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Poland's digital accessibility act for public sector websites

Updated October 14, 2026 · 9 min read

The Polish act of 4 April 2019 on the digital accessibility of websites and mobile applications of public bodies (ustawa o dostępności cyfrowej; consolidated text: Journal of Laws 2023 item 1440) implements Directive (EU) 2016/2102. It requires public bodies – among others, public finance sector units – to meet the requirements in the annex to the act, which are the WCAG 2.1 success criteria at levels A and AA, and to publish an accessibility statement. The minister responsible for digitisation supervises and monitors once a year, and fines go up to PLN 10,000.

This article is a factual overview, not legal advice.

The act at a glance

Question Answer
Act Act of 4 April 2019, Journal of Laws 2019 item 848, consolidated text 2023 item 1440
Implements Directive (EU) 2016/2102
Covers websites and mobile apps of public bodies
Requirements annex to the act: WCAG 2.1 success criteria, levels A and AA
Accessibility statement mandatory, reviewed by 31 March every year
Supervision and monitoring minister responsible for digitisation, monitoring once a year
Fines up to PLN 10,000 or up to PLN 5,000

Who is covered

Article 2 lists the public bodies that have websites or mobile apps or manage elements of them:

  1. public finance sector units,
  2. other state organisational units without legal personality,
  3. other legal persons created to meet needs of general interest that are not industrial or commercial, if bodies under points 1 and 2 finance more than 50% of them, hold more than half of the shares, supervise their management body or appoint more than half of their supervisory or management board,
  4. associations of these bodies,
  5. NGOs carrying out public tasks in health protection and promotion, for people with disabilities and for people of retirement age.

The act does not apply to websites and apps of media service providers. Article 3 also excludes certain elements, among others live multimedia, multimedia published before 23 September 2020, older office documents not needed for current tasks, maps (with a condition for navigation maps), and content the body did not produce, fund or acquire.

Schools, kindergartens, municipalities

If a school, kindergarten or municipal office is a public finance sector unit, it is a public body under Article 2(1). The same rules apply to its website as to a ministry: the annex requirements, an accessibility statement and responses to user requests. Searches for a "school accessibility audit" (audyt dostępności szkoły) often also cover the physical accessibility of the building – the accessibility statement must include information on it or a link to it, but this article does not cover the physical requirements themselves.

Which WCAG applies

Article 5 states that a public body ensures digital accessibility by meeting the requirements in the annex to the act. The annex is titled "Web Content Accessibility Guidelines 2.1" and lists the WCAG 2.1 success criteria at levels A and AA – from 1.1.1 Non-text Content to 4.1.3 Status Messages. The government site gov.pl describes this as equivalent to WCAG 2.1 level AA "with minor limitations". The annex notes, for example, that criteria 2.4.1, 2.4.2, 2.4.5, 3.1.2, 3.2.3, 3.2.4 and 4.1.3 do not apply to mobile apps.

Article 5(3) adds that the requirements are deemed met when the body ensures accessibility taking into account clauses 9, 10 and 11 of the Polish Standard implementing EN 301 549 V3.2.1:2021.

What about WCAG 2.2? The act refers to WCAG 2.1. WCAG 2.2 contains all 2.1 criteria except the removed 4.1.1 Parsing – and that criterion is still in the annex to the act. Checking a site against WCAG 2.2 AA therefore covers the annex except 4.1.1. See WCAG 2.1 vs 2.2 and WCAG levels.

The accessibility statement

Every public body prepares an accessible accessibility statement (deklaracja dostępności) for each language version of a website or app, following the model in Commission Implementing Decision (EU) 2018/1523 (Article 10). Besides the items in section 1 of the model, the statement includes among others:

  • the publication date of the website or app and the date of the last significant update,
  • information, or a link to information, on how accessibility was assessed,
  • the address of the premises and contact details of the person or unit responsible for digital accessibility,
  • information on non-standard keyboard shortcuts,
  • information on the physical accessibility of the premises,
  • information on whether online sign language interpreting is available,
  • information on how to report a lack of accessibility,
  • a link to the website of the Polish Ombudsman (Rzecznik Praw Obywatelskich).

The link to the statement must be available while navigating the site. The statement is reviewed and updated by 31 March every year and promptly after changes that may affect accessibility (Article 11). A body that invokes disproportionate cost (Article 8) attaches the results of its assessment to the statement; bodies working for people with disabilities or older people cannot use this exemption.

