Preparing for the EAA with Legal Expert: What Lithuanian Businesses Need to Know

2025 05 09 · 4 min read

As the European Accessibility Act (EAA) compliance deadline of June 28, 2025, approaches, businesses in Lithuania are beginning to take a closer look at their readiness. How prepared are they? 

We spoke with Vaiva Masidlauskiene, a Legal Expert at Sorainen, to better understand the implementation process, potential challenges, and what businesses can expect from regulators in the coming months. Read on and discover her indispensable insights.

Institutions Are Preparing for European Accessibility Act 

When asked why EAA implementation appears sluggish in Lithuania, Vaiva explains that while things may seem quiet, work is happening behind the scenes. 

“The four key institutions – the State Consumer Rights Protection Authority, Lithuanian Radio and Television Commission, Communications Regulatory Authority and Lithuanian Transport Safety Administration each have their responsibilities. While we don’t yet see overarching guidelines from all of them, discussions are underway, and some have already issued their own directions”, she shares. 

For example, the Lithuanian Radio and Television Commission has already published draft guidelines for media service providers, and the Consumer Rights Protection Authority has released a FAQ on EAA requirements. Broader, general guidelines are expected soon from the leading executive organisation, the Ministry of Social Security and Labour, which would then serve as a basis for more specific sectoral rules. 

No Excuses for Inaction, Except a Few 

Despite the slow rollout of detailed instructions, the European Accessibility Act is already part of Lithuanian law as it is transposed into national legislation. As Vaiva notes, companies can – and should – start acting based on the legislation itself. 

“If you’re a business, you can already assess the information on what will apply from June 28, 2025. For instance, if you provide online services, you should ensure your website is accessible through multiple senses, for instance, screen reader compatibility as well as text. If it’s a book, you should consider incorporating the braille”, she advises. 

This does not mean a complete digital overhaul. According to article no. 14 (in Lithuanian) of the law implementing EAA in Lithuania, there is some flexibility: if implementation would result in a disproportionate burden, meaning large expenses with little benefit, or having to change the product completely, businesses can justify non-compliance. To be eligible, they would have to have an internal assessment conducted and the essential documentation prepared to back their claims. This would require businesses to use the internal resources (maybe even form a new team) or to request those services from external IT partners and lawyers. 

There is an exception for small businesses, too. When the turnover of the business is less than 2 million, or there are no more than 10 employees, the EAA does not apply. 

Three Types of Businesses: From Pioneers to the Unaware of the EAA 

Interestingly, Vaiva notes that businesses are in very different stages of preparation: 

  1. Pioneers – already fully compliant and waiting; 
  1. Proactive planners – have assessed their gaps and are working on implementation; 
  1. Unaware companies – still have not heard of the EAA. 

The good news? Among those asking for legal help, the level of understanding is improving. Vaiva notes: “The questions we receive are now much more specific. It shows that companies are not only becoming more aware but have started doing their homework”. 

Borrowing from the Best Global Practices 

Lithuanian businesses do not need to start from scratch. The EAA references international standards that many companies can already align with: 

  • EN 301 549 V3.2.1 – ICT accessibility requirements; 
  • EN 17161:2019 – design for all; 
  • WCAG 2.2 – the latest Web Content Accessibility Guidelines, updated in October 2023. 

While national regulators are still refining their guidance, these harmonised standards provide a solid foundation. The Lithuanian Consumer Rights Protection Authority has already recommended this trio of standards for companies aiming to comply. 

EAA Compliance as a Competitive Advantage 

Is the European Accessibility Act just another compliance headache? Vaiva does not think so. 

“I’d put EAA on the same shelf as ESG – they’re not about mitigating risks like DORA or NIS2. They’re about building a socially responsible business”, she says. 

Beyond just ticking regulatory boxes, accessibility offers potential as a competitive differentiator. Businesses that embrace inclusive design early will not only reduce legal risks but could also reach wider audiences and strengthen their brand reputation. 

Nevertheless, the enforcement model encourages cooperation. Regulators are expected to provide guidance and adjustment periods before imposing penalties. Only blatantly non-cooperative companies will face serious consequences like product bans across Lithuania and the EU. 

What is Next? 

With less than 2 months until the EAA becomes enforceable, the message for businesses is clear: start now. 

  • Use the legislation and existing standards as your guide. Check out our European Accessibility Act (EAA) Guide as a starting point; 
  • Begin internal assessments and documentation; 
  • Stay alert for new guidance from national authorities; 
  • Leverage accessibility as a strategic advantage – not just a requirement. 

“It’s just like with ESG. A few years ago, it sounded foreign. Today, it’s part of business as usual. I believe EAA will be the same – it’ll become the new normal”, concludes Vaiva. 

Thank you for the interview, Vaiva! 

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