Lithuania

Lithuania's accessibility framework is built from two European Union directives transposed onto a long-standing domestic disability-rights foundation. Public-sector websites and mobile applications have been on the hook since 2019 under the Public Sector Bodies Accessibility Act (Viešojo sektoriaus subjektų prieinamumo įstatymas), which carried Directive (EU) 2016/2102 into national law. Private-sector products and services followed in 2023, when the Lithuanian Seimas adopted the stand-alone Law on Accessibility of Products and Services (Gaminių ir paslaugų prieinamumo įstatymas) to transpose Directive (EU) 2019/882 — the European Accessibility Act — with substantive obligations on businesses applying from 28 June 2025. Below both sits a constitutional and treaty foundation older than either directive.

The constitutional and treaty floor

The 1992 Constitution of the Republic of Lithuania (Lietuvos Respublikos Konstitucija) is the apex source. Article 29 guarantees that "all persons shall be equal before the law, the court, and other State institutions and officials" and prohibits restriction of rights on grounds including health condition — the textual anchor under which disability-discrimination claims are constitutionalised. Article 53 obliges the State to take care of people's health and provides in its second paragraph that the State and society "shall take care of persons with disabilities" and ensure their social integration. The Constitutional Court of Lithuania has read Article 53(2) as imposing a positive State obligation rather than a programmatic ideal, and it has been invoked in administrative-court review of penalty decisions under the Law on Social Integration of the Disabled.

Lithuania signed the UN Convention on the Rights of Persons with Disabilities on 30 March 2007 and deposited its instrument of ratification on 18 August 2010; the Convention entered into force for Lithuania on 17 September 2010, together with the Optional Protocol. Article 9 (accessibility) and Article 33 (national implementation and monitoring) are the international-law instruments most frequently cited in Lithuanian policy documents. The CRPD Committee's Concluding Observations on Lithuania's combined Second and Third Periodic Report flagged the need to accelerate digital-services accessibility, strengthen the independent monitoring mechanism, and align deprivation-of-legal-capacity law with Article 12 — themes the 2024 rewrite of the Law on Social Integration of the Disabled explicitly addresses.

A distinctive feature of the Lithuanian framework is the constitutional and statutory recognition of Lithuanian Sign Language (lietuvių gestų kalba, LGK). A 1995 Government Resolution recognised LGK as the native language of the deaf community in Lithuania — one of the earliest such recognitions in Europe. The recognition feeds into accessibility obligations on broadcasters, public administration, and emergency-communication services under both the WAD-transposing law and sector-specific legislation.

Public-sector accessibility: the WAD path via VSSPĮ

Directive (EU) 2016/2102 — the Web Accessibility Directive — was transposed into Lithuanian law through the Public Sector Bodies Accessibility Act (Viešojo sektoriaus subjektų prieinamumo įstatymas, VSSPĮ), adopted by the Seimas in 2019 just inside the 23 September 2018 EU deadline. Unlike Bulgaria's amend-an-existing-act approach, Lithuania chose a stand-alone statute, which gave the country a cleaner legal vehicle for the supervisory and methodology provisions and reduced the cross-referencing burden between accessibility rules and the broader law on electronic government.

The act obliges every public-sector body in Lithuania — central administration, municipalities, state-funded universities and research institutes, hospitals run by public bodies, and the publicly-owned enterprises captured by the EU's expanded definition — to make their websites and mobile applications conform to the technical standard set by Government Resolution. Three concrete obligations follow:

• Conformance. Websites and mobile applications must conform to the harmonised European standard EN 301 549 (currently v3.2.1, integrating WCAG 2.1 Level AA). The implementing Government Resolution fixes the conformance bar at WCAG 2.1 AA pending the formal update of EN 301 549 to track WCAG 2.2.
• Accessibility statement. Each in-scope body must publish, in Lithuanian, a structured accessibility statement covering conformance status, content that falls outside the directive's scope (third-party widgets, legacy office documents predating September 2018, archived recordings), and a complaint mechanism. The statement is filed into the national registry maintained by IVPK.
• Feedback and enforcement procedure. Users must be able to submit accessibility complaints to the in-scope body; unresolved complaints are escalated to IVPK as the national enforcement body for WAD.

The supervising regulator is the Information Society Development Committee (Informacinės visuomenės plėtros komitetas, IVPK), operating under the Ministry of Economy and Innovation. IVPK runs the periodic monitoring rounds required by Commission Decision (EU) 2018/1523 — twice-yearly simplified scans of roughly 3,500 in-scope sites and a smaller in-depth-scan tranche each cycle — publishing the results into the national accessibility-statement registry and contributing the Lithuanian dataset to the Commission's biennial WAD implementation review. Lithuania has consistently appeared in the implementation review without an open finding since 2022.

