In June 2025 the Accessibility Requirements for Products and Services Act (“ARPSA” or the “Act”) entered into full force.
Its main objective is to harmonize the Bulgarian legislation with European law by facilitating the access for consumers with disabilities to a wide range of products and services at competitive prices.
The Act applies to specific categories of products and services, including: hardware and operating systems, payment terminals and ATMs, consumer equipment used for electronic communications and audio-visual content, banking services, e-books, and others.
What is key in the new Act? Products and services within the scope of the Act may be placed on the market only if they meet the so-called “accessibility requirements” – defined technical and functional parameters, described in detail in Appendix No 2 to the Act. These are aimed at making products and services easier and more effective to use by people with disabilities. For example, product usage information (labels, instructions, etc.) must be provided through more than one sensory channel, be understandable, and be printed in large and legible font, among others.
The obligated parties under the ARPSA are the “economic operators” of the listed products and services, which term includes: manufacturers, authorized representatives, importers, distributors, and service providers.
The main obligation for economic operators is to ensure that each product complies with the accessibility requirements before it is placed on the market. Products must be accompanied by technical documentation and safety instructions in Bulgarian, as well as a clear indication of the name, trademark, and address of the manufacturer and importer. If non-compliance is identified, the product must not be placed on the market, and if already released - measures must be taken immediately to correct the non-compliance or for its withdraw from the market. If the violation was, for example, committed by the product manufacturer, but later discovered by a distributor, importer, or service provider, the latter are obliged to immediately notify the relevant supervisory authorities.
Compliance with the accessibility requirements is monitored by different supervisory authorities, depending on the nature of the product or service, including the CRC, BNB, CPC, and others.
In case of a legal violation, consumers, as well as disability organizations have the right to file complaints and alerts to the competent authorities. Mechanisms for collective protection of the interests of affected individuals are also envisaged.
With the entry into force of the ARPSA, economic operators are obliged to bring their operations into full compliance with its provisions. The Act provides for administrative-penal liability in the case of violations, but also introduces certain reliefs:
(i) Violations committed until 1st June 2026 are subject to lower fines and sanctions;
(ii) Until 28th June 2030, obliged entities may continue using products that were lawfully in use before this date;
(iii) Service contracts concluded before 28th June 2025 may remain in force without modification/adaptation until their expiration, but no later than 5 years after this date.
The adoption of the ARPSA represents a significant step forward in Bulgaria’s legislative framework, aimed at removing barriers to the free movement of goods and services. Ensuring the accessibility and full technical compliance of the products offered is becoming a competitive advantage, but also a legal obligation. Companies that bring their activities into compliance with the requirements in a timely manner will not only avoid penalties, but will also position themselves sustainably in an increasingly regulated market and contribute to the full, equal, and unhindered participation of people with disabilities in public life, on par with the other citizens.
