Legal and data10 min read

The Accessibility Act and customer service: what applies to e-commerce

Short answer

The Swedish act implementing the European Accessibility Act has applied since 28 June 2025 and requires e-commerce services, including customer service's support services, to be perceivable, operable and understandable with assistive technology. Micro-enterprises with fewer than ten employees and under two million euros in turnover are exempt for services. For customer service it means accessible contact routes, a chat and a help centre that work with assistive technology, and information about the service's accessibility in both speech and writing.

Anyone responsible for e-commerce or customer service has probably heard of the accessibility act as a requirement on the website: contrast, alternative text, keyboard navigation. Fewer have noticed that the law also places requirements on customer service, on the chat, the forms, the help centre and on how you inform customers about the service's accessibility. The law has applied since summer 2025, and the Swedish Post and Telecom Authority, PTS, is now auditing e-commerce services. This article goes through what applies, who is covered and what customer service needs to do. It is not legal advice; check with your lawyer.

What does the accessibility act require of e-commerce since 28 June 2025?

That the e-commerce service can be used by people with disabilities, and that the company informs customers about how the service is accessible. The Swedish act on the accessibility of certain products and services, act (2023:254), implements the EU's accessibility directive, Directive (EU) 2019/882, which the European Commission describes as common requirements for, among other things, e-commerce platforms, banking services and electronic communication. According to PTS, the act entered into force on 28 June 2025, and PTS supervises e-commerce services.

For e-commerce PTS points out two things beyond the general requirements on the service. According to PTS's review of the sector-specific requirements four functions must be perceivable, operable, understandable and robust: identification methods, electronic signatures, security functions and payment functions. And the retailer must reproduce the accessibility information that exists about what is sold; if there is, for example, information on how a product works with a hearing aid, it may not be left out of the store.

Is your company covered by the act?

Yes, if you sell to consumers via a website or app and are not a micro-enterprise. According to PTS's questions and answers on the act, micro-enterprises are exempt from the requirements on services, and a micro-enterprise is a company with fewer than ten employees and less than two million euros in turnover. Both conditions must be met. An online store with six employees and 30 million kronor in turnover is therefore covered.

Three things to watch:

  • The threshold is counted on the company, not on customer service. A service company with 40 employees and three people in customer service is covered.
  • The exemption applies to the service, not to information about the products. If you sell products that have accessibility information, it must be reproduced regardless of company size, according to PTS.
  • Customers can complain. PTS accepts complaints about the accessibility of products and services, so the question comes not only from the regulator but from customers who cannot shop with you.

What does the act mean for customer service: chat, forms and help centre?

That customer service's contact routes must be usable with assistive technology, and that customer service must be able to explain how the service is accessible. The directive calls them support services, and PTS summarises the requirements like this: support services are help desks, call centres, technical support, relay services and training; they must be able to inform about the service's accessibility and how it works with assistive technology, and they must be reachable through accessible modes of communication.

For an online store with a few hundred tickets a week that means four concrete things:

  1. More than one contact route, and all of them must work. A customer who cannot use the phone must be able to reach you in text, and a customer who cannot use a mouse-driven chat must be able to reach you another way. Which channels fit which tickets is covered in the article on channel choice; the act adds that no channel may be the only one unless it is accessible.
  2. The chat and the forms must work with screen readers and keyboard. That applies to the chat window, the buttons, attachments and the chatbot that answers first. A bot that can only be opened with a mouse, or whose answers are not read aloud, shuts customers out.
  3. The help centre must be perceivable, operable and understandable. Headings in the right order, text that can be enlarged, images with alternative text and language that is understandable. How a help article is written so that it is understandable is described in the article on writing help articles; plain language is also an accessibility requirement.
  4. Customer service must be able to answer the question "how is the service accessible?" That requires an article in the knowledge base that agents, chat and help centre answer from, so the answer is the same whatever the channel.

The fourth point is tied to a requirement of its own. According to PTS's page on information about the service's accessibility, the information must contain a general description of the service and how it works, explain the parts that are necessary to understand how the service works, and be available to the public in both speech and writing.

What do perceivable, operable, understandable and robust mean in practice?

They are the four principles from the WCAG web standard, and they can be translated into a short list for help centre and chat. W3C, which maintains the standard, describes them like this: information and interface must be perceivable with at least one sense, the interface must be operable without requiring something the user cannot do, the content and its operation must be understandable, and the content must be robust enough to be interpreted by different assistive technologies.

