Swedish Act (2018:1937) on Accessibility in Digital Public Services

This article provides information about accessibility laws and regulations but is not legal advice. You should consult a lawyer for advice on specific legal issues or problems.

While the European Accessibility Act (EAA) isn’t set to take effect until later this year, Sweden is already ahead of the curve! Under the Swedish Act (2018:1937) on Accessibility to Digital Public Services, effective since 2019, public sector websites and mobile applications must meet accessibility standards that empower everyone to fully engage with digital services.

What Is Swedish Act (2018:1937)?

Act (2018:1937) aligns with EN 301 549, the European Union’s standard for digital accessibility, setting clear expectations for accessibility across the public sector. EN 301 549 outlines functional accessibility requirements for Information and Communications Technology (ICT), ensuring usability for people with diverse needs.

Because this legislation was enacted before EN 301549 and the EAA, Sweden found it had to add some regulations to its Act to ensure consistency. To do that, they enacted Ordinance (2018:1938).

This ordinance supplements the provisions of Act (2018:1937) by incorporating specific exemptions and clarifications outlined in EN 301 549. For example, EN 301 549 exempts documents published before September 23, 2018, from certain accessibility requirements. While Act (2018:1937) does not explicitly mention this exemption, Ordinance (2018:1938) addresses it, ensuring consistency with the European standard.

This alignment helps Sweden create a standardized, user-friendly digital ecosystem that prioritizes usability and universal design principles. By embedding accessibility into its digital infrastructure, Sweden is paving the way for a more equitable digital experience.

Swedish Digital Accessibility Requirements

The combined framework of Act (2018:1937) and Ordinance (2018:1938) requires public sector bodies to ensure their digital services conform to accessibility standards equivalent to WCAG 2.1 AA, as referenced in EN 301 549. This includes making websites, mobile applications, and digital documents perceivable, operable, understandable, and robust for all users.

The Swedish Act defines “inadequate accessibility” as a form of discrimination under its Discrimination Act (2008:567). This legal framework underscores the importance of eliminating barriers by requiring public sector organizations to:

  • Build inclusive digital platforms.
  • Design services that address diverse user needs.
  • Enable equal access for all citizens.

Compliance Monitoring in Sweden

The Swedish Agency for Digital Government (DIGG) oversees compliance with the Act, offering resources and conducting evaluations to ensure public sector organizations meet accessibility requirements. DIGG’s proactive monitoring holds public bodies accountable, keeping Sweden at the forefront of accessibility initiatives in the EU.

The Importance of Conformance with the Act

Failure to conform to the Act on Accessibility to Digital Public Services can lead to significant legal and financial consequences under the Discrimination Act. Public organizations are encouraged to proactively implement accessibility measures to avoid potential legal issues and to promote inclusivity.

Consequences of Nonconformance:

  • Fines and Penalties: Organizations in violation may face monetary fines proportional to the severity and duration of the infraction. Repeat violations can lead to escalating penalties.
  • Litigation Risks: Affected individuals have the right to file complaints with Sweden’s Equality Ombudsman (DO), potentially leading to legal disputes, reputational harm, and binding court rulings.
  • Reputational Damage: Nonconformance can erode public trust, damage an organization’s brand, and deter potential users who value inclusivity.

Implications for Private Businesses

While Act (2018:1937) specifically targets public sector organizations, private companies also have a role to play, particularly as the EAA expands accessibility requirements to the private sector. Businesses that prioritize accessibility can:

  • Increase Market Reach: Accessible platforms attract a broader audience, including 15% of the global population living with disabilities.
  • Enhance User Experience: Accessibility improves navigation and functionality for all users.
  • Demonstrate Leadership: Being proactive about accessibility shows a commitment to ethical practices.
  • Empower Users: Providing access to vital services fosters independence for people with disabilities.
  • Create Trust: Accessible platforms demonstrate a commitment to serving all members of society, creating trust and loyalty. According to 84% of blind participants in a TPGi survey, accessibility has a moderate or significant impact on their willingness to return to a business.

Sweden and the European Accessibility Act (EAA)

Sweden’s approach to implementing the EAA focuses on integrating accessibility standards into its existing framework, mirroring strategies seen in other EU countries.

The EAA establishes requirements for:

  • Electronic Communication Services: Including websites, mobile apps, and customer service platforms.
  • Banking Services: Accessible ATMs and online banking platforms.
  • E-Commerce Platforms: Websites and apps facilitating the sale of goods and services.
  • Passenger Transport Services: Online booking systems for travel and ticketing.
  • Consumer Electronics: Ensuring accessibility in self-service terminals like payment kiosks.

While this proactive approach necessitates adjustments to ensure consistency with the EAA and EN 301 549 standards, Sweden deserves recognition for swiftly enacting supplementary legislation to achieve this alignment. By creating consistency in its policies with the EAA, Sweden continues to promote a more inclusive digital ecosystem that meets the needs of diverse users.

Looking Ahead: The June 2025 Deadline

With the EAA’s conformance deadline approaching on June 28, 2025, Swedish businesses have a unique opportunity to lead by example. Organizations that invest in accessibility now position themselves for success in an increasingly inclusive and competitive European market.

To help businesses navigate these changes, TPGi offers resources like the EAA Resource Center and the Essential Guide to the European Accessibility Act — designed to simplify conformance and drive impactful results.

Explore Additional EU Member Resources

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About Melissa Morse

Melissa Morse is a passionate advocate for digital accessibility and an accomplished content creator at TPGi. With expertise spanning accessibility, HR compliance, and recruiting, Melissa brings a unique perspective to her work — bridging the gap between inclusive digital experiences and equitable workplace practices.