An accessible website helps more people find information, use a service and make contact. A decision-maker also needs to distinguish good usability, a technical WCAG target and a legal obligation. Finland expanded the scope of its Act on the Provision of Digital Services on 28 June 2025, but the expansion covers specified consumer services rather than automatically applying to every corporate brochure website.
Accessibility is both user experience and risk management
Accessibility means that people can perceive, understand and operate web content and functions in different ways. A person may navigate by keyboard, enlarge text, listen through a screen reader or need clear language and a predictable structure. The same decisions often help customers using a mobile device, working in a difficult environment or dealing with a temporary impairment.
For a company, accessibility can affect customer experience, service reach, procurement requirements and potential legal duties. It should not be treated as an extra test at the end of a launch because structure, colours, components, content, forms and third-party services are created throughout the project. The buyer needs to set the intended level and allocate responsibilities before implementation begins.
The expanded Finnish law does not cover every company website
Finland's Act on the Provision of Digital Services has long applied to the public sector and certain other organisations. From 28 June 2025, its scope expanded to new digital services specifically listed in the law and offered to consumers: ecommerce, ebooks, certain passenger transport and banking services, services providing access to audiovisual content, and communications services. This does not mean every private company's brochure website automatically falls within the act.
The new service requirements in Chapter 3a do not apply to digital services provided by microenterprises. Traficom describes a microenterprise as having fewer than ten employees and annual turnover or a balance-sheet total of no more than two million euros. The exemption should not be read as a general release from every accessibility duty because an organisation may fall within the act on another basis.
WCAG 2.1 is the practical legal baseline, while WCAG 2.2 is the current development target
When a digital service is subject to the accessibility requirements of the Finnish act, Traficom describes WCAG 2.1 Level A and AA criteria as the practical technical baseline. WCAG organises accessibility around content being perceivable, operable, understandable and robust. A contract should name the target version and conformance level so that the phrase accessible website does not remain open to interpretation.
W3C recommends using the latest WCAG 2.2 version, which adds criteria addressing areas such as focus visibility, target sizes and accessible authentication. It is therefore reasonable to consider WCAG 2.2 A/AA as the development target for a new site, while Finland's current practical legal reference remains WCAG 2.1. Automated checks can identify some issues, but quality assurance also requires manual testing and testing with assistive technologies.
Accessibility is visible in structure, content and transactions
Practical review areas include heading structure, keyboard operation, visible focus, colour contrast, text resizing and reflow, text alternatives for images, alternatives for video, and understandable link text. Semantic structure helps assistive technologies interpret a page, but accessibility does not come from technical markup alone: the wording, navigation and interactions also need to make sense to the user.
Forms and other critical service journeys deserve particular attention. Fields need understandable labels and instructions, errors must be communicated clearly, and the task must work without a mouse. The same expectations should cover cookie choices, appointment booking, embedded tools, downloadable documents and other third-party solutions because, to the user, they form part of one service.
A service within the law's scope needs a statement and feedback route
If the organisation and service are subject to the accessibility requirements of the Finnish act, the website needs an accessibility statement that is easy to find and kept current. According to Traficom, it describes matters including the level of compliance, known shortcomings and their reasons, the date and method of assessment, and a route to the supervisory authority. Consumer services added to the scope in 2025 also have service-specific information requirements.
The statement must also explain how a user can provide accessibility feedback and who in the organisation handles it. The feedback channel needs a real operating process with ownership for responses, prioritised corrections and statement updates. A statement does not replace correcting defects, and an assessment does not remain current automatically when content, components or external services change.
Buy accessibility as requirements, evidence and continuing ownership
A request for proposal should identify the service in scope, the target WCAG version and level, the content and external systems covered by the assessment, and the methods used for testing. Deliverables may include severity-ranked findings, retesting of corrections, information needed for an accessibility statement, guidance for content editors and a clear acceptance process before launch.
After launch, ownership is still needed for new content, integrations, component updates and user feedback. This article provides general information and is not legal advice on the status of an individual organisation or service. If the scope is unclear, the company should check current authority guidance and seek legal advice where appropriate; accessibility remains a sound quality objective even when the law does not directly require it.
When you want accessibility considered across the design, content and quality assurance of your company website, explore our website service.
Sources and further information
Information about legal scope and duties is based on the current act in Finlex and official guidance from Traficom. The technical target is described using W3C's WCAG material.