Auditing and checking the accessibility statement

An "accessibility statement audit" in practice means checking two things: whether the statement contains all the items required by Article 10(3)–(5), and whether what it declares matches the actual state of the site. A statement that claims full accessibility for a site full of contrast errors and unlabelled fields is not reliable. The gov.pl FAQ confirms that a public body may assess its own website, for example with the ministry's checklist, but should make sure the assessment is of good quality.

Ex ante accessibility audit

Many people search for an "ex ante accessibility audit" (audyt dostępności ex ante), for example for an investment financed by a loan. Such an audit does not follow from the digital accessibility act – its scope is set by the documents of the programme that requires it. We found no official source to base a description on, so this article explains only the digital part: the requirements for websites and apps of public bodies.

Requests and complaints

Anyone can request that a public body make a specific website, app or element accessible (Article 18). The body has 7 days; if it cannot meet that, it explains why and sets a new date no later than 2 months from the request. If it cannot provide accessibility, it offers an alternative means of access – for example by phone, post, electronic communication or a sign language interpreter (Article 7). After a refusal, the person can file a complaint, which is handled under Division VIII of the Code of Administrative Procedure.

Monitoring and supervision

The minister responsible for digitisation (Article 12):

  • supervises the application of the act,
  • monitors once a year the accessibility of websites and apps using the method of Implementing Decision (EU) 2018/1524,
  • reports to the European Commission every three years,
  • publishes a list of websites and apps of public bodies.

According to gov.pl, the Minister of Digital Affairs is responsible for monitoring; since 2022 the detailed review has covered 100 websites and 45 apps each year. The minister can also send a public body an inquiry, for example about the number of complaints; the body replies within 30 days (Article 13).

Fines: what "WCAG fines" means

WCAG itself contains no fines – fines come from the act. Article 19 provides for two fines, imposed by the minister through an administrative decision:

Breach Condition Fine
unjustified and persistent failure to ensure digital accessibility no improvement in three consecutive monitoring rounds and a growing number of justified complaints up to PLN 10,000
no accessibility statement or missing required items shown in two consecutive monitoring rounds up to PLN 5,000

How it differs from the act on products and services

2019 act (public bodies) 2024 act (EAA)
Covers websites and apps of public bodies businesses providing certain services to consumers, such as e-commerce
Implements Directive (EU) 2016/2102 Directive (EU) 2019/882
Document accessibility statement following the EU model information on how the service meets the requirements
Exemptions among others media service providers micro-enterprises providing services
Fines up to PLN 10,000 / 5,000 up to ten times the average monthly salary, at most 10% of turnover

Details for shops: Poland's accessibility act.

Where to start

  1. Check whether the organisation is a public body under Article 2.
  2. Test the website automatically – our free one-page check shows WCAG 2.2 A/AA issues that can be detected automatically; weekly monitoring covers the whole site.
  3. Add manual testing – keyboard, screen reader, forms, PDF documents. Automated tools detect only part of the issues.
  4. Compare the accessibility statement with the results and Article 10, and update it by 31 March.
  5. Provide a reporting channel and reply within 7 days.

Our check is an automated check, not a full audit, and it is not legal advice.

Frequently asked questions

Which WCAG applies to public bodies in Poland?

The annex to the act of 4 April 2019 lists the WCAG 2.1 success criteria at levels A and AA. According to gov.pl this corresponds to WCAG 2.1 level AA with minor limitations; a few criteria do not apply to mobile apps.

Who does the digital accessibility act cover?

The public bodies listed in Article 2: among others, public finance sector units, state organisational units without legal personality, certain legal persons financed or controlled by them, and NGOs working in health, for people with disabilities and for older people.

What must the accessibility statement contain?

The items of section 1 of the EU model (Decision 2018/1523) plus, among others, the publication and update dates, how accessibility was assessed, contact details, information on the physical accessibility of the premises and sign language interpreting, and a link to the Ombudsman.

What are the fines for lacking digital accessibility?

Up to PLN 10,000 for unjustified and persistent failure to ensure accessibility, and up to PLN 5,000 for a missing statement or missing required items. The minister responsible for digitisation imposes them by decision, after successive monitoring rounds.

Can a public body assess its own website?

Yes. According to the FAQ on gov.pl, a public body may test the accessibility of its own website, but should make sure the test is of good quality. The statement says how the assessment was done.

How does this act differ from the act on products and services?

The 2019 act covers websites and apps of public bodies. The 2024 act (Journal of Laws 2024 item 731) implements the European Accessibility Act and covers businesses that provide certain services to consumers, such as online shops.

Sources