Private-sector accessibility: the EAA path via GPPĮ

The European Accessibility Act — Directive (EU) 2019/882 — was transposed into Lithuanian law as a stand-alone statute, the Law on Accessibility of Products and Services (Lietuvos Respublikos gaminių ir paslaugų prieinamumo įstatymas, GPPĮ), adopted by the Seimas on 30 March 2023. The implementing Government Resolutions on conformity-assessment procedures and market-surveillance arrangements were issued through 2024, and the substantive obligations on businesses took effect on the EU-wide application date of 28 June 2025.

The GPPĮ covers the directive's full product and service scope:

• Products: computer hardware and operating systems, self-service terminals (ATMs, ticket machines, check-in kiosks), consumer terminal equipment with interactive computing capability used to access audiovisual media services, consumer terminal equipment used for electronic communications services, and e-readers.
• Services: electronic communications services, services providing access to audiovisual media services, elements of air-, bus-, rail- and waterborne passenger-transport services, consumer banking services, e-books and dedicated software, and e-commerce services.

The act borrows the directive's micro-enterprise carve-out: businesses with fewer than 10 employees and an annual turnover or balance-sheet total not exceeding €2 million are exempt from the service-side obligations (but not from the product-side obligations, which run on the manufacturer-rather-than-employer test). The transitional period for terminals already in use on 28 June 2025 extends until 28 June 2045 or until the terminal's economically-useful end of life, whichever comes first — calibrated to the depreciation cycle of bank-branch ATMs and transport-network ticket machines.

The market-surveillance authority on the product side is the State Consumer Rights Protection Authority (Valstybinė vartotojų teisių apsaugos tarnyba, VVTAT), an institution with a long-established role in general consumer-protection enforcement and product-safety surveillance. Cross-border market surveillance follows EU Regulation (EU) 2019/1020 and is coordinated through the EU's Information and Communication System on Market Surveillance (ICSMS). On the service side, GPPĮ designates sectoral regulators in the relevant lead role: the Bank of Lithuania for consumer banking services, the Communications Regulatory Authority (Ryšių reguliavimo tarnyba, RRT) for electronic communications and audiovisual media services, and the Transport Competence Agency for passenger-transport elements — with VVTAT serving as the residual authority and the formal national contact point for inter-Member-State cooperation.

The cross-cutting backstops: equality law and the disability-rights statute

The Law on Equal Opportunities (Lygių galimybių įstatymas, LGĮ) — adopted in 2003 and in force from 1 January 2005 — recognises disability as a protected characteristic and prohibits direct and indirect discrimination, harassment, and the failure to provide reasonable accommodation. The act creates an independent equality body, the Office of the Equal Opportunities Ombudsperson (Lygių galimybių kontrolieriaus tarnyba, LGKT), with authority to investigate complaints, issue binding recommendations, refer matters to the Administrative Disputes Commission, and bring proceedings in the administrative courts. The Ombudsperson is also the designated CRPD Article 33(2) independent monitoring mechanism for Lithuania, which couples the equality-body function with a treaty-monitoring mandate and feeds directly into the country's periodic reports to the CRPD Committee in Geneva.

The LGKT has built a steady caseload of digital-accessibility complaints since the WAD-transposition deadline. Decisions involving inaccessible online-banking interfaces, inaccessible municipal-administration portals, and inaccessible e-commerce checkouts have produced recommendations to remedy the inaccessibility within fixed periods, with referral to the administrative-disputes route where the respondent refuses to comply. The Ombudsperson's findings are persuasive in subsequent civil-court proceedings for damages, and have in several recent cases been cited in Supreme Administrative Court rulings on the proportionality of administrative responses.

The older domestic foundation is the Law on Social Integration of the Disabled (Lietuvos Respublikos neįgaliųjų socialinės integracijos įstatymas, NSIĮ), originally enacted on 28 November 1991 — among the first acts of the restored independent Lithuanian Seimas — and substantially modernised in 2004 in the run-up to EU accession. A further significant rewrite was adopted in 2024 to align the statute with the social model of disability under the CRPD, retitle key concepts (replacing older medical-model terminology with rights-based language), and recalibrate the relationship between the assessment authority (NDNT) and the social-protection entitlements that flow from the assessment. The act underpins the National Programme for Social Integration of Persons with Disabilities and provides the statutory hook for sector-specific accessibility regulations that pre-date or sit alongside the WAD and EAA frameworks (built-environment accessibility under the construction-technical regulations, sign-language interpretation services, transport-accessibility minima).

