may work well even if the payment stage or a form error prevents the customer from completing their task. The following checks help identify key issues, but they do not establish compliance across the whole website.

Does the website work with a keyboard?

Put the mouse aside and use the Tab key. Try the main menu, its submenus, forms and closing any pop-up windows.

In keyboard navigation, focus indicates the element the user is currently interacting with. It must be visible, for example as a clear outline, so the user knows which link or button they are about to activate.

The navigation order must be logical, and users must not become trapped in an element. Also check the cookie banner, mobile menu and chat window. These can prevent people from using the rest of the page even when the content itself is accessible.

Are contrast and text readability adequate?

Text must stand out from its background. At WCAG Level AA, normal text generally requires a contrast ratio of at least 4.5:1, and large text 3:1. Contrast requirements also apply to essential interface components and elements that indicate a state.

Use a tool to measure contrast, as a visual judgement is not reliable enough. Pay particular attention to light grey text, headings placed over images and form field borders.

Try enlarging the text and using the page in a narrow viewport. Content and functions must not disappear, overlap or become unusable.

Colour must not be the only way information is conveyed. If a required field or an error is marked in red, a clear text indicator is also needed.

Is the heading structure logical?

Headings organise content and help people find the right section. Screen reader users can navigate from heading to heading, so headings must also be marked up as headings in the code. Large, bold text is not enough.

A page generally has one H1 heading describing its content. Main sections use H2 headings, with H3 headings for subsections where needed. Heading levels should reflect the content hierarchy, not the desired font size.

A good heading tells readers what the section covers. “Service pricing and billing” is more helpful than “Good to know”.

Are forms and error messages accessible?

How well forms work often determines whether a customer can contact you or place an order.

Every field needs a clear label that is also associated with the field in the code. Placeholder text inside a field does not replace a persistent label: it disappears when the user starts typing and is not always conveyed correctly to assistive technologies.

Test the form with incorrect and missing information. If an email address is invalid, the message should explain the problem and how to correct it. “Submission failed” alone does not help the user.

Error messages must also be conveyed to screen readers. Previously entered information should not be cleared unnecessarily, and a successful submission needs a clear confirmation.

It is also worth reviewing form functionality when your goal is to generate more enquiries through your website. Marketing may bring the right visitors to the page, but a broken form stops the process at the final step.

Are links, buttons and calls to action clear?

Link text should help users anticipate where a link will take them. “Explore our maintenance services” describes the destination better than a standalone “Read more”.

Button text should match the action it performs. “Send quote request” and “Proceed to payment” are clear, whereas “Continue” may need more context.

The technical implementation must also match the purpose. A link generally takes users to another view or piece of content, while a button performs an action. A text area that has simply been made clickable may be inaccessible to keyboard or screen reader users.

The same clarity matters on a well-designed landing page: visitors need to understand what is being offered and what happens next.

Do images have alt text where needed?

Alt text is a text alternative for an image that a screen reader can convey to the user. Its purpose is to replace the meaning of the image in that particular context.

A product image may need alternative text describing the product’s appearance. A chart needs the essential information it communicates. A complex diagram may also require a longer text explanation.

Not every image needs a description. A purely decorative image should have an empty alt attribute so assistive technology can skip it. When an image acts as a link, its alternative text should describe the link’s purpose.

Alt text is not a place to collect keywords. Its role is to help the user understand the content.

If your website includes videos, downloadable documents or online events, include these in the assessment too. Otherwise, important information may remain inaccessible even if the page template works well.

What do an accessibility statement and audit tell you?

An audit establishes the service’s current accessibility status. A statement communicates it to users. The statement is not a certificate of a flawless website, and publishing it does not replace fixing the issues.

What should an accessibility statement cover?

As a general rule, a digital service covered by the accessibility requirements of the Act on the Provision of Digital Services must have a published accessibility statement.

The statement describes the service’s accessibility status, known issues and the grounds for any exemptions. It explains how users can provide accessibility feedback or request information in an accessible format, and how they can contact the supervisory authority if necessary.

The statement must be based on an actual assessment and kept up to date. Copying a template without examining the website may give a misleading picture of how the service works.

Also assign responsibility for handling accessibility feedback. A feedback channel does not help users if messages go unread and they receive no reply.

What is an accessibility audit used for?

An audit examines compliance with technical requirements and the user’s ability to complete their tasks. It should produce a report that supports remediation: where the issue is, who it affects, which requirement it relates to and how to fix it.

