Accessibility laws · Denmark

Denmark: Web Accessibility Act and the EAA

Denmark's own national audit office went and checked. It found that 61% of the ministerial and regional homepages it examined failed at least one of the accessibility requirements it tested, and it published that on 15 April 2024, three and a half years after the last deadline for existing sites went by. It also called the regulator's supervision not entirely satisfactory, because the agency had never followed up on whether its own orders were being obeyed. That gap has since closed. A follow-up in January 2026 records new procedures from the start of 2025. All 23 orders it reviewed had been chased. Denmark runs one of Europe's most digitised public sectors, which is why an audit like that lands harder there than it would elsewhere.

Via EN 301 549 V3.2.1: 2.1 AA
Web Accessibility Act: 2018
Statement review cycle: Annual
EAA application date: Jun 2025

What the law is

The Act is Lov om tilgængelighed af offentlige organers websteder og mobilapplikationer, which everyone shortens to webtilgængelighedsloven, and it transposed the EU Web Accessibility Directive into Danish law. It entered into force on 23 September 2018 and phased in from there. Websites published after that date had to comply by 23 September 2019, websites published before it had until 23 September 2020, and mobile applications had until 23 June 2021. Reading the Act alone will not tell you the technical standard, because it is not in there. Section 3 requires that sites be made perceivable, operable, understandable, and robust, and then hands the Minister the job of naming a standard that satisfies those four words. That standard arrives through a separate executive order from November 2021, which names EN 301 549 v.3.2.1 from March 2021, the edition that carries WCAG 2.1. No edition referencing WCAG 2.2 has been published yet, so v3.2.1 is still what the Danish order points at.

The stakes here come from how Danes actually deal with their government. Digital Post became mandatory for businesses in 2013 and for residents aged 15 and over with a permanent address in Denmark in 2014. An exemption is available on application for people who cannot communicate digitally, and at the start of 2026 the agency put that at 4.7% exempt against 95.2% registered. So roughly nineteen in twenty are set up to receive official mail digitally. That is not the same as saying no other route exists. The exemption and ordinary paper post both do. In 2025, 82% of people aged 15 and over used a public digital service at least once a week. Set against that, the national audit office noted that roughly 20% of Denmark's adult population faces challenges in the digital society. An inaccessible Danish public service is rarely one option beside a phone line. It is the only door there is.

The private-sector half has its own Act and its own regulator, and our page used to name neither. The European Accessibility Act came into Danish law as Lov om tilgængelighedskrav for produkter og tjenester. The Folketing passed it on 17 May 2022 and it entered into force on 28 June 2022. Its accessibility requirements bite on products and services placed on the market from 28 June 2025. Sikkerhedsstyrelsen, the Danish Safety Technology Authority, supervises it and can issue orders and fines. It reaches e-commerce, consumer banking, passenger transport, and e-books, and it also reaches self-service terminals, meaning payment terminals, ATMs, ticketing machines, check-in machines, and interactive information screens. In a country built on self-service, that last category is the sharp end.

This applies to you if…

You are a Danish public body, and the definition goes further than the three obvious tiers. State, regional, and municipal authorities are in. So is any body governed by public law, which the Act defines by the familiar procurement test. It was set up specifically to meet a need in the general interest that is not industrial or commercial. It has legal personality. And it is more than half financed by public authorities, or under their management control, or has more than half its board appointed by them. Plenty of organisations that would never call themselves government land inside that.
You think you are outside it, and you might be. The Act excludes schools and education institutions in the Ministry of Education's area that are not part of the public administration, though they still owe accessibility on content tied to essential administrative online functions. It excludes private daycare institutions on the same terms, meaning content tied to essential administrative online functions stays in. It excludes television and radio bodies with a public service obligation, and NGOs that neither provide services essential to the public nor services aimed specifically at people with disabilities. And it does not apply to the Faroe Islands or Greenland, though it can be brought into force there by royal decree with local modifications.
You sell EAA-covered products or services to Danish consumers, wherever your company is based. Service providers that count as microenterprises are exempt from the service accessibility requirements and the compliance obligations that go with them, which is a real carve-out for a small Danish business and one most guides skip.
You supply digital services into Danish public procurement, where the buying body's own duty tends to reach you as a contract clause long before any regulator does.