PrincipleWhat it meansExample in customer service
PerceivableThe content exists in a form the customer can take inAlternative text on screenshots in the help centre, sufficient contrast in the chat, captions on instruction videos
OperableCan be controlled with keyboard and assistive technologyThe chat window opens, accepts typing and closes without a mouse; form fields can be reached in order
UnderstandableThe language and the interface can be understoodError messages in the form say what is wrong and how to fix it; plain language in the articles
RobustWorks with different browsers and assistive technologiesThe chat and the help centre follow the standard so screen readers can read them

A practical test: ask someone on the team to use the chat and submit a form using only the keyboard, and read a help article with the screen reader built into their phone. What cannot be done that way is what the act requires you to fix.

What does supervision look like, and what happens if you do not meet the requirements?

PTS is auditing e-commerce services during 2025 and 2026, started with larger players and can impose a penalty fee. According to PTS's page on supervision, it checks that websites are perceivable, operable, understandable and robust, and that there is information on how the service works, provided in an accessible way. In a press release PTS describes eleven new cases opened as part of a planned audit of e-commerce services' websites.

That does not mean smaller retailers can wait. Supervision starts in stages, complaints from customers can open a case at any time, and a company close to the micro-enterprise threshold grows into the act the day it passes it. The Swedish Trade Federation has published a checklist for member companies that is a good start for anyone who does not know where they stand.

What to do

  1. Decide whether you are covered. Count employees and turnover. If you are under both thresholds you are exempt for the service, but must still reproduce the products' accessibility information.
  2. Test the contact routes. Chat, forms and help centre with keyboard only and with a screen reader. Write down what does not work.
  3. Make sure no channel is the only one. The customer must always have an accessible alternative, for example email or a form when the chat does not work with assistive technology.
  4. Write the article on the service's accessibility: how the service works, which parts are necessary to understand, and how it works with assistive technology. Publish it in the help centre and make sure it can be read aloud. In Supportifier the same article is used by the help centre, the chat and the agents, so the answer is the same in every channel.
  5. Reproduce the products' accessibility information where the supplier provides it, on the product page and in the help centre.
  6. Ask the suppliers of chat, forms and help centre for their accessibility statement. If they do not have one, that is a reason to ask why.

Common questions

Does the accessibility act apply to our help centre?

Yes, if the company is covered by the act. The help centre is part of the e-commerce service and of customer service's support service, and must therefore be perceivable, operable and understandable with assistive technology. That means correct heading structure, alternative text on images, text that can be enlarged and understandable language. In addition the help centre must contain the information on how the service is accessible, in a form that can be both read as text and read aloud.

Does the chatbot have to be accessible?

Yes. The chatbot is often the customer's first contact route, and the act requires that support services can be reached through accessible modes of communication. The chat window must be possible to open, use and close with a keyboard, the answers must be readable by a screen reader, and there must be an accessible alternative when the bot is not enough. Require an accessibility statement from the supplier and test it yourselves before you rely on it.

We have fewer than ten employees, can we ignore the act?

Only if you also have a turnover of less than two million euros, and only for the requirements on the service. Both conditions must be met to count as a micro-enterprise according to PTS. The requirement to reproduce accessibility information about the products you sell applies anyway. And a company that grows past either threshold is covered from that day, so it is wise to build accessibly from the start.

What should the information about the service's accessibility contain?

A general description of the service and how it works, an explanation of the parts necessary to understand how the service is used, and a description of how it works with assistive technology. According to PTS the information must be available to the public in both speech and writing. Put it as its own article in the help centre, link to it from the footer and make sure customer service can refer to it.

Sources

Martin Carlsson

By

Martin Carlsson

Martin har fjorton år på Länsförsäkringar Gävleborg bakom sig. Han började med att leda en kundserviceenhet på drygt 20 medarbetare i telefon, mejl och chatt, satt sedan i ledningsgruppen som chef för verksamhetsutveckling och IT, och har de senaste åren ansvarat för den digitala kundupplevelsen. I dag är han affärsansvarig för Alf, Länsförsäkringars uppkopplade tjänst som bevakar hemmet och varnar innan skador uppstår. Dessförinnan digitaliserade och automatiserade han manuella försäkringsflöden på Gjensidige. Vid sidan av jobbet har han byggt egna webbtjänster, bland annat en jämförelsetjänst för elavtal. Martins motto är att automatisera allt som inte behöver mänskligt handlag, med kunden i centrum. Han har läst systemvetenskap vid Högskolan i Gävle och har på senare år certifierat sig inom AI hos Google.

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  • accessibility
  • legal
  • e-commerce
  • help centre
  • chat

This article is also available in Swedish: Tillgänglighetslagen och kundservice: vad gäller för e-handel?

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