European Accessibility Act (EAA): What Businesses Need to Know

What Is the European Accessibility Act?

The European Accessibility Act (EAA) is Directive (EU) 2019/882, adopted by the European Parliament and Council in April 2019. It is the most significant piece of EU legislation on accessibility for the private sector, establishing harmonized accessibility requirements for a broad range of products and services sold or provided within the European Union internal market.

Before the EAA, accessibility regulation in Europe was fragmented. Each member state had its own rules, creating an inconsistent patchwork that made it difficult for businesses to operate across borders and left many people with disabilities without consistent protections. The EAA was designed to solve this problem by creating a single set of accessibility requirements that apply uniformly across all 27 EU member states plus the European Economic Area (EEA) countries.

The scope of the EAA is deliberately broad. It covers not only digital services like websites and mobile applications but also physical products such as computers, smartphones, tablets, e-readers, self-service terminals (ATMs, ticketing machines, check-in kiosks), and consumer equipment used for electronic communications and audiovisual media services. This means the EAA affects manufacturers, importers, distributors, and service providers across nearly every sector of the economy.

The EAA should not be confused with the earlier Web Accessibility Directive (WAD), Directive (EU) 2016/2102, which applies exclusively to public sector websites and mobile applications. The EAA extends accessibility obligations to the private sector, covering a much wider range of products and services. Together, the two directives create a comprehensive regulatory framework: the WAD for government digital services and the EAA for commercial products and services.

Key Dates and Timeline

The EAA follows a phased implementation timeline that businesses must understand to plan their compliance efforts effectively.

April 2019 -- The European Parliament and Council adopted Directive (EU) 2019/882, the European Accessibility Act. The directive entered into force 20 days after its publication in the Official Journal of the EU.

June 28, 2022 -- Deadline for all EU member states to transpose the EAA into their national legislation. Each country was required to adopt the laws, regulations, and administrative provisions necessary to comply with the directive. By this date, the EAA became part of the national legal framework in each member state, though the specific implementing legislation varies by country.

June 28, 2025 -- The enforcement date. From this date, all new products placed on the EU market and all services provided to EU consumers must comply with the accessibility requirements set out in the EAA and the corresponding national transposition laws. Market surveillance authorities in each member state began actively monitoring and enforcing compliance. This is the date that most businesses need to treat as their hard deadline.

June 28, 2030 -- The end of the transitional period for products and services that were already on the market before June 28, 2025. Service providers that were using products lawfully before the enforcement date may continue to use them until this date. After June 28, 2030, all products and services in the EU market must meet the accessibility requirements regardless of when they were first introduced.

For businesses that have not yet started their compliance journey, the enforcement date has already passed. The time to act is now, not at some future date. Organizations still working toward compliance should prioritize the highest-impact changes and document their remediation roadmap to demonstrate good faith efforts.

Who Must Comply?

The EAA applies to economic operators that place covered products on the EU market or provide covered services to consumers in the EU. This includes four categories of economic operators: manufacturers, who design and produce products; importers, who bring products from outside the EU into the EU market; distributors, who make products available on the market through the supply chain; and service providers, who offer services directly to consumers.

The obligations for each category vary. Manufacturers bear the primary responsibility for ensuring their products meet accessibility requirements. Importers must verify that the manufacturer has carried out the appropriate conformity assessment procedures. Distributors must check that the product bears the required CE marking and is accompanied by the necessary documentation. Service providers must ensure that they design and provide their services in accordance with the accessibility requirements.

Products and Services Covered

The EAA covers a specific list of products and services defined in Article 2 of the directive. The products covered include: computer hardware systems and their operating systems, including desktops, laptops, tablets, and smartphones; self-service terminals such as ATMs, payment terminals, ticketing machines, check-in kiosks, and interactive information terminals; consumer equipment used for electronic communication services, including routers and modems; consumer equipment used for accessing audiovisual media services, such as smart TVs and streaming devices; and e-readers.

The services covered include: electronic communications services, including telephony and messaging; services providing access to audiovisual media, such as streaming platforms and electronic program guides; elements of passenger transport services (websites, mobile apps, electronic ticketing, real-time travel information) for air, bus, rail, and waterborne transport; banking services for consumers, including online banking, payment accounts, and payment services; e-books and dedicated e-book software; and e-commerce services, meaning any service that allows consumers to purchase products or services online.

The e-commerce category is particularly significant because it means that virtually every online store or marketplace serving EU consumers falls within scope. If your business sells products or services online to customers in the EU, the EAA applies to your website and purchasing flows.

Micro-Enterprise Exemption

The EAA provides a limited exemption for micro-enterprises, but only for services. A micro-enterprise is defined as a business that employs fewer than 10 people and has an annual turnover or annual balance sheet total that does not exceed 2 million euros. Both conditions must be met simultaneously.