What it technically requires

Satisfy the four principles the Act actually states, and use the standard as the shortest route there. Perceivable, operable, understandable, and robust is the legal requirement. Conforming to EN 301 549 V3.2.1 gives you a presumption of conformity with it, which in practice means WCAG 2.1 Level AA. That distinction is not academic. It means an argument about whether your site is perceivable is available where the standard is silent, and it means the version pinned in the executive order is the version you are measured against.
Denmark pins the version by name, and that cuts both ways. The executive order from November 2021 names EN 301 549 V3.2.1 from March 2021, so your bar is fixed rather than floating. It does not follow the European reference on its own. Somebody has to issue a new order first, which is the opposite of how the Dutch and Spanish rules work, and it is why Danish public bodies and Dutch ones can end up on different editions of the same standard. A revision carrying the web clauses up to WCAG 2.2 is drafted and working through ETSI's process, with no published version number and no date behind it, so nobody can tell you when a Danish order would follow. Treat that as a grace period you did not ask for rather than as a reason to wait.
Publish an accessibility statement that is detailed, exhaustive, and clear, in an accessible format, and update it at least once a year. Denmark files these centrally through the agency's WAS-Tool, which was built to match the European Commission's model statement, and every statement gets a predictable public address of its own. A mobile app's statement can live where the app is downloaded rather than on your website.
Build the feedback mechanism to Denmark's specification, because it is unusually precise about it. The statement carries telephone contact details so any citizen can reach you by voice, and written contact details so any citizen can reach you in writing. The written route must not sit behind a MitID login, and it must not use inaccessible verification like a CAPTCHA. The recommended response time is 10 working days. If you do not answer properly, the person can escalate to the agency, which feeds those approaches straight into its monitoring.
Claim the disproportionate burden only where it holds, and declare it when you do. The Act weighs your size, resources, and nature first. Then it weighs the costs and benefits to you against the benefits for people with disabilities, taking into account how often and for how long that specific site or app is used. Where you do decline, the accessibility statement has to say which parts of the requirements you could not meet and, where possible, point to an accessible alternative. The regulator supervises whether you were entitled to invoke it at all, so this is a claim somebody checks.
Know which content the Act leaves out, because the list is long and specific. Document formats published before 23 September 2018, unless the content is needed for active administrative processes. Prerecorded video published before 23 September 2020. Live video. Online maps, where the essential information is given accessibly for maps meant for navigation. Third-party content you neither financed nor developed nor control. Reproductions of heritage items that cannot be made accessible without harming conservation or authenticity. Intranet and extranet content published before 23 September 2019, until the site is substantially revised. And archive content neither updated nor edited after 23 September 2019.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

This law expects a published accessibility statement, and regulators check for it first. Generate yours free →

How it is enforced

Digitaliseringsstyrelsen, Denmark's Agency for Digital Government, monitors and supervises, and its powers are stronger than a naming exercise. It can require you to give it access to every solution sitting behind a login. It can order you to make specific content accessible, to produce an adequate and updated accessibility statement, or to point to a specific accessible alternative. It exercises that supervision in full independence, and its supervisory decisions cannot be appealed to any other administrative authority. It also checks whether a body claiming disproportionate burden was entitled to.

Monitoring runs on a published cadence rather than on complaints alone. The agency has supervised covered mobile applications since 23 June 2021, and describes its cadence as four apps in 2021 and twelve a year after that. That is the plan it published rather than a count of finished work we were able to check. Complaints that come in through a body's own feedback channel feed the same process, which is part of why the feedback rules are written so tightly.

The national audit office measured all of it and was blunt. Rigsrevisionen's report landed on 15 April 2024. It found that 61% of the homepages it examined across ministries and regions failed one or more of the accessibility requirements it checked. It also found that some ministries and regions had still not published accessibility statements for all their websites as of March 2024. It rated the agency's supervision not entirely satisfactory, specifically because the agency had not followed up on whether its own orders were being complied with. It did credit the supervision for meeting the requirements on sample size, composition, and involving the people affected, while saying every public website should stand a chance of being selected.

The EAA side answers to somebody else, and it is not one somebody. That Act sits under the business ministry, and the market surveillance work that used to carry the Sikkerhedsstyrelsen name moved into Erhvervsstyrelsen at the start of 2026. Digitaliseringsstyrelsen keeps two slices of it, covering consumer terminal equipment used to reach audiovisual media services and electronic communications services, and the transport regulators take their own. So the first question is which of them your product belongs to. The penalty provision is section 57. It is a criminal one. It sets fines for a listed set of breaches, and companies carry criminal liability under the general rules. What it does not do is print a kroner figure, so nobody can quote you a Danish maximum. The control authorities cannot fine you themselves either. They order a correction and, if that fails, hand the matter to the police. No enforcement action under the Danish EAA Act since 28 June 2025 turned up in what we read, and we did not search every register.

Key dates

Sep 23, 2019New public sector websites in scope
Sep 23, 2020All public sector websites in scope
Jun 23, 2021Public sector mobile apps in scope
Jun 28, 2025European Accessibility Act applies to covered private services

What to do about it

Every obligation on this page is measured against WCAG, so the first step is knowing where you actually stand. Run the free 10-page scan for the machine-checkable slice. For the rest, we review the key journeys with an expert and a real blind screen-reader user, then attach a screenshot and a fix to every finding. $499, 5 business days.

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This law does not set the web requirement itself. It points at EN 301 549, the European accessibility standard, and that is where the requirement actually lives. Clause 9 of the standard carries WCAG 2.1 Level AA, so a site that already meets Level AA has met the web part of it. The rest of the standard covers ground WCAG never touches, including hardware, two-way voice, documents that are not web pages, and the support channels a customer reaches once the site has already failed them. Several countries adopt the standard under their own national designation, which carries the same requirements under a different name.

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.