Amendments to the Digital Services Act
This page contains information on the services within the scope of the accessibility requirements of the Digital Services Act from now on, and what types of requirements and obligations apply to these services and their providers. The services must comply with the accessibility requirements of the Digital Services Act after the transition period, from 28 June 2025 onward. Service providers should take the new requirements into consideration well in advance.
Table of contents
New services falling within the scope of the Digital Services Act
The Digital Services Act covers the following services intended for consumers: e‑commerce, e‑books, some passenger and bank services, as well as services and communication services providing access to audiovisual content.
A consumer is a person, not an organisation, that acquires a service or product mainly for purposes other than their business activities.
The Act does not apply to micro-enterprises. A micro-enterprise refers to enterprises with fewer than 10 employees, whose annual turnover does not exceed EUR 2 million or whose annual balance sheet total does not exceed EUR 2 million. However, micro-enterprises are encouraged to provide their services in accordance with accessibility requirements, even if they do not apply to them.
The Digital Services Act will apply to the following new services from 28 June 2025 onward.
An online shop refers to e-commerce on a website or in a mobile application where the consumer can conclude contracts for the purchase of services or products remotely. In practice, this can mean online shops where consumers can buy services and products online.
E-books, websites and mobile applications intended for reading and using them will be covered by the Act.
An e-book refers to a file or a set of files offered to consumers in text or graphic form. An e-book may also contain images or sound. E-books include all written works, such as fiction, nonfiction and textbooks, including professional digital libraries and online bookshelves.
The definition of an e-book does not include, i.e.:
- newspapers, journals and similar
- material intended for temporary use, such as advertising products, brochures, price lists and annual reports.
Passenger transport refers to rail transport, regular bus transport, air transport and scheduled commercial waterborne transport. With regard to urban, suburban and regional transport services, the Act applies to rail, bus, metro and tram services. Taxi services do not fall within the scope of application of the Act. Still, these accessibility requirements will apply to taxi services with regard to e-commerce.
Accessibility requirements apply to digital services provided to consumers as part of transport services. These services include websites, mobile applications, digital passenger tickets, digital ticket services, as well as journey planners and traffic and disruption notices in a digital service.
The Digital Services Act already applied to some digital services for passenger transport, and thus the websites of publicly organised transport and mobile applications have already been obligated to meet accessibility requirements. The amendments to the Digital Services Act extend the accessibility requirements to the private sector in a large scale. All passenger transport services covered by the Act are subject to the new obligations referred to in the Digital Services Act.
The Digital Services Act already applied to some digital services provided by banks. Now, the scope of the Act will be broader, including digital services related to consumer payment services, basic payment accounts, credits, asset management and investment advice. You can check which consumer banking services fall within the scope of the Act under Section 10a of the Digital Services Act (linkOpens in a new windowOpens in a new window, in Finnish).
Audiovisual media service refers to a service the main purpose of which is to provide television broadcasts or on-demand services to the public. The Digital Services Act applies to the services used to select and view these contents. These include Yle Areena, MTV Katsomo and Netflix.
The Digital Services Act does not regulate the audiovisual content itself. Additionally, if a service providing access to audiovisual content is a non-digital service, such as an electronic television programme guide or a hybrid television service, its accessibility requirements are laid down in the Act on Electronic Communications Services (Section 194b). Compliance with these requirements is supervised by the Finnish Transport and Communications Agency Traficom. For more information, visit Traficom’s website (linkOpens in a new windowOpens in a new window).
Communication services include instant messaging services offered to consumers, such as Whatsapp, Signal and Messenger.
However, for these services, the scope of application of the Digital Services Act does not include the content of messages. Additionally, if a communication service is a communication service other than a mobile application or a website, such as a traditional voice, text message or e-mail service, its accessibility requirements are laid down in the Act on Electronic Communications Services (Section 194b). Compliance with these requirements is supervised by the Finnish Transport and Communications Agency Traficom. For more information, visit Traficom’s website (link).
New requirements and obligations of the Digital Services Act
The above-mentioned services within the scope of the Digital Services Act must meet the general accessibility requirements and obligations laid down in the Digital Services Act. These requirements are described on the Requirements of the Act on the Provision of Digital Services page.
The Digital Services Act has also been supplemented with additional obligations and service-specific requirements. These only apply to services falling within the scope of the Act from now on. These services must meet both the general accessibility requirements mentioned above, and the service-specific additional requirements and additional obligations related to the accessibility statement as of 28 June 2025. Further provisions on service-specific additional requirements are laid down in the relevant Government Decree (link to the DecreeOpens in a new window, in Finnish). The following section provides information on new service-specific additional requirements and additional obligations related to the accessibility statement.
The service provider shall provide information on the accessibility of products and services in its online shop where such information has been provided by the economic operator responsible for those products and services, such as the manufacturer or importer.
