The fine can reach €100,000. That is what Article 26 of Greek Law 4994/2022 provides. This is the law through which Greece transposed Directive (EU) 2019/882, better known as the European Accessibility Act. The obligation has applied since 28 June 2025. It is already in force today.
On top of the fine, the authorities can issue a compliance order, suspend the service and publish the non-compliance.
Below you will find who the law applies to, who it does not apply to, exactly what it requires technically and what you can do this week.
Which businesses it applies to
The law covers specific categories of digital services aimed at consumers. A website alone does not automatically fall within it:
| Category | Examples |
|---|---|
| E-commerce | E-shops, marketplaces, online bookings with payment |
| Banking & financial services | E-banking, insurance platforms, investment services |
| Electronic communications | Phone and internet providers, messaging services |
| Transport | Ticketing, timetable and route information |
| E-books | E-books and related reading software |
| Audiovisual media | Services that give access to audiovisual content |
For products, the law also covers payment terminals, ATMs, self-service machines, computers, smartphones and e-readers.
Who it does NOT apply to
- Microenterprises that provide services: fewer than 10 employees and annual turnover or balance sheet total of up to €2 million. Note: the exemption covers services. It does not cover placing products on the market.
- Purely informational sites with no commercial function — a company brochure site with no basket, bookings or transactions does not automatically fall within scope.
- Third-party content that is neither funded nor controlled by the service provider.
If you run an e-shop, even a small one, check the microenterprise criteria before assuming you are exempt. Both criteria must be met at the same time.
What the law requires technically
This is where the most common mistake is made. Law 4994/2022 does not name WCAG. It provides a presumption of conformity when the harmonised European standard EN 301 549 is applied, and that standard incorporates WCAG 2.1 at level AA.
In practice: aim for WCAG 2.1 AA. WCAG 2.2 is newer and we recommend it, although it is not required. WCAG 2.0 is now outdated as a reference.
Do not confuse two separate regimes: Law 4727/2020 requires WCAG 2.1 AA for the public sector. Law 4994/2022 is the one that applies to private businesses.
What an accessible site means in practice
- Keyboard navigation across the whole site — without a mouse and with a visible focus indicator.
- Alternative text on every image that carries information.
- Colour contrast of at least 4.5:1 for normal text.
- Correct heading structure (H1 → H2 → H3, with no skipped levels) and semantic HTML.
- Forms with labels and clear error messages.
- Captions on videos.
- Compatibility with screen readers — NVDA, JAWS, VoiceOver.
- Works at 200% zoom with no loss of content.
- No auto-moving elements that cannot be stopped.
- An Accessibility Statement published on the site.
An overlay widget will not make you compliant. “Accessibility toolbar” plugins that add an icon with font enlargement do not fix the structure of the code and are not recognised as compliance. In several countries they have even been the subject of lawsuits.
Who enforces it and how
Oversight lies mainly with the Greek Ministry of Digital Governance, working with the General Secretariat for Consumer Affairs. The inspection procedure has not yet been fully clarified in practice — and that is exactly why many businesses keep putting it off.
In practice, the first inspections are usually triggered by a complaint: a user who cannot complete an order files a report. No authority has to pick you at random.
What you can do this week
| Step | What it involves | Time |
|---|---|---|
| 1. Quick self-check | Try to complete an order using only the keyboard. If you get stuck, you already have your answer. | 30 minutes |
| 2. Automated check | Run the page through an accessibility testing tool. It will catch 30-40% of the issues. | 1 hour |
| 3. Expert review | The remaining 60-70% (navigation, structure, screen readers) need manual testing. | — |
| 4. Compliance plan | Prioritise: purchase journeys first, then the rest of the site. | — |
| 5. Accessibility Statement | Publish it on the site with your level of conformity and contact channels. | — |
How we can help
At WebMate we build websites and e-shops to the WCAG 2.1 AA standard — both for businesses that must comply with Law 4994/2022 and for those taking part in NSRF (ESPA) co-funded programmes, the EU-funded Greek grant schemes where accessibility for people with disabilities is a requirement.
We build accessibility in from the design stage onwards. If you already have a site or e-shop, we start with an audit and give you a written picture of what is needed and what it will cost.
More details: Website development · E-shop development
Frequently asked questions
What is the fine if my website is not accessible?
Article 26 of Greek Law 4994/2022 provides for administrative fines of up to €100,000. On top of the fine, the authorities can issue a compliance order, suspend the service and publish the non-compliance. The amount is scaled according to the seriousness and duration of the breach, the number of people affected and any repeat offence.
Which businesses does the law apply to?
Mainly those that provide digital services to consumers: e-shops and e-commerce, banking and financial services, electronic communications, e-books, transport services with ticketing, and services giving access to audiovisual media. A purely informational company site with no commercial function does not automatically fall within scope.
Are microenterprises exempt?
Service providers that are microenterprises, meaning they employ fewer than 10 people AND have an annual turnover or balance sheet total of up to €2 million, are exempt from the accessibility obligations for services. The exemption covers services and does not extend to economic operators that place products on the market.
Which standard should I follow?
The law does not explicitly name WCAG. It provides a presumption of conformity when the harmonised European standard EN 301 549 is applied, and that standard incorporates WCAG 2.1 at level AA. In practice, WCAG 2.1 AA is the reference standard. WCAG 2.2 is newer and recommended, although it is not required.
My site has been live since before 2025. Do I have some leeway?
The law provides a transition period for services that were already lawfully provided before 28/6/2025. The provision is not interpreted uniformly and should not be treated as a general extension for all existing sites, especially when a site undergoes a substantial redesign. For your own case, seek legal advice.
What is an Accessibility Statement?
It is the text published on your site describing its level of conformity, any non-accessible content, alternative contact methods and how to submit a complaint. It is the first thing that will be requested in an inspection, and it is usually also required in the documentation for grant-funded projects.
Do I need accessibility for NSRF (ESPA) funding?
Grant-funded digital projects under NSRF (ESPA), the EU-funded Greek grant programmes, require accessibility for people with disabilities at level AA, along with supporting documentation. The exact wording and the version of the standard vary by call: older calls refer to WCAG 2.0 AA and newer ones to WCAG 2.1 AA. Always check the text of the specific call that applies to you.
How much does it cost to make my site accessible?
It depends on whether we are fixing an existing site or building a new one. In a new build, accessibility is part of the design and the extra cost is small. On an existing site, the cost depends on how deep the issues go in the theme, the structure and the content. We always start with an audit and give you a written quote.
This article is for general information and does not constitute legal advice. For whether and how Law 4994/2022 applies to you, consult a legal adviser.
Sources: Law 4994/2022 (Greek Government Gazette FEK A 215/18.11.2022), Directive (EU) 2019/882, standard EN 301 549, WCAG 2.1 (W3C). Last updated: July 2026.
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