ACCESSIBILITY STATEMENT 

Epassi Finland Oy strives to guarantee the accessibility of its application in compliance with the Act on the Provision of Digital Services. 

This accessibility statement applies to Epassi App. 

Compliance status  

This application partly fulfils the requirements of the Finnish Act on the Provision of Digital Services 306/2019. Please see below for a list of non-conformities and exceptions applicable to the criteria. 

Non-accessible content  

The content discussed below is non-accessible for the specified reasons: 

Non-compliance with the Act on the Provision of Digital Services 306/2019 

The following content and/or functionalities do not yet meet the requirements: 
 
General Accessibility Issues 

• Android: The app contains decorative images that are not hidden from screen readers and lack alternative text. There are also informative images and icons without text alternatives, or the alternatives are insufficient. (WCAG 1.1.1) 

• Android: Headings in the app are not programmatically marked as headings. As a result, screen readers do not recognize them correctly, and users cannot navigate using headings. (WCAG 1.3.1, 2.4.6) 

• Android: Several views contain tab lists. Switching tabs may produce incorrect or unclear information. In some tab lists, numbers indicate the number of results per tab, but this is not clearly communicated to users. (WCAG 1.3.1, 4.1.2, 4.1.3) 

• Android: In some views, the reading and focus order is incorrect for assistive technology or keyboard users. Focus is sometimes placed in illogical locations when navigating between views, or it jumps unexpectedly. Focus does not always behave as expected in dialogs (e.g., it does not move to or remain within the open dialog). (WCAG 1.3.2, 2.4.3) 

• Text and content do not always adapt properly to zoom or text scaling. (WCAG 1.4.4) 

• Android: Some links and buttons have non-descriptive names. (WCAG 2.4.6) 

• Android: Some buttons are too small to meet accessibility touch target requirements, making them hard to activate. (WCAG 2.5.8) 

• Some views or view components are not marked with the correct language, leading to mispronunciation by screen readers. This affects English descriptions in the Finnish app, confirmation emails, the login process, and receipt content. (WCAG 3.1.2) 

• Android: The app automatically logs users out after a certain period, but no real-time alert is provided to screen reader users when this happens. (WCAG 4.1.3) 

App Onboarding and Profile Completion 

• The PIN is submitted automatically after the last digit without warning. (WCAG 3.2.2) 

• Android: Form errors are not always connected to their fields, and clear suggestions for correction are not consistently provided. Screen readers may not read error messages automatically. (WCAG 3.3.1, 3.3.3, 4.1.3) 

• KYC process: Form instructions may be unclear, appear too late, or be in English in the Finnish app. Required fields are not always indicated. (WCAG 3.3.2) 

• KYC process: In the nationality dropdown during profile completion, the list may break, making it unusable with assistive tech or keyboard. (WCAG 2.1.1) 

• KYC process: During profile completion, users may land in visually hidden modal content. Navigation forward or backward is still possible. (WCAG 1.3.1, 1.3.2) 

• KYC process: It is not possible to exit the "Political Influence" modal using assistive technology in iOS. (WCAG 2.1.1, 2.1.2) 

Main App View 

• The "Stories" widget at the top has multiple issues: English labels when Finnish is selected as the app language, inconsistent element order, unclear structure of multi-part stories, and some stories are text within images, making them unreadable by screen readers. (WCAG 1.1.1, 1.3.1, 2.4.3, 4.1.2) 

• Android: No visible keyboard focus indicator is shown for search results. (WCAG 2.4.7) 

• Android: The instructional text for adding favorites refers only to the shape of the icon. (WCAG 1.3.3) 

• Android: Favorites are not grouped, so users may forget which information belongs to which favorited service. (WCAG 1.3.1) 

• Android: The button for transferring balances is not clearly named. (WCAG 2.4.6, 4.1.2) 

 

Service Provider Views 

• The "Back" button is not properly named. (WCAG 4.1.2) 

