How to File an Accessibility Complaint in Romania

Perspectives11 min read

You cannot buy a train ticket. But the problem may lie with the station ticket machine, the PDF ticket received after payment, the travel app or the screen displaying service changes. For you, it is one failed transaction. For the law and public institutions, it may involve four separate components.

This is the idea that makes the difference between a vague complaint and one that can be verified: do not complain about an “inaccessible service” in the abstract; complain about the task you could not complete and the precise point at which you were blocked.

As a general rule, Law No. 232/2022 has applied since 28 June 2025 to categories including ATMs and ticket machines, consumer banking services, e-commerce and certain passenger-transport components. It stems from the European Accessibility Act, but it does not turn every existing machine into a new terminal overnight, nor does it place every stage of the same experience under a single authority. legeaz.net

In 90 seconds: describe the barrier in six fields

Before calling, writing or publishing an account of your experience, note down these six points. They are more useful than the conclusion that “it is not accessible”.

Task: What were you trying to complete? “Withdraw cash”, “confirm authentication”, “buy a ticket”, “pay for an order”.
Blocked step: Where did the process break down? For example: selecting the amount, entering the code, choosing the journey, confirming payment.
Observable barrier: What happened in concrete terms? “The screen reader does not announce the field”, “the button cannot be operated from the keyboard”, “the instruction disappears before it can be read”, “the error does not explain what needs to be corrected”.
Context: The date, time, exact location or page address; for apps, the version, phone and operating system.
What you tried: The steps you took, including any assistive technology used, where relevant.
Effect: What you could not do without help or an alternative solution: withdraw money, catch the service, make a payment or access your account.

This is the level at which verification can begin. A documented experience demonstrates a real barrier for the user. Establishing legal non-compliance, however, remains the responsibility of the operator, the competent authority or a court.

The operator first. Then the authority responsible for the component.

Separate two requests that serve different purposes:

To the operator — the bank, trader or transport operator: request that the urgent transaction be resolved, as well as a written response on the cause of the barrier and how it will be remedied.
To the supervisory authority — if the problem persists, the response is insufficient, or you want compliance with Law No. 232/2022 to be checked: send the same timeline, together with the operator’s response.

ANPC has an online complaint form and publicly states that a standard submission receives a registration number. Its procedure distinguishes between a notification, which may form the basis for an inspection, and a complaint, where the consumer also makes claims. For an issue involving a consumer banking service, this is a practical, verified channel for consumer-protection action. anpc.ro

For the other authorities designated by Law No. 232/2022, the editorial team had not identified, by the publication date, a single public form dedicated exclusively to accessibility notifications. Do not assume that the lack of a button with that name means you cannot submit a notification: send your petition through the institution’s general channel, explicitly state “notification concerning Law No. 232/2022”, and request a registration number. If the institution considers another authority competent, request that it forward the case and confirm this in writing.

Quick guide: which component was blocked?

If the problem is with…	What to describe	Start with…	Authority indicated by law for the component
ATM	The terminal, location, time, screen or instruction that prevented the withdrawal	The bank or terminal operator; also request an immediate solution for the blocked transaction	The ministry responsible for the economy, for self-service terminals
Banking app	The app version, phone, authentication or confirmation step, and error message	The bank	ANPC, for consumer banking services
Ticket machine	The station, machine, route, exact step, and any alternative offered or refused	The transport operator	The ministry responsible for the economy, for the self-service terminal
Electronic ticket / electronic issuance	The point at which the ticket could not be issued, received, opened or used	The transport operator or ticket issuer	The ministry responsible for the economy
Transport website or app	The exact page or screen, device and outcome of the blockage	The transport operator	The Authority for the Digitalisation of Romania
Travel information	Which information was missing or could not be perceived, and which travel decision was affected	The transport operator	The Ministry of Transport and Infrastructure, for the information component provided for by law
Online-store checkout	The page, identification, security or payment step that could not be completed	The trader; it is your contractual counterparty	The Authority for the Digitalisation of Romania, for e-commerce, under the allocation set out in the law

The table is a guide, not an administrative decision. In a technical workflow, the same obstacle may involve several companies: the trader, payment processor, issuing bank, authentication provider or terminal manufacturer. This is why the first useful question for the operator is: “Who provides the step at which I was blocked, and what remedial measure are you applying?”

Why an ATM and the same bank’s app are two different cases

The law treats an ATM as a self-service payment terminal. A mobile-banking app falls within the category of consumer banking services. The same logo does not alter this distinction: the physical terminal and the digital service have separate supervisory rules. infodosar.ro

There is also a timing issue. The law allows providers to continue, until 28 June 2030, providing certain services using products used for similar services before 28 June 2025. Separately, self-service terminals already in use before 28 June 2025 may remain in use for similar services within the limits laid down by law. This may matter for an older ATM or ticket machine, but it cannot be assumed simply by looking at it: customers generally do not know the date on which a machine entered service or its technical history. legeaz.net

Do not, however, accept the transition period as an answer without substance. If the operator invokes it, ask them to specify which product is concerned, which transitional rule they are applying and what immediate alternative they are offering you. The transition may limit the conclusion regarding a specific terminal; it does not turn the user’s experience into a problem unworthy of resolution.