Technical standards and conformance

The conformance bar across the public-sector (WAD) and private-sector (EAA) tracks is anchored on the same EU harmonised standard, EN 301 549, currently in force at version 3.2.1. EN 301 549 imports WCAG 2.1 Level AA as its baseline web-content conformance requirement and adds requirements specific to mobile applications, native software, non-web documents, hardware, and communications functionality. The standard's update to integrate WCAG 2.2 is in progress at ETSI and CEN-CENELEC; once published, the IVPK's monitoring methodology and VVTAT's market-surveillance guidance are both expected to track the new version on a transitional schedule.

The 2024 implementing Government Resolutions under the GPPĮ set out the conformity-assessment procedures, the form of the EU Declaration of Conformity required for in-scope products, the technical-file requirements, the CE-marking interaction, and the language regime: declarations may be issued in Lithuanian or in English, with a Lithuanian translation provided on request. For accessibility statements — required under both the VSSPĮ and the GPPĮ — the Commission's Implementing Decision (EU) 2018/1523 model is followed verbatim in the public-sector context, and the lighter "information for consumers" notice is the standard under the EAA path.

Penalties — the full exposure stack

A common error in compliance budgeting is to read the administrative-fine schedule in isolation and conclude that accessibility violations in Lithuania are inexpensive. They are not. The administrative-fine column is the floor of a five-layer exposure stack: (1) administrative fines under the two transposition acts and the Code of Administrative Offences; (2) civil damages under the Law on Equal Opportunities, with discretionary moral-damage awards; (3) public-procurement disqualification, with bid-revenue implications that often dwarf the fine itself; (4) consumer-protection and collective-redress exposure under the general civil-procedure framework; and (5) EU Commission infringement procedures against the Lithuanian state for systemic non-implementation, which sit outside the national regime but flow back as policy pressure on the regulators to enforce harder. All figures below are in euros — Lithuania has been in the euro area since 1 January 2015.

Layer 1 — administrative fines under the two transposition acts

The EAA's Article 30 obliges every Member State to set penalties that are "effective, proportionate, and dissuasive" — language the Court of Justice has interpreted to require maxima sufficient to alter the cost-benefit calculation of large operators, not nominal fines treated as a cost of doing business. The WAD's Article 9 imposes the same proportionality test on the public-sector side. The Lithuanian transposition implements both through tiered administrative-fine provisions, with the upper tiers reserved for repeated or systemic violations.

Lithuania's EAA ceiling sits in the middle-to-lower part of the EU-wide spread. By way of comparison: Germany's BFSG §37 caps single-incident fines at €100,000; France's 2023 transposition ordinance allows administrative fines up to €50,000 per non-conforming product, with per-day penalties for ongoing non-compliance; Spain's Ley 11/2023 sets a graduated framework reaching €1,000,000 for "very serious" infringements; Italy's transposition (D.Lgs. 82/2022) caps at €40,000; and the Netherlands has signalled exposure of up to 5% of annual turnover for systemic violations. The Lithuanian figures reflect both the comparatively lower price level in Lithuania and the regulator's stated preference, at least in the first surveillance cycle, for corrective-action orders over high one-off fines.

Layer 2 — civil damages under the Law on Equal Opportunities

Beyond the administrative-fine track, complainants under LGĮ may pursue parallel civil claims in the general courts for both material and non-material (moral) damages. Lithuanian civil law sets no statutory cap on non-material damages — the courts assess them by reference to the severity of the breach, the duration of the discriminatory conduct, the size and resources of the respondent, and the broader public-interest implications. Awards in disability-discrimination cases over the last decade have typically fallen in the €500–€5,000 range per claimant, with a small number of high-profile cases reaching €10,000–€20,000 where the discriminatory effect on a class of users was well-documented. The civil-court route is the higher-exposure pathway for cases involving named individual claimants, especially where multiple complainants can be joined under Lithuanian civil-procedure rules on related claims.

Layer 3 — public-procurement disqualification

The Lithuanian Law on Public Procurement (Viešųjų pirkimų įstatymas, VPĮ), transposing the EU Procurement Directives, requires contracting authorities to consider accessibility from the technical-specification stage onward and allows for disqualification of bidders that have been found to have committed serious professional misconduct — a category that includes adjudicated accessibility-related discrimination decisions and significant administrative-penalty findings under GPPĮ. For vendors selling into the Lithuanian public sector — particularly the State Data Agency, the State Tax Inspectorate, the SoDra social-insurance fund, and the larger municipalities (Vilnius, Kaunas, Klaipėda) — the loss of bid eligibility on an active procurement (typical contract values from a few hundred thousand euros to several million) routinely exceeds the administrative fine that triggered the disqualification by one to two orders of magnitude.