If a micro-enterprise provides services covered by the EAA, it is exempt from the accessibility requirements for those services. However, this exemption does not extend to products. If a micro-enterprise manufactures, imports, or distributes products covered by the EAA, such as self-service terminals or consumer electronics, it must still ensure those products meet the accessibility requirements.

Additionally, member states are encouraged to provide tools and guidance to help micro-enterprises understand and voluntarily adopt accessibility practices. Some member states may also implement additional proportionality measures in their national transposition laws. Businesses near the micro-enterprise thresholds should monitor their size carefully, as exceeding either threshold would bring them into full scope.

What the EAA Requires

Unlike some accessibility regulations that reference a specific version of a technical standard, the EAA takes a principles-based approach. Annex I of the directive defines functional accessibility requirements that describe what the end result should be, not how to achieve it technically. Products and services must be designed and produced to maximize their foreseeable use by people with disabilities.

For products, the requirements address the provision of information (instructions, labeling, warnings) in multiple accessible formats, the design of the user interface and physical functionality to accommodate people with various disabilities, and the packaging and associated documentation.

For services, the requirements focus on ensuring that the service is provided in a manner that allows people with disabilities to perceive, operate, and understand it. Websites, mobile applications, and other digital interfaces must be perceivable, operable, understandable, and robust -- language that directly mirrors the POUR principles of WCAG.

EN 301 549 and the WCAG Connection

While the EAA itself does not cite WCAG by name, the practical path to compliance for digital products and services runs through the European harmonized standard EN 301 549 (Accessibility requirements for ICT products and services). When a product or service conforms to a harmonized standard, it benefits from a presumption of conformity with the corresponding requirements of the directive.

EN 301 549 is the harmonized standard that provides this presumption of conformity for the EAA. For web content, EN 301 549 maps its requirements directly to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. The standard is being progressively updated to incorporate WCAG 2.2 criteria as well. This means that for any web-based service or digital interface, meeting WCAG 2.1 Level AA (or ideally WCAG 2.2 Level AA) is the most straightforward path to demonstrating EAA compliance.

EN 301 549 also covers requirements beyond web content, including software, hardware, documentation, and support services. For organizations that offer digital products or services, understanding the full scope of EN 301 549 is essential, as WCAG alone may not cover all applicable requirements. If your product includes native mobile applications, desktop software, or embedded systems, the relevant clauses of EN 301 549 beyond the web content sections will apply. For a detailed understanding of the WCAG standard, see our complete WCAG 2.2 guide.

Functional Performance Criteria

EN 301 549 defines a set of functional performance criteria that describe the capabilities a product or service must support. These criteria provide a human-centered framework for understanding what accessibility means in practice. Products and services should support usage:

• Without vision -- The product or service must be fully operable by a person who cannot see, using assistive technologies such as screen readers or braille displays.
• With limited vision -- Content must be perceivable and operable for users with reduced visual acuity, including support for magnification, high contrast, and customizable text sizes.
• Without perception of color -- Information must not be conveyed solely through color. Color distinctions must be supplemented with text labels, patterns, or other non-color indicators.
• Without hearing -- Audio content must have text-based alternatives such as captions, transcripts, or visual notifications.
• With limited hearing -- Audio quality must be sufficient and volume controls must be available. Visual complements to audio information should be provided where possible.
• Without vocal capability -- Interactions that require speech input must have alternative input methods available.
• With limited manipulation or strength -- Physical interactions must not require fine motor control, simultaneous actions, or significant physical force. Digital interfaces must support alternative input methods.
• With limited reach -- Physical products must be operable from various positions. Digital interfaces must not require physical gestures with extended reach.
• Minimizing photosensitivity triggers -- Content must not contain flashing elements that could trigger photosensitive seizures. This aligns with WCAG success criterion 2.3.1.
• With limited cognition -- Interfaces must be designed to minimize cognitive load, provide clear and consistent navigation, use plain language where possible, and support error prevention and recovery.

These functional performance criteria are used as a fallback when specific technical requirements in EN 301 549 do not fully address a particular use case. They ensure that the spirit of accessibility is maintained even in scenarios not explicitly covered by the detailed technical clauses.

Penalties for Non-Compliance

The EAA requires each EU member state to establish its own penalties for non-compliance, with the directive specifying that penalties must be "effective, proportionate and dissuasive." This means the specific fines, enforcement mechanisms, and consequences vary from country to country based on how each member state transposed the directive into national law.

Enforcement is carried out by market surveillance authorities designated by each member state. These authorities have the power to conduct inspections, request documentation, order corrective measures, and impose penalties. For products, enforcement actions can include ordering the withdrawal of non-compliant products from the market, prohibiting or restricting their sale, and requiring the manufacturer to bring products into compliance within a specified timeframe.

For services, surveillance authorities can order service providers to modify their services to meet accessibility requirements, suspend non-compliant services, and impose financial penalties. The financial penalties in some member states can be substantial. For example, Germany has established fines of up to 100,000 euros for certain violations, while other member states have adopted penalty frameworks that scale with the severity and duration of the non-compliance and the size of the business.