E-books must be accessible so that they can be read and processed. This means that when providing e-books, the service provider must ensure:
- that when an e-book contains audio in addition to text, it then provides synchronised text and audio
- that e-book digital files do not prevent assistive technology from operating properly
- that the user has according to their choices, access to the content, the navigation of the file content and layout including dynamic layout, the provision of the structure, flexibility and choice in the presentation of the content
- alternative renditions of the content and its interoperability with a variety of assistive technologies, in such a way that it is perceivable, understandable, operable and robust
- that e-books are discoverable by providing information through metadata about their accessibility features
- that digital rights management measures do not block accessibility features.
The service provider shall provide information on digital banking services using language that meets the level B2 of Council of Europe’s Common European Framework of Reference for Languages.
Additional service-specific requirements have also been laid down for communication services and services providing access to audiovisual content. The additional requirements can be found in the Act on Electronic Communications Services (Sections 194 c and 194 d). Compliance with the requirements is supervised by the Finnish Transport and Communications Agency Traficom. For more information, visit Traficom’s website (linkOpens in a new windowOpens in a new window).
Additional obligations related to the accessibility statement
Services within the scope of the Digital Services Act must have an accessibility statement describing the state of accessibility of the service. In addition to the general description, the accessibility statement for services falling within the scope of the Act from now on must include the following information:
- The service provider must provide information on the product needed to use the service
- If the use of a digital service requires the use of a product in order to function, the service provider must also provide information on how the product in question relates to the digital service, what accessibility features it has and how it works with assistive devices and other arrangements that assist the use of the service.
- The service provider must provide information on the fulfilment of additional service-specific requirements
- The service provider shall also publish a description of how additional service-specific requirements concerning the service in question have been taken into account in the service.
More information on the accessibility statement and how to prepare one is available on the page Information about the accessibility statement. Accessibility monitoring has created a tool to help you prepare a statement. It will be updated to include the amendments to the Digital Services Act before the application of the new accessibility requirements begins.
Legal rights of users and monitoring of accessibility requirements
Users of digital services have exactly the same rights with regard to the accessibility requirements of the Digital Services Act. In other words, the user will also have the right to submit requests for clarification and complaints about accessibility concerning the services and additional requirements falling within the scope of the Act from now on. Read more about user rights on the User rights page.
The Regional State Administrative Agency for Southern Finland also supervises the implementation of accessibility requirements with regard to the digital services covered by the Act from now on and the additional requirements concerning them. More information on the tasks of the supervisory authority.
Transition period for amendments to the Digital Services Act
Services falling within the scope of the Digital Services Act from now on must comply with the accessibility requirements and service-specific additional requirements after the transition period, i.e., from 28 June 2025 onward.
However, if a service agreement concerning a service falling within the scope of the Digital Services Act from now on has been concluded before the end of the transition period on 28 June 2025, the agreement may remain unchanged until the agreement expires. However, the agreement may not be extended unchanged for more than five years from the end of the transitional period.
This also means that as of 28 June 2025, new service agreements will no longer be allowed for services that do not comply with the accessibility requirements and service-specific additional requirements of the Digital Services Act.
The accessibility requirements and additional requirements of the Digital Services Act do not apply to:
- contents of digital services that are archived before 28 June 2025.
- pre-recorded time-based media published before 28 June 2025.
- office file formats in digital services published before 28 June 2025.
What to do if accessibility requirements cannot be met?
Deviation from accessibility requirements for service-specific additional requirements
The service provider may deviate from the accessibility requirements of the Digital Services Act if, based on its accessibility assessment, it can demonstrate that compliance with the accessibility requirements places a disproportionate burden on its digital service. Information about a disproportionate burden is available on the Information about the accessibility statement page:
The service provider may deviate from the additional service-specific requirements added to the Digital Services Act if compliance imposes a disproportionate burden on its digital service or if compliance would fundamentally alter the basic nature of the service.
With regard to additional requirements, the assessment of disproportionate burden shall take into account the following:
- Ratio of the costs of compliance with accessibility requirements to the operational and capital expenditure for the economic operator.
- Ratio of the net costs of compliance with accessibility requirements to the net turnover of the economic operator.
- Cost-to-benefit ratio. When assessing this, particular attention shall be paid to the needs of persons with disabilities to use the service.
A new assessment shall be carried out by the service provider whenever the digital service is changed, when requested by the supervisory authority, or at least every five years. The assessment carried out shall be documented. Documentation must also be kept for five years after the provider has provided the digital service.
However, no exception can be made to the accessibility requirements or additional service-specific requirements if the service provider receives funding granted for improving accessibility, and this funding originates from external public or private sources, not from the service provider’s own resources.
Notification of shortcomings in accessibility
If the digital service does not meet the accessibility requirements, the service provider must inform the supervisory authority of the shortcomings in compliance and how the shortcomings will be rectified.
Accessibility monitoring will later publish more detailed instructions on how to report shortcomings in accessibility.
The Act on the Provision of Digital Services (in Finnish)Opens in a new window
Government Decree on Accessibility Requirements for Certain Digital Services (in Finnish)Opens in a new window
Directive (EU) 2019/882 of the European Parliament and of the Council on accessibility requirements for products and services (Accessibility Directive)Opens in a new window