An automated checking tool can detect missing alternative text or some contrast issues, for example. However, it cannot reliably assess whether a description is appropriate, whether all text is understandable or whether the complete user journey works.

That is why the assessment also requires manual testing, keyboard navigation and a screen reader. Usability testing with disabled users can reveal additional barriers that a compliance check alone may not identify.

When should you seek an expert assessment?

An expert assessment is particularly worthwhile when the service falls within the scope of the law, the website involves purchases or multi-step processes, or your own team cannot assess technical issues.

An assessment is also worth carrying out before a website redesign. If problems are only discovered after launch, structures may need to be designed and built again.

Agree on the scope of the assessment in advance. A sample of a few pages may reveal shared problems, but it does not guarantee accessibility across the entire service.

How should accessibility issues be fixed?

For each finding, assign an owner, a target date and a way to verify that the fix works. Prioritise issues according to their impact on users, not just how easy they are to fix.

Remove barriers to completing tasks first

If users cannot pay for a purchase with a keyboard, or a screen reader cannot identify form fields, fixing these issues should be among the highest priorities. Such problems can make the service entirely unusable.

Unclear link text, missing field labels, poor contrast and invisible focus indicators may be quick to fix. Address them, but do not let easy changes push more difficult barriers further down the list.

Fixing a shared menu, form or button style can improve several pages at once. Wherever possible, make changes to shared components rather than applying individual patches.

Fix structures and content

The behaviour of a menu, a multi-step form or a date picker may require more extensive technical changes.

Content issues may involve heading structure, instructions, image alternatives, video captions and downloadable documents. Responsibility therefore does not rest with the developer alone. Content creators and website administrators also need clear working practices.

If the service uses an external payment, booking or identity verification system, involve the suppliers in the remediation work. Customers experience one continuous journey, even when several systems operate behind the scenes.

Test fixes before publishing

A fix is not complete simply because the code has changed. Retest the original problem and make sure the change does not introduce new barriers.

For example, fixing a pop-up window may require more than adding a visible close button. Keyboard focus must move into the window, behave appropriately within it and return to a sensible place when the window is closed.

After publishing the changes, update the accessibility statement to reflect the current situation. Also agree on how accessibility will be checked in future content updates and functional changes.

Why should accessibility be built into website development?

When accessibility is included in the design process, colour choices, form behaviour and menu navigation are resolved before they need to be corrected on a finished website.

Include accessibility in the website project requirements. Simply stating that “the website must be accessible” leaves considerable room for interpretation. The specification needs to identify the target standard, the user journeys to be tested and the acceptance criteria.

Accessibility as part of a good user experience

Clear instructions, readable text and understandable error messages help many users. They are also useful on small screens, in bright light or in situations where using a mouse is not possible.

Accessibility and usability are not the same thing, however. A website may meet individual technical criteria yet still be difficult to understand. Conversely, a website that is visually easy to use may exclude screen reader users.

Alongside the technical checks, you therefore need to ask: does the customer understand what they need to do, and can they do it?

Platform, content and search visibility work together

No content management platform guarantees accessibility on its own. The outcome depends on page templates, plugins, custom code and maintenance practices.

However, your choice of website platform affects how easily accessible structures can be built, tested and maintained. For example, content creators should be able to mark up headings correctly and add appropriate alternative text to images.

A clear heading structure, descriptive links and understandable content also support search engine optimisation goals. Accessibility does not guarantee higher search rankings, however, and good search visibility does not prove that a website is accessible.

Your company’s brand image is also shaped by practical experiences. A promise of easy service is more credible when customers can use the website without unnecessary barriers.

Summary: where should you start?

The law does not apply to every business website, but the obligations for consumer-facing online shops and other specifically regulated services need careful assessment.

Follow these steps:

1. Establish whether the law applies. Identify the service, its audience and the obligations that apply to the provider. Check official guidance for possible exemptions.
2. Test the most important user journey. Start with keyboard navigation, focus, forms, contrast and content structure.
3. Create a remediation plan. Remove barriers to completing tasks first. Assign responsibilities, deadlines and retesting for each fix.
4. Keep accessibility part of maintenance. Update the accessibility statement where needed and incorporate checks into ongoing website development.

Even if your business is not legally required to comply, customers’ ability to use your service matters to your business. A website that looks functional does not, on its own, tell you whether people using different methods can contact you, make a booking or complete a purchase.

Need help assessing or improving your website’s accessibility?

If you are unsure about your website’s current accessibility or are planning a redesign, get in touch with us. Let’s discuss your service and what kind of assessment or remediation work would make sense as the next step.