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Accessibility (EAA) in Slovakia: online shops, microenterprises, products and fines

Methodology: Marek Galetka, founder of Pravano. English translation of our Slovak article, which a person approved before publication; every number, date and legal reference of the translation is checked automatically against the original.

Cross-checked as of 10 September 2026 · based on primary sources

Updated 10 September 2026. Based on Act No. 351/2022 Coll., Government Regulation No. 89/2026 Coll. and Act No. 56/2018 Coll.. An informative readiness check, not a legal service or an official audit. Original: slovenská verzia.

The European Accessibility Act (Directive (EU) 2019/882, EAA) has two layers in Slovakia. Services are governed by Act No. 351/2022 Coll. on the Accessibility of Products and Services for Persons with Disabilities, in effect since 28 June 2025. Products are governed by Government Regulation No. 89/2026 Coll., in effect since 30 May 2026. The difference between them decides, above all, whether the exemption for microenterprises applies to you.

Services: whom Act No. 351/2022 Coll. concerns

The act covers services provided to consumers, including information society services (Section 2(1)(d), with reference to Section 2(a) of Act No. 22/2004 Coll. on Electronic Commerce), i.e. an online shop too, as well as passenger transport, financial services and e-books. It does not apply to services provided by microenterprises (Section 2(3); microenterprise as defined in Recommendation 2003/361/EC).

Transitional provisions (Section 12): a service provided under a contract concluded by 28 June 2025 is not subject to the requirements until the contract ends, but no later than 28 June 2030; the only website and app content exempted is pre-recorded time-based media and office file formats published before 28 June 2025 and archives that are not updated or edited after that day (Section 12(2)); other content, even older content, is not exempt. The requirements apply only to the extent that they do not lead to a fundamental alteration of the service or to a disproportionate burden; the provider must keep the assessment for 5 years and notify it to the supervisory authority (Section 7).

Supervision of services and fines

The authority supervising the accessibility of services is the Slovak Trade Inspection (SOI) (Section 8(1)), which checks compliance with the requirements, investigates complaints and decides on administrative offences. Fines (Section 10(2)): from €200 to 3% of turnover for the previous accounting period, up to €6,000 for failing to ensure accessibility or to make information available, up to €20,000 for failing to introduce procedures, to inform the supervisory authority or to take corrective measures, and up to €30,000 for failing to cooperate. For failing to ensure accessibility and to introduce procedures, the supervisory authority refrains from imposing a fine if the provider takes corrective measures or demonstrates a disproportionate burden or a fundamental alteration (Section 10(3)).

Products: Government Regulation No. 89/2026 Coll.

Act No. 351/2022 Coll. governs the accessibility of services; the accessibility requirements for products are laid down by Government Regulation No. 89/2026 Coll. of the Slovak Republic (in effect since 30 May 2026, replacing Government Regulation No. 282/2023 Coll.), issued under Act No. 56/2018 Coll. on Conformity Assessment of Products and Making Specified Products Available on the Market. It applies to specified products (Section 1(2)): consumer general-purpose computer hardware systems and their operating systems; self-service terminals (payment terminals, ATMs, ticketing machines, check-in machines and interactive self-service information terminals, except those installed as integrated parts of vehicles, aircraft, ships or rolling stock); consumer terminal equipment with interactive computing capability used for electronic communications services and for access to audiovisual media services; e-readers.

The manufacturer, authorised representative, importer and distributor fulfil their obligations under the regulation and Act No. 56/2018 Coll.: conformity assessment (internal production control and technical documentation), the EU declaration of conformity (Section 23), CE marking (Section 25), keeping documentation and information on suppliers and customers for 5 years, corrective measures and withdrawal from the market in case of non-compliance. The specific requirements are in Annexes 1 (general) and 2 (specific) and in the functional performance criteria. The application of the requirements is limited by a fundamental alteration of the nature of the product and by a disproportionate burden (Section 14; the assessment is kept for 5 years). Self-service terminals used before 28 June 2025 may continue to be used until the end of their economic life, but for no longer than 20 years. Supervision of making specified products available is carried out by the Slovak Trade Inspection (Section 9 of Act No. 351/2022 Coll. in conjunction with Section 26 of Act No. 56/2018 Coll.).

Microenterprises: services yes, products no

This is the most common mistake. A microenterprise providing services is exempt from the EAA in Slovakia (Section 2(3) of Act No. 351/2022 Coll.). A microenterprise as a manufacturer of specified products is not exempt; it only has the relief of not having to document the assessment of disproportionate burden.

This article is a general explanation, not individual legal advice. A specific overview for your company (Pravano Kompas) comes with the free check – in writing, within 2 working days.