Web and App Accessibility under WCAG 2.2 AA from June 28, 2025: An Opportunity, Not Just an Obligation

A new era of web service accessibility begins

On June 28, 2025, Act No. 351/2022 Coll. on the accessibility of products and services for persons with disabilities came into force in Slovakia. This legislation, which implements the European Accessibility Act, affects a wide range of digital services and represents not only a legal obligation for businesses but above all a business opportunity.

Who is accessibility for?

The statistics speak for themselves: approximately one million people with varying degrees of disability live in Slovakia. Across the EU, it's as many as 101 million people, with 27% of residents over the age of 16 having some form of health-related limitation. This is a significant market segment with enormous purchasing potential.

A practical example: A visually impaired customer tries to shop in your e-shop using a screen reader. If your website doesn't let them:

• Navigate properly between elements
• Identify buttons and links
• Find and use the cart
• Complete the order

The result? A lost customer who moves to a competitor with a better-adapted solution.

Who do the new rules for websites and apps apply to?

The law applies to all companies with 10 or more employees or an annual turnover above EUR 2 million that provide online services.

The most common cases include:

• e-commerce (online sale of goods and services),
• websites and portals,
• mobile apps,
• online forms, orders and payments,
• electronic communication with customers (e.g. chatbots, email interfaces).

Microenterprises (fewer than 10 employees and turnover up to €2 million) are exempt from these obligations.

Significant exemptions

Specific areas

• Taxes, fees and lotteries
• Services of notaries, lawyers and bailiffs within their powers
• Online encyclopedias and non-profit educational repositories
• Open source platforms and free software

Legacy content

• Video and audio files published before June 28, 2025
• Office files (.pdf, .docx) from earlier periods
• Archived websites with no updates after June 2025

A transition period provides flexibility

For digital services launched before June 28, 2025 under binding contracts, a transition period until June 28, 2030 applies. You can use this time to gradually implement the required changes.

Technical requirements for websites and apps under WCAG 2.2 AA

Your web solutions must meet the international Web Content Accessibility Guidelines 2.2 at level AA. In practice, this means:

Visual accessibility

• Sufficient color contrast (at least 4.5:1 for normal text)
• Text can be enlarged up to 200%
• Color is not used as the only means of conveying information

Navigation and operation

• Full keyboard functionality
• Logical element order when tabbing through the page
• Clearly labeled buttons and links

Content and structure

• Alternative text for all images
• A clear heading hierarchy (H1, H2, H3...)
• Plain language at level B2 of the European framework

Mandatory accessibility statement for websites and apps

Every website must publish an accessibility statement that includes:

• The current state of compliance with the requirements
• A list of inaccessible content (if any)
• Contact details for reporting issues
• Information on how to file a complaint with ÚNMS SR (Slovak Office of Standards, Metrology and Testing)

We recommend placing this statement in the website footer and updating it regularly.

Penalties and enforcement

The Slovak Trade Inspection (SOI) will oversee compliance with the new rules. Fines range:

• From €200 to €30,000 depending on severity
• Up to 3% of annual turnover for serious violations
• Possible waiver with active cooperation and remediation

SOI favors an informative approach over a punitive one and, in the initial period, will focus on supporting businesses in implementing the changes.

Assessing disproportionate burden

If implementation is too costly for your company, you can apply for an exemption. The assessment must include:

Cost ratio

• Accessibility costs vs. total cost of the service
• Return on investment analysis
• Impact on the company's economic stability

Documenting the decision

• A properly justified assessment of the situation
• Evidence of efforts to implement
• Keeping documentation for 5 years

Practical steps to implementation

1. Audit the current state Use free tools for a basic check:

• axe DevTools for Chrome/Firefox
• WAVE (Web Accessibility Evaluation Tool)
• Lighthouse Accessibility audit

2. Prioritize fixes

• Start with critical errors (contrast, keyboard)
• Continue with structural fixes (headings, links)
• Finish with more complex solutions

3. Professional audit For complete peace of mind, we recommend working with certified accessibility experts who will:

• Carry out a detailed audit according to EN 301 549 and WCAG 2.2
• Prepare an implementation plan
• Create an accessibility statement

Web and app accessibility as a competitive advantage

Instead of seeing accessibility as a cost, think of it as an investment in:

• Expanding your customer base – you'll reach hundreds of thousands of new potential clients
• Better UX for everyone – accessible solutions are often more intuitive
• SEO optimization – proper structure helps search engines
• Building your image – socially responsible business

First steps today

1. Test your website with free tools
2. Identify the most critical issues
3. Plan a gradual implementation of the fixes
4. Prepare an accessibility statement
5. Consider a professional audit for complex solutions

The accessibility law isn't just a bureaucratic obligation – it's an opportunity to modernize your digital services, reach new customers and stand on the right side of social responsibility. The sooner you start, the greater the competitive advantage you'll gain.