ACCESSIBILITY STATEMENT 

Epassi Finland Oy strives to guarantee the accessibility of its consumer-facing web services in compliance with the Act on the Provision of Digital Services. 

This accessibility statement applies to services.epassi.fi, including log-in, payment button, merchant search and user portal. 

Compliance status  

This service partly fulfils the requirements of the Finnish Act on the Provision of Digital Services 306/2019. [However, it meets the critical A and AA requirements of the WCAG criteria]. 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: 
 

Log-in, Onboarding and Payment button  

• The picture in the pages is changing automatically and users can’t pause, stop or hide it themselves. (WCAG 2.2.2) 

• The website contains some decorative images, which should have empty text alternatives, and some interactive elements that lack descriptive or accessible names. (WCAG 1.1.1, 4.1.2) 

• There are some visually marked page areas that are not marked programmatically, which makes focus order sometimes illogical. (WCAG 1.3.1, 2.4.3) 

• Not all elements have their correct role or purpose identified programmatically. (4.1.2) 

• Decorative elements disturb focus order. (2.4.3) 

• Some page titles do not describe the page content enough. (WCAG 2.4.2)  

 

Profile Completion 

• KYC process: Form instructions may be unclear, appear too late, or be in English in the Finnish language setting. 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. (WCAG 2.1.1, 2.1.2) 

 

Merchant search 

• Some merchant provided content can be in a different language that the main content and this is not marked properly for screen readers. This can mainly cause problems when using the UI in English or Swedish as most content provided by merchants is in Finnish. (WCAG 3.1.2) 

 

User portal 

• In some elements, the keyboard focus indicator is not visible. (WCAG 2.4.7)  

• Some pages do not scale in a responsive manner. Horizontal scrolling cannot be avoided. (WCAG 1.4.10)  

• The contrasts of some texts and the graphic elements do not meet the criteria. (WCAG 1.4.3, 1.4.11)  

• In some elements (e.g. some link texts) colour is the only visual means of conveying information, and the colours don’t always meet the criteria. (WCAG 1.4.1)  

• Not all headings are marked as HTML heading levels, some programmatic heading structures do not reflect the visual hierarchy and some other content is marked up programmatically as headings. (WCAG 1.3.1)  

• The website contains some decorative images, which should have empty text alternatives. (WCAG 1.1.1)  

• Visually marked page areas are not marked programmatically. (WCAG 1.3.1)  

• There are unordered and ordered lists of which structure is not communicated programmatically. (WCAG 1.3.1)  

• The row headings in some HTML tables are not marked programmatically. Some tables have completely empty columns. (WCAG 1.3.1)  

• Tooltips that appear with the mouse hover cannot be closed without moving the pointer. (WCAG 1.4.13)  

• Active elements are not marked programmatically. (WCAG 1.3.1)  

• There is no way to skip over repeated blocks to the main content. (WCAG 2.4.1)  

• Not all form fields have labels or visible labels are not programmatically associated with the fields. (WCAG 1.3.1).  

• Sometimes invalid form fields are not marked neither visually nor programmatically. Invalid form fields do not get automatic keyboard focus after the form is submitted. (WCAG 4.1.3, 3.3.1)  

• Asterisk mark is not explained on the page. (WCAG 1.3.1, 3.3.2)  

• The purpose of each input field collecting information about the user is not programmatically determined. (WCAG 1.3.5)  

• Some tab and accordion implementations are presented as regular links, which do not convey their purpose and state to screen reader users. (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). 

• The embedded map in merchant search functionality. Accessible content of the embedded map is available through the Service.  

 

Preparation of this accessibility statement 

This statement was prepared on the 16th of July 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 web services and for processing any feedback.  

Enforcement procedure 

If you notice accessibility issues on the web services 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