Landscape - Blueprint: Trialogue Model
Building Bridges
Poland's "Trialogue" working group demonstrates how collaborative governance can transform regulatory ambiguity into practical guidance. The initiative brings together market surveillance authorities – including representatives of the State Fund for Rehabilitation of Disabled Persons, the Financial Ombudsman, the Ministry of Digitisation, the Office of Electronic Communications, and other regulatory bodies – with business representatives and non-governmental organizations to address complex accessibility implementation questions through a structured dialogue.
Shared Understanding
This multi-stakeholder model achieves what isolated regulatory interpretation cannot: shared understanding grounded in operational reality. Regulatory authorities bring legal expertise and enforcement perspective. NGOs contribute user experience and rights-based frameworks. Business brings the practical knowledge of technical constraints, market dynamics, resource realities, and operational complexities that determine whether regulatory requirements can be translated into functional accessibility.
BAF’s Role in Trialogue
The Business Accessibility Forum actively participates in Trialogue proceedings, contributing business perspectives grounded in operational realities. The working group has developed practical recommendations which the Polish Accessibility Council (Rada Dostępności) subsequently adopted (PDF). These address questions businesses confront daily: Where do e-commerce boundaries lie? Who bears responsibility when accessibility fails on consumer devices? How does liability distribute across third-party platforms? Which documents demand compliance? Further recommendations are in development as the group addresses new challenges.
Shared Goals, Practical Solutions
The power of this approach lies in its recognition that all stakeholders ultimately pursue the same goal: genuinely accessible digital environments that serve users effectively while remaining economically sustainable for businesses to adopt.
The regulatory ambiguities cannot be resolved through enforcement alone. They require dialogue where business expertise informs regulatory interpretation, where accessibility advocates make sure user needs remain central, and where authorities provide legal clarity within this collaborative framework.
The Polish model demonstrates why business participation in such forums is essential. Businesses implement accessibility requirements daily, encountering technical barriers, resource constraints, third-party dependencies, and user needs that regulatory frameworks must address pragmatically. Regulatory guidance that ignores business realities risks becoming impossible to implement in practice.
The Trialogue Template
The Trialogue model offers a replicable template for the EAA’s Article 28 expert group and for national transposition frameworks across Europe. When regulatory authorities, NGOs, accessibility experts, and business representatives collaborate openly toward shared objectives, accessibility regulation becomes more effective, more practical, and more likely to achieve its fundamental purpose: ensuring equal access to digital society for all users.
In Poland, I have the privilege of leading the Trialogue – an initiative that puts into practice the idea of shared responsibility for adopting the European Accessibility Act (EAA). It is a model of collaboration between public administration, business, and the expert community, aimed at jointly interpreting the law, identifying barriers, and developing practical implementation recommendations.
Within the framework of Trialogue, we develop recommendations for interpreting the national Accessibility Act – covering certain products and services – which are then used by supervisory authorities, businesses, and consumers alike. As a result, the process of implementing new regulations becomes more consistent, predictable, and grounded in the real-world experience of market participants.
— Artur Marcinkowski
Founder, Business Accessibility Forum
Founder, the Visibles
This approach, based on dialogue, expertise, and shared accountability, can be considered one of the most inspiring best practices in Europe. Trialogue demonstrates that executing accessibility legislation doesn’t have to be a confrontational process; it can be a partnership-driven effort, fostering a culture of cooperation and mutual learning.
Through this initiative, Poland has shown that accessibility can be a shared goal and a shared value. It’s a model worth scaling to the European level – as a tool for dialogue and practical coordination in the implementation of the European Accessibility Act.
Artur Marcinkowski
Founder, Business Accessibility Forum
Founder, the Visibles