DESAmedia ·

Short answer

Since 28 June 2025, Lithuania has applied the Law on Accessibility Requirements for Products and Services, which transposes the European Accessibility Act (Directive (EU) 2019/882). It covers consumer-facing online shops, banking services, passenger transport, e-books and electronic communications services, while microenterprises providing services are exempt. Public sector websites are separately subject to the EN 301 549 standard, which is based on WCAG 2.1 level AA. A good way to start checking a website's accessibility is with an automated tool and manual keyboard navigation, beginning with the most important user journey, such as making a purchase or submitting an application.

Who the requirements apply to

Businesses: the Law on Accessibility Requirements for Products and Services

In Lithuania, the European Accessibility Act was transposed by Law No. XIV-1633 of 8 December 2022, which entered into force on 28 June 2025. Amendments to it entered into force on 1 April 2026. For owners of websites and apps, the most relevant services are:

  • e-commerce, that is, consumer contracts concluded at a distance through a website or app;
  • consumer banking services;
  • elements of air, bus, water and rail passenger transport services (websites, apps, e-tickets);
  • e-books and dedicated software for them;
  • electronic communications and access services for audiovisual media.

The law focuses on services provided to consumers (B2C). The guidelines of the Ministry of Social Security and Labour stress that for e-commerce it does not matter what is being sold: a bicycle, a holiday or an insurance policy. The whole platform and the entire buyer journey from search to payment must be accessible, including older features that consumers still use.

Microenterprises providing services are exempt from the requirements. These are businesses with fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million. This exemption does not apply to product manufacturers.

Service contracts concluded before 28 June 2025 may continue unchanged until they expire, but no later than 28 June 2030. For e-commerce, the ministry's guidelines are clear: from 28 June 2025 the service must be accessible every time a new contract is concluded with a consumer, that is, with every new purchase.

Compliance of e-commerce and banking services is supervised by the State Consumer Rights Protection Authority. Transport services are supervised by the Lithuanian Transport Safety Administration, and electronic communications services by the Communications Regulatory Authority. A complaint can be filed not only by a consumer but also by an association or another interested party, and fines for infringements range from €500 to €15,000.

Public sector: Directive (EU) 2016/2102

Websites and mobile apps of state and municipal institutions are covered by a separate directive, Directive (EU) 2016/2102. In Lithuania it was transposed by Government Resolution No. 480, which approved the description of general requirements for websites and mobile applications of state and municipal institutions and bodies. Websites must comply with the EN 301 549 V3.2.1 standard, institutions must publish an accessibility statement and provide a way to report barriers. Monitoring and methodological support are provided by the State Digital Solutions Agency.

Who Legal act Technical basis Supervision
Online shops, banks (B2C) Law No. XIV-1633 (EAA) EN 301 549, in practice WCAG AA State Consumer Rights Protection Authority
Passenger transport Law No. XIV-1633 (EAA) EN 301 549, in practice WCAG AA Lithuanian Transport Safety Administration
State and municipal institutions Government Resolution No. 480 (Directive 2016/2102) EN 301 549 V3.2.1 State Digital Solutions Agency
Microenterprises providing services Exempt from the requirements WCAG 2.1 AA recommended Not applicable

What WCAG 2.1 AA means in practice

WCAG (Web Content Accessibility Guidelines) is produced by the World Wide Web Consortium, W3C. The guidelines have three levels: A, AA and AAA. In Europe the reference point is level AA, because it is used by the EN 301 549 standard. Its current version, V3.2.1, is based on WCAG 2.1.

The latest version of the guidelines, WCAG 2.2, adds 9 new success criteria (for example, a minimum target size for clickable elements and a requirement that focus is not hidden behind a sticky header) and removes one criterion (4.1.1 Parsing). In the EU it will become legally binding only once it is included in an updated version of EN 301 549, but the ministry's guidelines recommend aiming for WCAG 2.2 already.

In practice, level AA means roughly the following for a website:

  • Contrast. Contrast between normal text and its background of at least 4.5:1, and at least 3:1 for large text. Light grey text on a white background usually fails this requirement.
  • Keyboard. Every action can be done without a mouse: opening the menu, filling in a form, adding a product to the basket, closing a pop-up.
  • Visible focus. When navigating with the Tab key, it is always clear which element is active.
  • Alternative text. Informative images have a description that a screen reader (software that reads screen content aloud) can read out.
  • Forms. Every field has a label, and errors are described in words, not by red colour alone.
  • Structure. Headings follow a logical hierarchy, the page language is set in the code, and link text makes sense without context.
  • Zoom. When text is enlarged to 200% and on a phone-width screen, content does not overlap and no horizontal scrolling is needed.
  • Video. Videos have captions, and automatically moving content can be paused.

