Law 4994/2022 (the Law) transposes into the Greek legal order Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services (European Accessibility Act). The objective of this Directive is to enhance the accessibility of products and services for persons with disabilities.
The provisions of the Law shall enter into force on 28 June 2025. On 28 May 2025, a draft bill was submitted for public consultation, proposing amendments to Law 4994/2022 through the addition of new provisions. These aim to:
- prevent the misuse of accessibility requirements as grounds for prohibiting the placement of products and services on the market, and
- reinforce consumer protection for persons with disabilities.
Law 4994/2022 applies to all businesses operating within the EU, excluding microenterprises employing fewer than ten (10) persons. It establishes specific obligations for manufacturers, authorized representatives, importers, distributors, and service providers. The Law also designates a competent market surveillance authority responsible for overseeing compliance by the aforementioned persons.
Obligations of Manufacturers (Article 7):
Manufacturers are required to:
- Ensure that products are designed and manufactured in compliance with applicable accessibility requirements;
- Compile a technical documentation file;
- Conduct a conformity assessment procedure;
- Draft an EU Declaration of Conformity;
- Affix the “CE” marking on the product;
- Indicate the manufacturer’s name, registered trade name or trademark, and contact address on the product, or where not feasible, on its packaging or accompanying documentation;
- Provide contact information in Greek, in braille or other accessible formats;
- Supply user instructions and safety information in Greek.
Obligations of Importers (Article 9):
Before placing a product on the market, importers must verify that the manufacturer has fulfilled the following obligations:
- Carried out a conformity assessment procedure;
- Compiled the technical documentation;
- Affixed the “CE” marking;
- Included all required documents
- Not distribute in the market a product that does not comply with the requirements of the Law.
Importers also indicate their name, registered trade name or trademark, and contact address on the product, or, where not feasible, on its packaging or accompanying documentation and provide contact information in Greek, in braille or other accessible formats.
Obligations of Distributors (Article 10):
Distributors must act with due diligence concerning the applicable requirements in order to comply with the Law. Prior to making a product available on the market, they must ensure that:
- The CE marking is affixed;
- The required documents, instructions, and safety information in Greek are attached;
- The manufacturer and importer have fulfilled their respective obligations under Articles 7 and 9.
Both distributors and importers shall ensure that, for as long as they are responsible for a product, the conditions of storage or transport do not compromise its compliance with the applicable accessibility requirements. Also, distributors are obligated to provide to the competent authority all documentation and information required for demonstrating their compliance with the obligations under the Law.
Obligations of Service Providers (Article 13):
Service providers must:
- Design and deliver services in accordance with the accessibility requirements set forth in the Law;
- Prepare and disclose information required by Law, including a declaration of conformity for their services;
- Make such information publicly available in written and oral form, including in accessible formats for persons with disabilities.
In the event of non-compliance, manufacturers, importers, distributors, and service providers must take appropriate corrective actions to bring their services into conformity and must cooperate with the competent authority by supplying all necessary documentation requested to verify compliance.
If the market surveillance authority has sufficient grounds to believe that a product does not conform to applicable accessibility requirements, it may initiate an evaluation of the product.
Accessibility of Electronic Services:
Providers of electronic services must comply with the Web Content Accessibility Guidelines (WCAG). Digital interfaces, including websites, must ensure user accessibility at both the visual and structural levels—for example, supporting navigation without a mouse, voice-controlled interactions, and enabling interbank transactions via screen readers and voice commands.
Achieving full accessibility also necessitates:
- Structural adjustments to digital applications;
- Ongoing training of company personnel on accessibility needs;
- Regular internal audits by businesses to ensure compliance and continuous improvement.
Legal Sanctions (Article 26):
Member States are required to establish administrative penalties that are effective, proportionate, and dissuasive.
The market surveillance authority, among other penalties, may:
- Recommend corrective measures;
- Impose temporary detention of the product;
- Prohibit the placing of the product on the market.
The draft bill currently under consultation introduces provisions for:
- The right to file an appeal against the imposition of penalties before the hierarchically superior authority of the imposing body, within thirty (30) days from the date of notification;
- The right for collective legal action by associations entitled to represent persons with disabilities, and by public bodies tasked with protecting their collective interests or ensuring compliance with the present Law.