Layer 4 — consumer-protection and collective-redress exposure

Lithuania has implemented Directive (EU) 2020/1828 on representative actions for the protection of the collective interests of consumers through amendments to the Code of Civil Procedure and dedicated provisions in the Law on Consumer Protection. A digital service that systematically excludes a class of users with disabilities can give rise to a collective claim brought by a qualified consumer-protection entity, with damages assessed on a per-claimant basis and added together. The collective-redress route remains rare in Lithuanian practice but is increasingly invoked across the EU, and the VVTAT has signalled active interest in digital-services accessibility as a priority area under its 2025–2026 work plan.

Layer 5 — EU Commission infringement procedures (state-level)

The largest exposure number in the EU accessibility landscape is not a fine on a business — it is the lump-sum and daily penalty the Court of Justice of the European Union can impose on a Member State under Article 260(2) TFEU for failing to transpose or enforce an EU directive. The 2025 Commission communication on financial sanctions sets the indicative minimum lump-sum payment for failure to comply with a previous CJEU judgment at approximately €1,300,000 for Lithuania, with daily penalty payments calculated from a base of roughly €1,500–€7,500 per day multiplied by severity and duration coefficients. No accessibility-specific infringement procedure is open against Lithuania at present; the EAA-related risk vector for any Member State where the national enforcement infrastructure lags remains a credible 2026–28 concern. The pressure of an open Commission infringement procedure routinely produces a step-change in how aggressively the national regulator uses its existing administrative-fine powers.

Enforcement record and outlook

Public-sector enforcement under the VSSPĮ has been steady but not particularly aggressive: IVPK's monitoring methodology produces twice-yearly simplified scans of roughly 3,500 in-scope sites and a smaller in-depth-scan tranche each cycle. Findings of non-conformance trigger remedial-action orders in the first instance, with administrative penalties reserved for repeat offenders or for cases where the public-sector body refuses to engage. The first cohort of WAD-related penalty decisions appealed to the administrative courts (2023–2024) has produced a roughly even split between full upholding and partial reduction of the fine, with the Supreme Administrative Court (Lietuvos vyriausiasis administracinis teismas) generally deferring to IVPK on the substantive non-conformance finding while exercising independent review on proportionality.

Private-sector enforcement under the GPPĮ started only on 28 June 2025 and is in its first surveillance cycle as of mid-2026. VVTAT's market-surveillance programme prioritises (per its published 2025–2026 work plan): banking-app accessibility (with the Bank of Lithuania), e-commerce checkout accessibility, self-service ticketing kiosks at major transport hubs (with the Transport Competence Agency), and e-book reader devices and software placed on the Lithuanian market. The first round of administrative-penalty decisions under the GPPĮ is expected through the second half of 2026; the current expectation in the regulatory community is that VVTAT will give regulated entities a short formal grace period (typically a 60-day corrective-action window) before assessing penalties, except in cases of egregious or repeated non-compliance.

The LGKT's caseload on digital-inaccessibility-as-discrimination has been the most active enforcement strand over the past decade. Recommendations and findings in 2024 and 2025 against major Lithuanian retail banks, two municipal-administration portals, and a national online-pharmacy platform are now feeding into the appellate cycle before the administrative courts. The general pattern is that the Ombudsperson's substantive findings of discrimination are upheld more often than not, with the courts intervening primarily on the proportionality of the administrative response and on the question of how rapidly the respondent must remedy the inaccessibility.

What's coming in 2026–27

Three concrete developments to watch. First, the secondary legislation under the GPPĮ continues to be operationalised through 2026: detailed technical-file content requirements, the form of the EU Declaration of Conformity for in-scope products, and the procedure for designating notified bodies under the EAA's conformity-assessment regime. Second, IVPK has signalled an updated national accessibility methodology designed to align Lithuania's WAD monitoring with WCAG 2.2 once EN 301 549 formally tracks the new version. Third, the 2024 rewrite of the Law on Social Integration of the Disabled continues to bed in, with secondary instruments under the new statute being issued progressively through 2025–2026, including revised technical regulations on built-environment accessibility and a refreshed National Programme for Social Integration.

On the international-monitoring side, Lithuania's next periodic report to the CRPD Committee is due in 2027, and accessibility implementation under both the WAD and EAA pathways will feature prominently in the next round of Concluding Observations. The LGKT, in its capacity as Article 33(2) independent monitoring mechanism, is the primary domestic body coordinating the Lithuanian civil-society and shadow-report input to the CRPD review.