The Ukrainian procedure for ensuring the accessibility of electronic communications services for persons with disabilities

Oleksandr Kozhukhar
AVELLUM, Kyiv
okozhukhar@avelum.com

Olha Rudevych
AVELLUM, Kyiv
orudevych@avellum.com

Mariia Hrusheva
AVELLUM, Kyiv
mhrusheva@avellum.com

Background

On 18 February 2026, largely in line with the European Accessibility Act and as part of the broader Digital Accessibility Law (no. 14278) being drafted in parallel, the Ministry of Digital Transformation of Ukraine adopted Order No. 35 approving the Procedure for Ensuring the Accessibility of Electronic Communications Services for Persons with Disabilities by Providers of Electronic Communications Services (the ‘Procedure’).

The Procedure entered into force on 31 March 2026 and will become mandatory for large and medium-sized businesses starting from 31 March 2028, and for small and micro businesses from 31 March 2030.

Scope of application

The Procedure applies to all providers of electronic communications services and sets out the framework for ensuring the accessibility of such services for persons with disabilities. In particular, it regulates the accessibility of:

• information on electronic communications services and related services;
• service providers’ websites and applications (including mobile applications);
• self-service terminals used to provide these services;
• customer-facing premises and other physical locations; and
• forms of communication with providers’ service desks.

Exclusions

The Procedure does not apply to:

• services that exclusively or predominantly ensure the transmission of signals between devices for machine-to-machine interactions without human participation;
• pre-recorded multimedia data and document formats distributed before the Procedure entered into force;
• online maps, services and technologies related to the creation, processing, analysis and provision of cartographic information in a digital format, provided that essential information is made available in an accessible digital form for maps intended for navigation;
• third-party content that is not ordered, paid for, developed or controlled by the relevant provider; and
• archived content of websites and mobile applications that only contain content that has not been edited after the Procedure entered into force.

The regulatory requirements

Accessibility of information about the services provided

When publishing information regarding the provision of electronic communications services, providers must ensure that such information includes:

• a general description of the service in a format accessible to persons with disabilities;
• the terms and conditions for the provision of the service;
• a description of the functional capabilities of the service and instructions on how to use it;
• an indication of the accessibility of the service for persons with disabilities and, where possible, its compatibility with assistive technologies; and
• information on the suitability of the relevant electronic communications services and related services for use by persons with disabilities, as well as their compliance with the Procedure.

This information must remain available throughout the entire period during which the relevant service is provided and must be available simultaneously in three forms: (1) written (either electronically or in print), (2) oral and (3) video or multimedia, incorporating Ukrainian sign language or Ukrainian subtitles.

When publishing such information, providers must also ensure that it is accessible in practice for persons with disabilities. In particular, the information should be made available through more than one sensory channel and presented in a clear and understandable manner (for example, by using consistent terminology and maintaining a clear, logical structure).

The information must also be provided in text formats suitable for conversion into alternative assistive formats that convey information through more than one sensory channel (for example, by printing it in Braille). Providers must use fonts of sufficient size and in an appropriate form, ensure sufficient contrast and apply adjustable spacing between letters, lines and paragraphs to ensure that persons with visual impairments can read the text.

Any non-text content must be accompanied by an alternative form of presentation (for example, a textual description of a diagram explaining its main elements or key actions). Where information is provided in video or multimedia format using Ukrainian sign language or Ukrainian subtitles, users must be able to stop, replay and adjust the scale the relevant content.

Accessibility of websites, applications and self-service terminals

Providers must ensure that their websites and applications are perceivable, operable, understandable and robust for persons with disabilities. In particular, such websites and applications must:

• comply with the accessibility requirements for persons with visual, hearing, musculoskeletal, speech and intellectual impairments, as well as persons with different combinations of impairments, in accordance with Ukrainian national standard DSTU EN 301 549:2022 ‘Information Technology. Accessibility Requirements for ICT Products and Services’;
• be compatible with existing specialised hardware and software used by persons with disabilities; and
• be accessible through mobile devices, taking into account accessibility functions supported by operating systems such as iOS and Android.

Where self-service terminals are installed in customer service centres, providers must take measures to ensure that their employees can provide advisory assistance to persons with disabilities in using such terminals.

Accessible communication with service desks

Providers must ensure that they offer accessible forms of communication with their service desks. These include text communication through website or application chats (including mobile apps), email or other accessible services or applications. Providers must also offer a voice communication option through voice electronic communications services, the use of voice messages via websites or application chats (including mobile apps) or other accessible services or applications supporting voice communication.

Where providers operate customer service centres, accessible communication options must also include in-person interaction. This includes communication in Ukrainian sign language, either directly by the provider or through third parties (for example, via video link). Providers may also use other alternative forms of communication, taking into account the needs of persons with disabilities (for example, relay communication technologies, text-to-speech systems and other specialised services).

Providers must also facilitate the training of service desk employees on how to communicate effectively with persons with disabilities, including by providing access to training materials and recommendations on the provision of information in accessible formats, the accessibility of electronic communications services and their compatibility with assistive technologies.

Accessibility of customer-facing premises

Customer-facing premises, including service centres, must comply with the relevant sanitary rules, fire and industrial safety requirements, as well as accessibility requirements for persons with disabilities and other individuals with reduced mobility under Ukrainian law.

Penalties

The Procedure does not introduce a separate penalty regime for non-compliance. Instead, liability for breaches of electronic communications legislation is generally governed by the Law of Ukraine ‘On Electronic Communications’. In particular, under the Law, a breach of the requirements for the provision of electronic communications services to end users may result in a fine ranging from UAH 17,000 to UAH 85,000 (approximately US$379 to US$1,895) for each violation.

Separately, the Procedure requires providers to comply with Ukrainian anti-discrimination legislation. Accordingly, non-compliance may also expose providers to individual claims by affected persons alleging discrimination on the grounds of disability, including claims for compensation for material and moral damage.