The most common errors on websites

There is no separate large-scale study for Lithuania, so the most useful reference point is the WebAIM Million: an annual analysis of the home pages of the world's million most popular websites. In the 2026 report (data collected in February 2026), automatically detectable WCAG 2 errors were found on 95.9% of pages, with an average of 56.1 errors per page.

Error Share of pages
Low text contrast 83.9%
Images without alternative text 53.1%
Form fields without labels 51.0%
Empty links (e.g. an icon with no text) 46.3%
Empty buttons 30.6%
Page language not set 13.5%

These six categories account for 96% of all detected errors and, according to WebAIM, have remained the same for seven years. Lithuanian websites are built with the same themes, plugins and templates, so the pattern of errors here is likely to be similar. Another important finding of the report: pages using ARIA attributes had an average of 59.1 errors, compared with 42 on pages without them. Incorrectly applied accessibility attributes often add barriers instead of removing them.

How to check your website

A check has two parts. Automated tools find technical shortcomings quickly, but WebAIM stresses that the absence of detected errors does not mean a page is accessible. The rest can only be found manually.

Free automated tools:

  • WAVE (WebAIM) shows errors directly on the page and is convenient for non-developers;
  • axe DevTools (Deque) is a browser extension that suits developers, as it shows which code element contains the error;
  • Lighthouse, built into the Chrome browser, gives an accessibility score alongside performance and SEO metrics.

A manual check needs no special knowledge:

  1. Put the mouse aside and go through the main journey using only the keyboard (Tab, Shift+Tab, Enter, Space, Esc). Can you always see where you are? Do you get stuck anywhere?
  2. Zoom the browser to 200% and look at the page on a phone.
  3. Turn on a screen reader: the free NVDA on a Windows computer, or the built-in VoiceOver on Mac and iPhone. Listen to how the menus, forms and buttons sound.
  4. Fill in a form with errors and check whether the error messages are understandable.

Where to start if your website is already live

Rebuilding the whole website is rarely necessary. We recommend this order:

  1. Determine whether the requirements apply to you. Do you provide services to consumers online, are you a microenterprise, are you a public sector body?
  2. Pick the most important journey. For an online shop that is search, the product page, the basket, registration and payment. For an institution it is contacts, service descriptions and forms.
  3. Fix templates, not pages. Most errors come from a few repeated components: the header, the menu, the product card, the form field. Fix the component and the error disappears from hundreds of pages.
  4. Check third-party parts. Payment windows, chat widgets and cookie banners are often inaccessible. If they are part of your user journey, ask the vendor whether its solution complies with EN 301 549.
  5. Publish accessibility information. For the public sector this is the mandatory accessibility statement; for businesses the law requires information about the accessibility of the service. List known shortcomings and a contact for reporting a barrier.
  6. Build checks into the process. An automated test before every new release and a manual check once a quarter stop errors from coming back.

"Accessibility widgets" that add a button to increase contrast or font size do not fix code errors. For a screen reader user, an unlabelled button stays unlabelled whatever widget is installed.

Why it pays off even without the requirements

Even if the law does not apply to you, accessibility work pays off in several ways. Many WCAG requirements overlap with technical SEO: alternative text, a logical heading hierarchy, a declared language, semantic HTML and clear link text help both search engines and AI assistants understand a page. Lighthouse scores accessibility alongside performance and SEO, so these areas are usually fixed together.

Second, accessibility benefits more than people with disabilities. Higher contrast helps when reading a phone in sunlight, clear error messages reduce abandoned orders, and working keyboard navigation matters to everyone who fills in long forms. Third, accessibility can also be a public procurement criterion: EN 301 549 is complemented by the technical specification TR 101551, which deals specifically with accessibility requirements in ICT procurement. A supplier whose solutions already meet the standard needs less extra work in such a tender.

When building desamedia.lt, we treated WCAG 2.1 AA as the minimum: every component has a 3 px focus ring, clickable elements are at least 44 px, and colour contrast meets AA requirements.

What to do next

If you want to know how your website performs on accessibility, you can request a free website audit: we will review accessibility together with performance and SEO and tell you what to fix first. We build new websites to meet accessibility requirements from the start; read more on our website development and public sector pages.

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