What you can request when the transaction is urgent

Accessibility legislation concerns the compliance of products and services. It does not, by itself, guarantee that every blocked transaction will be completed instantly or that you will automatically receive compensation. But in your complaint to the operator, you can explicitly request three things:

an accessible, immediate solution — for example, assistance through a human channel, reissuing the ticket in a usable format, or an alternative confirmation method;
preservation of your commercial entitlement — for example, that you do not lose your booking, payment or account access because of a step you could not complete;
a written response on the technical component involved, the available alternative and the timeframe the operator estimates for the remedy.

Do not confuse an individual solution with a structural remedy. An employee helping you complete the transaction may resolve today’s urgent need, but does not by itself answer whether the next user will be able to complete the same task independently.

Short complaint template, ready to adapt

Subject: Accessibility barrier in [service/component] — request for remedy and written response

On [date], at [time], I attempted to [task] through [terminal/app/website], at [location/web address]. At the [exact step] stage, [specific description of the barrier]. I used [device, operating system, assistive technology — if relevant], and the result was that I could not [specific effect].

I request: 1) an accessible alternative solution to complete the transaction; 2) confirmation of the component or provider responsible for the blocked stage; 3) a written response on the remedial measure and estimated timeframe.

I attach [screenshots/photos], with sensitive data removed. Please provide the complaint’s registration number.

Example for a banking app: “When confirming authentication, in version [x] of the app, on [phone and operating system], the screen reader does not announce the mandatory code field. I could not complete access to my account without assistance.”

Example for a ticket machine: “At the ticket machine in [station], at [time], the screen returned to the home page before I could go through the instructions. I could not buy a ticket for service [x] without assistance.”

Example for checkout: “At the payment stage for order [number], the confirmation button could not be activated from the keyboard. The page did not display an alternative or an explanation of the error, and the order could not be completed.”

In the same context, see also You Have Multiple Payment Methods. But How Many Survive the Same Outage?, which provides additional relevant information.

Useful evidence — and evidence you should not keep

Keep screenshots, photos of the terminal, the time and place, the steps taken, error messages and the operator’s responses. For apps, note the version, device, operating system and relevant assistive technology.

Do not photograph or send PINs, one-time codes, full card details, account balances, identity documents or information about other people. A good notification should enable the problem to be reproduced, not expose your financial data.

Exceptions exist, but they are not a formula for ending the discussion

The law provides for situations involving a fundamental alteration and disproportionate burden. An operator relying on these must carry out an assessment and retain the results; on request, the assessment may be sent to the competent authorities. In other words, a generic assertion such as “it would cost too much” is not, on its own, the full explanation that the authority should receive. lege5.ro

Microenterprises that provide services are also exempt from the application of the law. The exemption should not automatically be extended to every small company, every product or every digital service. If an operator invokes it, ask them to state clearly in what capacity and under which provision they do so.

The useful conclusion: turn the blockage into a question that can be answered

“Your service is not accessible” is a conclusion. “I could not complete the payment because the confirmation button could not be operated from the keyboard, at date and time X; what alternative do you offer me and when will you remedy the issue?” is a verifiable request.

That does not artificially simplify the law. It makes it useful. For the user, accessibility begins with the ability to complete a task without depending on chance, another person’s help or a channel that the service does not normally offer.

Frequently asked questions

Can I send a complaint about an inaccessible ATM to ANPC?

For consumer banking services, Law No. 232/2022 identifies ANPC. For an ATM, treated as a self-service terminal, the law identifies the authority responsible for the economy. In practice, start with the bank or ATM operator, request that the transaction be resolved, and then send the notification to the authority corresponding to the blocked component.

Does the transition until 28 June 2030 mean old ATMs do not have to be accessible?

No. The law contains transitional rules for products already in use before 28 June 2025, and their application depends on the conditions and history of that product. A user cannot determine merely from the outside whether a specific terminal falls within the transition. The barrier can still be reported, and the operator can be asked which rule it invokes and what alternative it offers.

If an online payment is blocked, is the trader automatically solely responsible?

No. The trader is the first point of contact because it is the party with which you have the consumer relationship, but the technical cause may lie with the payment processor, authentication service or issuing bank. Describe the exact step that failed and ask the trader to identify the responsible component.

What can I request immediately if I cannot complete my transaction?

Request an accessible alternative for the specific transaction, preservation of the booking or order where applicable, and a written response concerning the cause, the provider of the blocked stage and the estimated timeframe for a remedy. The law does not automatically promise an instant solution or compensation, but the commercial complaint and accessibility notification can proceed in parallel.

Can I call 112 to check accessible options?

No. The 112 number is reserved for real emergencies. The special obligation in Law No. 232/2022 concerning the accessible handling of communications to 112 takes effect on 28 June 2027. The technical status of accessible channels should be checked through official information, not trial calls.