New requirements for products and services

On 28 June 2025, Act No. 424/2023 Coll. on Accessibility Requirements for Certain Products and Services will come into force to make certain products and services accessible to persons with disabilities. This is the implementation of Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on accessibility requirements for products and services (European Accessibility Act or EAA). As this is EU legislation, identical or very similar rules will apply across the EU (for example in Germany the so-called Barrierefreiheitsstärkungsgesetz). So-called micro-businesses with less than 10 employees and an annual turnover (or annual balance sheet total) of less than EUR 2 million are exempted from the law. All other businesses should take notice. Although the law only applies to certain categories of products and services, it covers, for example, all e-shops/online marketplaces and products, transport services, financial services, self-service terminals, computers, telephones and many other products and services.

Regulated products and services must meet accessibility requirements unless one of the exemptions applies. There are general requirements, and then requirements specific to the type of product or good. For products, these include general requirements for product information, instructions for use and user interface. Websites or mobile apps must be made accessible in a way that is perceivable, navigable, understandable and stable. It is therefore necessary, for example, to check the website for contrast, font size, image captions but also for the ability to read the text.

Failure to comply with these obligations is punishable by a fine of up to CZK 10,000,000 in the Czech Republic and up to EUR 100,000 in Germany. In Germany, there is also the risk of warning letters from competitors or consumer protection organisations, which are linked to the obligation to pay the costs of preparation of a warning letter by an attorney.

The end of the online consumer dispute resolution platform

The European online consumer dispute resolution platform will cease to operate on 20 July 2025. In particular, E-shop operators were obliged to inform consumers about this platform based on Regulation (EU) No 524/2013 of the European Parliament and of the Council, which is repealed on the above date. As of 20 July 2025, this obligation will no longer apply and all references to this online platform need to be removed from all documents/websites. In Germany in particular, neglect of this obligation may lead to warning letters from competitors or consumer protection organisations.

The information on out-of-court dispute resolution pursuant to Section 14 of the Czech Consumer Protection Act remains valid.

ČOI inspections

Please note that the Czech Trade Inspection Authority (ČOI) is currently inspecting e-shops. In the first quarter of the year, 174 inspections of online shops were carried out regarding compliance with the Consumer Protection Act. The ČOI found violations in 151 cases, i.e. in 86.78 % of all inspections! At the same time, 184 fines in the total amount of CZK 3,042,000 became enforceable in connection with the inspection of e-shops in the first quarter of this year (see ČOI press release of 19 June 2025). The risks of fines and their amounts are rising. In the German market, a careful approach to consumer law is already a matter of course, as there is a risk of warning letters from competitors or consumer protection organisations, which are linked to the obligation of the costs of drafting warning letter by a lawyer.

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This material is for general information on current topics only, it is not advice. It does not take into account any special circumstances, financial situations or special requirements of the addressees. Recipients should therefore always seek appropriate professional services for the information provided. Notwithstanding the careful compilation of this material, bpv Braun Partners s.r.o. advokáti, its partners, associates or co-operating solicitors and tax advisers cannot guarantee the accuracy or completeness of the information contained herein and accepts no responsibility for acting or refraining from acting on the basis of the information contained in this material.