On 28 June 2025, the provisions of Law No. 232/2022 on accessibility requirements for products and services (“Law 232/2022”) will come into force. Law 232/2022 aims to establish accessibility requirements for products placed on the market and services provided to consumers after 28 June 2025, in order to maximise their predictable use by persons with disabilities.
Law 232/2022, published in the Official Gazette of Romania on 25 June 2022, transposes into Romanian law the provisions of Directive (EU) 2019/882 on accessibility requirements for products and services.
Scope of Application
Products Covered. The products subject to Law 232/2022 include: ►general-purpose hardware systems intended for consumers (g., personal computers, laptops, smartphones, tablets) and operating systems for them; ►terminal equipment intended for consumers, having interactive computing capabilities, used for electronic communications services or for access to audiovisual media services; ►e-readers; ►self-service payment terminals, including ATMs, ticket machines, check-in machines, interactive self-service terminals providing information (excluding terminals installed as an integral part of vehicles, aircraft, ships or rolling stock).
Services Covered. Law 232/2022 applies to the following services provided to consumers: ►electronic communications services (except transmission services used for the provision of services between devices, such as machine-to-machine); ►services providing access to audiovisual media services; ►banking services for consumers; ►electronic books and dedicated software; ►e-commerce services.
E-commerce services are defined as services provided remotely, via websites, and services integrated into mobile devices, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract.
In addition, Law 232/2022 also applies to the following elements of air, rail, maritime, and bus passenger transport services (except for urban, suburban, and regional transport services, to which only self-service terminals apply): ►websites; ►integrated services on mobile devices, including mobile applications; ►electronic tickets and electronic ticketing services; ►providing information about the transport service, including real-time travel information; ►interactive self-service terminals, except those installed as an integral part of vehicles, aircraft, ships or rolling stock, used in the provision of any part of such passenger transport services.
Exceptions to Application. Law 232/2022 does not apply to certain content on websites and mobile applications, such as: ►media content with pre-recorded time dimension, published before 28 June 2025; ►file formats associated with office activities, published before 28 June 2025; ►maps and online mapping services, if the essential information is provided in a digital format accessible for navigation maps; ►content belonging to third parties that is not financed, developed, or controlled by the economic operator in question; ►the content of websites and mobile applications that can be classified as archives (containing only content that has not been updated or edited after 28 June 2025).
Also, micro-enterprises that offer services are exempt from having to meet accessibility requirements for urban, suburban, and regional transport services.
Accessibility Requirements
Law 232/2022 requires economic operators (i.e., the manufacturer, authorised representative, importer, distributor or service provider) to place on the market only products and provide only services that comply with the accessibility requirements detailed in its Annex No 1.
I. Accessibility Requirements for Products
General Requirements for Products. Products should be designed and manufactured to maximise their foreseeable use by persons with disabilities. Information on the use of the product (e.g., labelling, instructions, warning messages) provided on the product itself should be: ►available through multiple sensory channels; ►easy to understand; ►presented to users in ways they can perceive; ►presented in characters of adequate size and type, taking into account foreseeable conditions of use and using sufficient contrast and adjustable spacing between letters, lines, and paragraphs.
If they cannot be provided on the product itself, the instructions for use must be made available through the use of the product or by other means (e.g., website) and, in addition to the above, must be: ►in text formats that allow the generation of other assistive formats; ►accompanied by an alternative presentation for non-text content.
Requirements for User Interface and Product Functionality. Products must provide features, elements, and functions that enable persons with disabilities to access, perceive, use, understand, and control the product. Examples include: ►alternatives to visual, auditory, vocal, and tactile elements; ►flexible image enlargement, brightness, and contrast adjustment functions; ►alternatives to colours or sound signals that convey information; ►flexible methods for improving visual clarity; ►user-adjustable volume and speed functions, as well as amplified audio features, including reduction of interference from audio signals from surrounding products and audio clarity; ►avoidance of operating modes that require a wide range of motion, high force, or simultaneous commands; ►avoidance of triggering photosensitive seizures; ►protection of the privacy of users who use accessibility features; ►alternatives to biometric identification and control; ►provision of software and hardware for creating interfaces with assistive technologies.
