Who it applies to · sectoral services in art. 3(2) and products in art. 3(1)
The other services covered by the act
Besides e‑commerce the act names five kinds of service, each with its own supervisory authority and its own article of extra requirements. All must meet art. 12 (information and the four principles); below is what comes on top. Plus the products in art. 3(1) — because a page selling a computer or an e‑reader has to inform about their accessibility (art. 18(1)).
Consumer banking (art. 16)
"[…] consumer banking services shall ensure: 1) the perceivability, operability, understandability and compatibility of the methods of consumer identification, electronic signatures, security and payment services; 2) the provision of information in Polish or – with the consumer's consent – in another language, at level B2 of the Council of Europe's Common European Framework of Reference for Languages." (our translation)
Supervisory authority: the Financial Ombudsman (art. 38(3)(3)). Point 2 is unique in the whole act: it requires understandability at level B2 — contracts, fee tables, app messages and terms written in language a person without legal or financial training understands. That is a measurable (readability indices) and auditable criterion. It covers banks, credit unions, payment institutions, consumer lenders, payment operators (for consumer services), fintechs. Consumer banking under the act includes accounts, consumer and mortgage credit, payment services, electronic money (art. 5(30) lists them following the directive).
Telecoms (art. 13)
"[…] the transmission of voice communication together with real‑time text communication shall be ensured, and where video transmission is available – total conversation." Real‑time text and total conversation (voice + text + video at once, for deaf people using sign language) are requirements on operators, not on their websites — but operators' websites, apps and customer panels are subject to art. 12 like every service. Authority: the President of UKE. Excluded: machine‑to‑machine transmission (art. 3(2)(1)).
Access to audiovisual media services (art. 14)
Electronic programme guides and information about accessibility features (captions, audio description, sign language) must be perceivable, operable, understandable and compatible, and the features delivered by the broadcaster — transmitted in a quality that allows them to be displayed, synchronised and controlled. It applies to VOD platforms, internet TV apps, cable and satellite operators. Authority: the President of UKE. Programme content itself is regulated by the broadcasting act (quotas of accessibility features); the new act concerns access to it.
Passenger transport (art. 15)
Services accompanying bus and coach, waterborne, air and rail transport: websites, apps, electronic tickets and ticketing systems, real‑time passenger information, terminals (art. 3(2)(3)). Art. 15 adds a duty to inform about conditions for people with special needs in vehicles and buildings, about available assistance and its current state, about ticketing systems and real‑time travel. Authorities: regional road transport inspectorates, the President of UTK, the President of ULC, maritime and inland navigation offices. Urban transport and local‑government services are excluded (art. 4(3)), apart from interactive information terminals. Services conforming to the EU passenger rights regulations are deemed conforming as regards information (art. 20(2)).
E‑books (art. 17)
"[…] e‑book distribution services shall ensure: 1) where an e‑book contains audio in addition to text – synchronisation of text and audio; 2) interoperability of the e‑book file ensuring the compatibility and operability of assistive tools […]; 3) access to the content and structure of the e‑book; 4) the ability to navigate the content and layout […], including in a dynamic layout; 5) the ability to choose an alternative presentation of the content […]; 6) the provision of information on the functions and properties ensuring the accessibility of the e‑book's content via metadata." (our translation)
It applies to publishers, distributors and platforms (the service consists of delivering files together with software to read them, art. 5(33)). In practice: EPUB 3 with navigation, structure, image alternatives and accessibility metadata (schema.org accessibilityFeature, ONIX code 196), DRM that does not block screen readers, an e‑book shop that is accessible like any shop. Exclusion: e‑books published before 28 June 2025 (art. 86(1)–(2) for content; products under art. 84). Authority: the President of UKE.
Products (art. 3(1), arts. 7–11)
Computers and operating systems, payment and self‑service terminals (ATMs, ticket machines, check‑in, information kiosks), terminal equipment for telecoms and media (phones, routers with an interface, set‑top boxes, smart TVs), e‑readers. Duties of manufacturers, importers and distributors (arts. 22–31): conformity assessment, EU declaration of conformity, CE marking, technical documentation, information on the product and in the manual, a complaints register. For a shop owner one thing matters: if you sell such a product to consumers you are a distributor (art. 30) and must check the CE marking and the enclosed information, and on the product page — pass on the manufacturer's accessibility information (art. 18(1)). Self‑service terminals in use before 28 June 2025 may operate for up to 20 years (art. 85(3)).
Common to all
Conformity assessment and information
Art. 32: assessment, information in the terms or an equivalent document, monitoring, corrective measures, self‑notification of the authority.
Complaints
Arts. 35–37: channels, content, 30 days, the effect of silence, the content of the reply. Deadlines.
Disproportionate burden
Art. 21: three cost criteria, documentation for 5 years, reassessment every 5 years, notification to the authority; not for operators that received funding.
Fines
Art. 73: up to 10× the average wage, max 10 % of turnover, five grounds. The path.