WCAG 2.2 Accessibility: What Finnish Businesses Must Do
WCAG 2.2 and the European Accessibility Act — Practical Guide
The European Accessibility Act (EAA) came into force on 28 June 2025. In Finland it's implemented via the Act on Accessibility (saavutettavuuslaki). Many SME owners assume it only affects government sites — that's no longer true.
Who Must Comply
The EAA covers private businesses that:
- Sell to consumers through digital channels (e-commerce)
- Provide banking, payment, or transport services online
- Have 10+ employees or €2M+ annual turnover (micro-enterprises are mostly exempt)
If you run an online store, booking system, or any consumer-facing digital service in Finland and you're not a micro-business, you're in scope.
Public sector sites have been required to comply since 2019 under the older Digital Services Act.
What WCAG 2.2 Actually Requires
WCAG (Web Content Accessibility Guidelines) 2.2 Level AA is the legal benchmark. The 9 new success criteria added in 2.2:
- Focus Not Obscured (Minimum) — keyboard focus must be at least partially visible
- Focus Appearance — focus indicators must have sufficient contrast
- Dragging Movements — alternative to drag for any draggable interface
- Target Size (Minimum) — touch targets ≥ 24×24 CSS pixels
- Consistent Help — help links in the same place across pages
- Redundant Entry — don't ask for the same info twice in a flow
- Accessible Authentication (Minimum) — no cognitive function tests for login
- Accessible Authentication (Enhanced) — no exceptions for cognitive tests
- Focus Not Obscured (Enhanced) — focus fully visible
On top of all WCAG 2.1 requirements: color contrast, alt text, keyboard navigation, ARIA labels, semantic HTML, form labels, etc.
Fines for Non-Compliance
In Finland, supervised by Etelä-Suomen aluehallintovirasto (AVI). Penalties scale with company size and harm:
- Warnings and orders to comply for first violations
- Conditional fines (uhkasakko): €1,000–€50,000+ per failure
- Damages claims from affected users
- Reputational damage: AVI publishes non-compliance findings
The bigger risk isn't the fine — it's being publicly named as the company that excluded disabled users. And it's losing the 10–15% of customers who have some form of accessibility need.
The Practical Audit Checklist (1 Hour)
Do this on your own site right now:
- Tab through the entire homepage with keyboard only. Can you reach every link, button, form field? Is the focus visible at every stop?
- Run WAVE or axe DevTools (free browser extensions). Fix every error and most warnings.
- Check color contrast on body text, links, buttons. Use the WebAIM Contrast Checker. Body text needs 4.5:1; large text 3:1.
- Add alt text to every image. Decorative images get `alt=""`. Informative images get meaningful descriptions.
- Label every form field. Visible labels are better than placeholder-only.
- Add `lang="fi"` to the html element (or correct language).
- Test with a screen reader. macOS VoiceOver (Cmd+F5) or Windows Narrator. Listen to your homepage being read.
- Check tap targets on mobile. Buttons under 24×24px (or 44×44px ideally) are too small.
- Publish an accessibility statement (saavutettavuusseloste). Required by law. Template at saavutettavuusvaatimukset.fi.
Quick Wins by Tech Stack
WordPress:
- Use accessibility-ready themes (filter in the theme directory)
- Plugins to avoid: most page builders create accessibility issues by default
- Install "Accessibility Checker" plugin to flag issues
Shopify:
- Use a Polaris-based theme (Dawn, Sense, Refresh)
- Check the Accessibility apps in the App Store
- Test the checkout flow specifically — that's where issues hide
Custom React/Next.js:
- Use semantic HTML, not div-everywhere
- React-Aria, Radix UI, or Headless UI for accessible components
- Run axe-core in your CI/CD pipeline
- Test with jest-axe in unit tests
What's NOT a Real Solution
- "Accessibility overlays" (UserWay, AccessiBe). These widgets claim to fix accessibility automatically. They don't — and have been the subject of lawsuits for misleading claims. Build accessibility into your site, don't bolt it on.
- "We'll fix it if someone complains." EAA requires proactive compliance, not reactive.
When to Hire Help
For a 10–20 page site, an accessibility audit costs €500–€1,500. Remediation work €1,000–€5,000 depending on issues found. Annual re-audit €300–€500. Cheaper than one fine.
If you're under EAA scope and haven't audited yet, do the 1-hour self-audit this week. Most issues can be fixed in a day. The longer you wait, the more it costs to retrofit.
Published · Bluefour-tiimi
Bluefour – Helsinki digital agency | hello@bluefour.fi | +358 45 850 4236