• Android: The tab list is not operable via keyboard. (WCAG 2.1.1) 

• Adding favorites may incorrectly announce the element as selected, even if it's not. Users can verify from the favorites section. (WCAG 4.1.2) 

• Expandable/collapsible elements have state communication issues. Some content appears before the button used to open it. On Android, some buttons are not marked as buttons. (WCAG 1.3.1, 1.3.2, 4.1.2) 

• Inline text links cannot be activated with keyboard or assistive tech. (WCAG 2.1.1) 

• Some links are not marked as links or lack descriptive names. (WCAG 4.1.2) 

• Several buttons for payment methods lack roles or have unclear states. (WCAG 4.1.2) 

• Icons for payment methods do not have clear text alternative. QR codes are hidden from assistive tech, so users don't know when they're visible. (WCAG 1.1.1, 1.3.3) 

• Some buttons have poor contrast between text and background. (WCAG 1.4.3) 

• A profile completion prompt appears only after the user tries to enter an amount and is not announced programmatically. (WCAG 3.3.2, 3.3.3, 4.1.3) 

• iOS: Some views contain empty elements that are announced as buttons but have no functionality. (WCAG 1.3.1, 4.1.2) 

 

Balances 

• Android: Users may sometimes be stuck and unable to navigate forward or backward. Sometimes users skip elements but can return to them by navigating in reverse. (WCAG 2.1.1, 2.1.2) 

• Android: Some links are not operable with keyboard or assistive technologies. (WCAG 2.1.1) 

• Android: The toggle for accepting EpassiBIKE terms is not correctly marked for assistive tech. (WCAG 4.1.2) 

• Android: The input field for entering MyMoney balance lacks a name. (WCAG 4.1.2) 
   

 
Epassi is continuously developing its products and services and we are continuously working on improving accessibility as we develop these products. This accessibility statement is kept up-to-date on the resolution of the non-conformities above. 
 

Certain content is excluded from the applicable legislation 

The following content and/or functionalities are not accessible as they are not covered by the Act on the Provision of Digital Services 306/2019). 

• Epassi application’s embedded map functionality. Accessible content of the embedded map is available directly through the application. 

 
Content excluded due to undue burden 

The following aspects of the content in the functionalities are not accessible due to undue burden by Epassi to make them accessible. Current form of the service has certain technical limitations which result in making the content accessible impossible or in any case result in unreasonable economic burden in the service's current form. Epassi will aim to make the content accessible in some point in the future in the normal development of its technical systems. 

• The app does not support landscape screen orientation. (WCAG 1.3.4) 

 

Preparation of this accessibility statement 

This statement was prepared on the 26th of June 2025. 

The statement is based on a third-party audit on the service’s compliance of the applicable legislation of whether or not the application meets the requirements of Act on the Provision of Digital Services 306/2019) and Directive (EU) 2016/2102 which it is based on. 

The statement was last reviewed on the 16th of July 2025. 

Did you notice shortcomings in accessibility? 

We are constantly striving to improve the accessibility of the application. If you encounter issues that are not described on this page, please report them to us and we will do our best to rectify them. 

Provide feedback [via this online form]. 

You can also use the feedback channel to request accessible information on the content of the application.  

Epassi Finland Oy is responsible for accessibility on the Epassi App and for processing any feedback.  

Enforcement procedure 

If you notice accessibility issues on the application first give feedback to the feedback channel mentioned above. Receiving a response may take 14 days.  

Finnish Transport and Communications Agency Traficom monitors compliance with the applicable accessibility requirements. If you are dissatisfied with a response or do not receive one within two weeks, you can submit your feedback to Traficom. 

Supervisory authority’s contact details 

Finnish Transport and Communications Agency Traficom Digital Accessibility Supervision Unit 

www.webaccessibility.fi 

saavutettavuus@traficom.fi 

telephone switchboard 029 534 5000