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European Accessibility Act: Lithuania (No. XIV-1633)
LT- Applies from
- 2025-06-28
- Maximum penalty
- €15,000
- Enforcement authority
- Valstybinė vartotojų teisių apsaugos tarnyba (VVTAT / State Consumer Rights Protection Service) — primary authority, covering most products (computers, self-service terminals, e-readers) and services (banking, e-books, e-commerce). Sector regulators handle their own areas: Lietuvos transporto saugos administracija (LTSA) for passenger transport service elements and railway-interoperable products; Lietuvos Respublikos ryšių reguliavimo tarnyba (RRT) for electronic communications services; Lietuvos radijo ir televizijos komisija (LRTK) for audiovisual media access products and services. — https://vvtat.lrv.lt/
- Microenterprise exemption
- Yes — under the EAA's EU-wide microenterprise exemption for services
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- National law
- Lietuvos Respublikos gaminių ir paslaugų prieinamumo reikalavimų įstatymas (No. XIV-1633)
- Notes
- Article 23 sets a tiered fine structure rather than one flat maximum: €500–2,500 for placing/providing a non-compliant product or service; €1,000–6,500 for defying a market-surveillance authority's restriction, withdrawal, or stop-service order; €2,500–15,000 if the non-compliant product or service caused actual harm to a consumer's or end-user's health. Article 23(4) sets the actual fine at the midpoint of the applicable tier, then moves it toward the ceiling for aggravating circumstances (repeat violation within a year; obstructing the investigation) or toward the floor for mitigating ones (voluntary harm prevention; voluntary compensation). A warning can substitute for the lowest tier if a non-compliant product is voluntarily withdrawn before reaching consumers. Fines/warnings must be imposed within 5 years of the violation (Art 25).
Who is obligated in Lithuania
Lithuania's law transposes the EAA's full scope: computers and operating systems, self-service terminals (payment terminals, ATMs, ticketing/check-in machines, interactive information terminals), consumer terminal equipment for electronic communications, audiovisual media access equipment, and e-readers among products; electronic communications, audiovisual media access services, air/bus/waterborne/rail passenger transport information elements, consumer banking, e-books and their software, and e-commerce among services. It also extends accessibility duties to the national 112 emergency response service. Article 7(1) grants the law's only explicit exemption: micro-enterprises (under 10 staff, under €2M turnover/balance sheet) providing services are fully exempted. Manufacturing micro-enterprises are not exempted from product requirements themselves, but face lighter paperwork if invoking the disproportionate-burden defence. All other operators must comply from 28 June 2025, with transition until 28 June 2030 for services using pre-existing non-compliant products and for contracts signed before that deadline.
What happens if you don't comply
Enforcement splits across four market surveillance authorities by category. A case opens from a complaint — filed by a consumer, end user, state/municipal body, consumer association, or any other interested person (Art 26(2), not restricted to the affected party) — or the authority's own initiative. Investigators can inspect premises, demand documents, and sample products (Art 21). On finding a violation, the authority typically first issues a reasoned written notice ordering correction within a reasonable period, minimum 3 working days (Art 19, 20, 21(1)(7)); only continued non-compliance escalates to market restriction, withdrawal, or a fine. The operator gets at least 14 days' written notice before a formal hearing, can review the evidence, and may request an oral hearing. A decision must issue within 3 months of the authority receiving the investigation file. Decisions are appealable within one month to an administrative court (Art 27).
How this differs from the EU baseline
Lithuania splits enforcement four ways by sector — VVTAT as consumer-facing generalist, plus dedicated transport, telecoms, and broadcast-media regulators — closer to Latvia's model than to a single-authority country like Austria. Distinctively, its fine structure is explicitly tiered by harm and defiance rather than one ceiling: a modest band for a first-instance non-compliant product/service, a higher band for ignoring a market-surveillance order, and a top band reserved specifically for cases causing actual consumer health harm. The law codifies formal aggravating/mitigating factors that mechanically shift the fine from the tier's midpoint — a level of procedural detail well beyond the bare Directive. A statutory 5-year limitation period on imposing fines, and a mandatory legislative effectiveness review 3 years after entry into force, are further national additions.
How to complain
Article 26(2) lets essentially anyone trigger a case — a consumer, an end user, a state or municipal institution, a consumer association, or another interested person, not only the person directly affected. Complaints go to whichever of the four market surveillance authorities covers the relevant product or service; for most consumer goods and services that is VVTAT, which offers an online electronic-complaint channel and a consumer-request form on its site, alongside phone and postal options.
Frequently asked questions about the EAA in Lithuania
- What is the maximum EAA fine in Lithuania?
- The maximum penalty is €15,000. Article 23 sets a tiered fine structure rather than one flat maximum: €500–2,500 for placing/providing a non-compliant product or service; €1,000–6,500 for defying a market-surveillance authority's restriction, withdrawal, or stop-service order; €2,500–15,000 if the non-compliant product or service caused actual harm to a consumer's or end-user's health.
- Who enforces the European Accessibility Act in Lithuania?
- Valstybinė vartotojų teisių apsaugos tarnyba (VVTAT / State Consumer Rights Protection Service) — primary authority, covering most products (computers, self-service terminals, e-readers) and services (banking, e-books, e-commerce). Sector regulators handle their own areas: Lietuvos transporto saugos administracija (LTSA) for passenger transport service elements and railway-interoperable products; Lietuvos Respublikos ryšių reguliavimo tarnyba (RRT) for electronic communications services; Lietuvos radijo ir televizijos komisija (LRTK) for audiovisual media access products and services. Details are published at https://vvtat.lrv.lt/.
- Since when does the EAA apply in Lithuania?
- The requirements apply from 28 June 2025, the EU-wide date, transposed into Lithuania by Lithuania's national implementing law.
- Are small businesses exempt from the EAA in Lithuania?
- Only microenterprises — fewer than 10 staff and annual turnover or balance sheet total of €2 million or less — and only for services. A microenterprise in Lithuania that places a covered product on the market still has to make that product accessible.
Official source: https://www.e-tar.lt/portal/lt/legalAct/8869165081dc11ed8df094f359a60216
Verified on 2026-09-29. This page is not legal advice — verify against the official source above before making compliance decisions.