The European Accessibility Act in Slovenia: who is in scope and what it requires

ZDPSI sets accessibility requirements for a defined list of products and services, the obligations of economic operators, and the competent supervisory bodies. It has applied since 28 June 2025.

Keep it distinct from the older instrument: ZDPSI addresses economic operators, while the Act on the Accessibility of Websites and Mobile Applications (ZDSMA) has bound the public sector since 2018. An organisation may fall under either or both.

The act covers a specific list, not every website. On the services side this includes e-commerce, consumer banking services, e-books, electronic communications services, access to audiovisual media services and certain passenger transport services.

In practice: if consumers conclude contracts through your site, you are likely in scope. A brochure site with no purchase or contract path is generally not an e-commerce service in itself. Verify scope against the statutory text for your specific activity.

Microenterprises providing services are exempt. A microenterprise employs fewer than 10 people and has annual turnover or a balance sheet total not exceeding EUR 2 million. The exemption is permanent, not a transition period.

Two common misreadings. Both tests apply — headcount and the financial threshold. And the exemption is framed for services; the treatment of products is not identical. If you are near the threshold, the obligation follows the change in status.

Service providers may continue using products lawfully used to provide similar services before the act took effect until 28 June 2030. Contracts concluded before it took effect may run to expiry, and at most five years from the date of application. These concern existing equipment and contracts — they are not a general deferral for a new or redesigned site.

The act states functional accessibility requirements rather than one technical specification. In practice conformity is demonstrated through the harmonised standard EN 301 549, which for web content incorporates WCAG 2.1 at level AA.

The recurring barriers are recognisable: insufficient text contrast, form fields without an associated label, content reachable only by mouse, images without meaningful alternative text, broken heading hierarchy, and focus that is invisible during keyboard navigation. For online shops the critical paths are checkout, sign-in and every step where a contract is concluded.

Supervision is carried out by the competent inspection bodies; depending on the product or service these include the Market Inspectorate of the Republic of Slovenia and the Inspectorate for Information Society. Check the applicable authority and penalties for your activity directly against the ZDPSI text, as the allocation differs by product and service type.

This is the paragraph that matters most, because it is where expectations usually go wrong. Automated accessibility testing reliably finds a subset of problems: missing alternative text, contrast ratios, missing field labels, duplicate identifiers, document language, structural errors. That subset is measurable, repeatable and evidenced.

Automated testing cannot judge whether alternative text is meaningful, whether the keyboard order is logical, whether an error message is understandable, whether a video is properly captioned, or whether checkout actually works with a screen reader. That requires manual review and testing with assistive technology.

So no automated review — including ours — is a WCAG conformance certificate. It is useful as an evidenced starting point: what was measured, what could not be verified, and where the risk concentrates. A report that renders an unmeasured item as zero, or as a pass, leaves you worse off than having no report at all.

Establish whether you are in scope and under which instrument. Measure the current state and document it with evidence bound to an exact version of the page. Then sequence the fixes — first whatever blocks concluding a contract or signing in, because that is where legal and commercial exposure concentrates.

After the fixes, repeat the measurement against the same scope and the same device profile so the comparison holds. A change without a baseline is not proof of improvement. See the sample report for how evidence is bound to a specific finding.