Specific Requirements for Certain Products: ►self-service terminals: text-to-speech synthesis technology; allow the use of personal audio headsets; multi-sensory warnings for response intervals; possibility of extending the time allocated; adequate contrast, easily distinguishable tactile keys/buttons; no prior activation of an accessibility feature is required for the user to use it when needed; if the product uses audio signals, it must be compatible with EU assistive devices and technologies (g., hearing aids, hearing loops, cochlear implants, and other listening devices); ►e-readers: equipped with text-to-speech synthesis technology; ►interactive terminal equipment for electronic communications: real-time text processing, compatibility with high-fidelity audio systems, use of full conversation (synchronized voice, text, video), efficient wireless connection with assistive technologies, avoidance of interference with assistive devices; ►terminal equipment for accessing audiovisual media services: accessibility components for access, selection, control, and personalisation by the user and for transmission to assistive devices.
II. Accessibility Requirements for Services
General Requirements for Services. Services must be provided by ensuring the accessibility of the products used, providing accessible information about the service and related products; making websites, including related online applications, and mobile device-based services, including mobile applications, accessible; and providing support services (e.g., help centers, call centers, relay services, and training) in accessible modes of communication.
Additional Requirements for Specific Services: ►electronic communications services: provision of real-time text; full conversational option (including video); synchronisation of emergency communications; ►audiovisual media services: accessible electronic programme guides; full and high-quality transmission of accessibility features (subtitles, audio descriptions, sign language); ►air, rail, maritime, and bus passenger transport services (excluding urban, suburban, and regional services): information on the accessibility of vehicles, infrastructure, the built environment, and assistance for persons with disabilities; information on intelligent ticketing services; ►urban, suburban, and regional transport services: ensuring the accessibility of self-service terminals used for the provision of the service; ►banking services: identification methods, electronic signatures, security, and payment services that are perceivable, usable, understandable, and robust; easily understandable information (maximum level B2); ►electronic books: synchronisation of audio content with text; ensuring that digital files do not prevent assistive technologies from functioning; accessibility of content, navigation, and file format; ensuring that content can be rendered in alternative formats and is interoperable with various assistive technologies; metadata for identifying accessibility features; ensuring that digital rights management measures do not block accessibility features; ►e-commerce services: providing information on the accessibility of products and services sold; accessibility of identification, security, and payment functions; providing accessible identification methods, electronic signatures, and payment systems.
In addition, with regard to e-commerce services, Law 232/2022 includes the following indicative and non-binding examples of possible solutions that contribute to compliance with accessibility requirements: ►ensuring that available information on the accessibility features of a product is not removed; ►ensuring that the user interface of payment services is available in voice format so that blind people can shop online independently; ►ensuring that identification dialogues on a screen can be read by screen readers so that blind people can use them.
Obligations of Economic Operators
Law 232/2022 imposes specific obligations on each type of economic operator.
Manufacturers must ensure that products are designed and manufactured in accordance with accessibility requirements. They are also required to draw up technical documentation and an EU declaration of conformity, affix the CE marking, and keep these documents for a period of 5 years after the product has been placed on the market. Manufacturers must ensure the ongoing conformity of series production and indicate on the products the identification elements (e.g., product type, batch or serial number), the name and registered trade name or registered trademark, and the contact details. Instructions and safety information must be in Romanian, clear, and easy to understand. In case of non-compliance, manufacturers must take corrective measures and inform the authorities.
Authorised representatives perform the tasks specified in the mandate received from the manufacturer, excluding obligations relating to the preparation of technical documentation and conformity assessment.
Importers may only place products on the market that comply with accessibility requirements. They must ensure that the manufacturer has carried out the conformity assessment procedure, drawn up the technical documentation, affixed the CE marking, and that the product is accompanied by the necessary documents. If they consider that a product is not compliant, importers must inform the manufacturer and the authorities and refrain from placing the product on the market until it has been brought into conformity. They must keep a copy of the EU declaration of conformity for 5 years.
Distributors must ensure that the products they make available on the market meet accessibility requirements. They check the CE marking, the accompanying documents, and the manufacturer's and importer's compliance with the identification requirements. They must also ensure that storage and transport conditions do not jeopardise the product's compliance with the applicable accessibility requirements and inform the manufacturer, importer, and authorities in the event of non-compliance.
Service providers are responsible for designing and providing services in accordance with accessibility requirements. They must prepare and make available to the public information on how the services meet accessibility requirements, in written and oral form, accessible to persons with disabilities. The information must be kept for as long as the service is available. In the event of non-compliance, they must inform the authorities and take corrective measures.
Exceptions and Disproportionate Burden
Accessibility requirements do not apply to the extent that compliance (i) would require a significant modification of a product/service that would result in a fundamental change in its basic nature, or (ii) would impose a disproportionate burden on economic operators. Economic operators must carry out an assessment to estimate whether compliance with the accessibility requirements would introduce a fundamental change or whether such a burden would arise, based on specific criteria listed in Annexe No. 6 to Law 232/2022.
The assessment of disproportionate burden must take into account: ►the ratio between the net costs of compliance with accessibility requirements and the total costs (operating and capital) of manufacturing, distributing, importing, or providing the product/service; ►the estimated costs and benefits for economic operators in relation to the estimated benefit for persons with disabilities; ►the ratio between the net costs of compliance and the net turnover of the economic operator.
Economic operators are required to keep the results of this assessment for 5 years. The disproportionate burden exception cannot be invoked if the economic operator has received funding (public or private) to improve accessibility. Micro-enterprises are not required to keep the results of the assessment for 5 years, but must provide relevant data for the assessment of the disproportionate burden upon request by the authorities.
Product Conformity and CE Marking
The EU declaration of conformity certifies compliance with the applicable accessibility requirements. It must be kept up to date and translated into Romanian for products placed on the Romanian market. The CE marking must be affixed visibly, legibly, and permanently to the product or its data plate, or, if this is not possible or not justified due to the nature of the product, to the packaging and accompanying documents before the product is placed on the market.
Market Surveillance
Various authorities are designated for market surveillance and conformity checking:
►The National Authority for Consumer Protection (ANPC) – for hardware products, terminal equipment for electronic communication services or those for access to audiovisual media services, e-readers and consumer banking services;
►The Ministry of Economy – for self-service payment terminals, and electronic tickets and electronic ticketing services;
►The National Authority for Management and Regulation in Communications (ANCOM) – for electronic communications services, with the exception of transmission services used for the provision of services between devices (such as machine-to-machine);
►The Authority for the Digitalisation of Romania (ADR) – for e-books and dedicated software, e-commerce services, websites and integrated services on mobile devices (including mobile applications);
►The National Audiovisual Council (CNA) – for services providing access to audiovisual media services;
►The Ministry of Transport and Infrastructure – for transportation services (travel information and self-service terminals, except those integrated into vehicles, aircraft, vessels or rolling stock);
►The Competition Council – on indicative and non-binding examples of possible solutions contributing to compliance with accessibility requirements.
Authorities may initiate assessments and request corrective measures from economic operators in the event of non-compliance. If non-compliance persists, the product may be withdrawn from the market. Consumers, organisations, or other private legal entities may refer non-compliance with accessibility requirements to the courts or authorities.
Offences and Sanctions
Law 232/2022 provides for fines for various violations of obligations, which can reach up to RON 15,000 (approx. EUR 3,000).
In addition to fines, complementary measures may be proposed, such as the withdrawal/recall of the product from the market, the suspension of the activity of the economic operator or the suspension/withdrawal of the permit, agreement or authorisation to exercise the activity.
Entry Into Force and Transitional Rules
Law 232/2022 shall enter into force on 28 June 2025, with the exception of the provisions relating to the handling of emergency communications to the single European emergency call number 112, which shall enter into force on 28 June 2027.
Service providers may continue to provide their services until 28 June 2030, using the products they used to provide similar services prior to 28 June 2025. Service provider contracts entered into prior to 28 June 2025 shall remain in effect without modification until their expiration, but not more than 5 years after that date. Self-service terminals used prior to 28 June 2025 may continue to be used to provide similar services, but not more than 20 years after they come into use.
Law 232/2022 is an important step towards ensuring an inclusive and accessible market for persons with disabilities, imposing clear obligations on economic operators. We recommend that all covered entities familiarise themselves with these new requirements and begin the necessary steps to ensure compliance.