Beyond direct financial penalties, non-compliance carries significant reputational risk. As awareness of digital accessibility grows among consumers and advocacy organizations, businesses that fail to meet their obligations under the EAA face negative publicity, loss of customer trust, and potential discrimination complaints. The combination of regulatory enforcement, financial penalties, and reputational damage makes a strong case for proactive compliance.

EAA vs. Web Accessibility Directive

The European Accessibility Act and the Web Accessibility Directive (WAD) are separate but complementary pieces of EU legislation. Understanding how they relate to each other is important for organizations that may fall under one or both.

The Web Accessibility Directive, Directive (EU) 2016/2102, was adopted in October 2016 and applies exclusively to public sector bodies. It requires that the websites and mobile applications of public sector organizations across the EU meet accessibility requirements based on the EN 301 549 standard. The WAD also requires public sector bodies to publish an accessibility statement, respond to user feedback on accessibility issues, and undergo regular monitoring by designated national bodies.

The European Accessibility Act, adopted three years later, extends accessibility requirements to the private sector. Its scope is broader, covering not only digital services but also physical products. The EAA does not require accessibility statements in the same way as the WAD, but it does require manufacturers to draw up a declaration of conformity and affix the CE marking to compliant products.

Both directives reference EN 301 549 as the relevant harmonized standard for web and digital accessibility, which in turn references WCAG. This means the technical baseline for web accessibility is consistent across both directives. An organization that achieves WCAG 2.1 Level AA conformance for its web content is well-positioned to meet the digital accessibility requirements of both the WAD and the EAA.

In practice, the two directives coexist without conflict. A public university complies with the WAD for its website and mobile app. A private e-commerce company complies with the EAA for its online store. A bank that serves both government clients and consumers may need to be aware of both frameworks depending on the specific products and services it offers.

EAA and Non-EU Businesses

One of the most important aspects of the European Accessibility Act is its territorial application. The EAA applies to products and services that are placed on the EU market or provided to consumers in the EU, regardless of where the business is headquartered. This extraterritorial reach is similar in principle to the General Data Protection Regulation (GDPR), which applies to any organization that processes the personal data of EU residents, regardless of the organization's location.

For businesses outside the EU, this means that if you sell products to customers in the EU through your own e-commerce website or through marketplaces operating in the EU, or if you provide digital services (such as SaaS platforms, online banking, or streaming services) accessible to EU consumers, the EAA applies to you. The fact that your company is incorporated in the United States, the United Kingdom, Canada, Brazil, or any other non-EU country does not exempt you from the requirements.

In practical terms, non-EU businesses should evaluate whether they have EU customers or actively market to the EU. If the answer is yes, they should treat EAA compliance as a legal obligation, not an optional best practice. The enforcement mechanisms may be more challenging to apply across borders, but the trend in EU regulation is toward stronger cross-border enforcement, and non-compliant businesses risk having their products restricted from the EU market.

Many international businesses are already familiar with this model from GDPR compliance. The EAA follows the same logic: if you want access to the EU market, you play by the EU's rules. For organizations that already meet WCAG 2.1 Level AA for their web properties, the additional effort to achieve EAA compliance may be relatively modest. For those starting from scratch, the investment is significant but necessary to maintain access to one of the world's largest consumer markets.

How to Get Started with EAA Compliance

Achieving EAA compliance is a structured process that requires commitment across multiple departments, from product development and design to legal and marketing. The following four-step framework provides a practical roadmap for organizations at any stage of their compliance journey.

Step 1: Determine If You Are in Scope

The first step is to determine whether your organization falls within the scope of the EAA. Review the list of covered products and services in Article 2 of the directive and compare it against your product and service portfolio. Ask the following questions: Do you manufacture, import, distribute, or sell products covered by the EAA (computers, smartphones, tablets, self-service terminals, e-readers)? Do you provide services covered by the EAA (e-commerce, banking, telecommunications, electronic communications, transport services, e-books, audiovisual media)? Do you have customers in the EU or sell products in the EU market? If you answer yes to any of these, you are likely in scope.

If your organization qualifies as a micro-enterprise (fewer than 10 employees and turnover below 2 million euros), you may be exempt from the service requirements, but you should verify this against the specific national transposition law in each EU member state where you operate. Remember that the micro-enterprise exemption does not apply to products.

Step 2: Audit Your Digital Products

Once you have confirmed that you are in scope, conduct a thorough accessibility audit of your digital products and services. For web-based services, this means evaluating your websites and web applications against WCAG 2.1 Level AA (the standard referenced by EN 301 549). Start with automated scanning to establish a baseline. You can scan your website for EAA compliance using our free accessibility checker to get an instant report of issues that need attention.

Automated scanning is a critical first step, but it is not sufficient on its own. As with WCAG 2.2 compliance, automated tools typically detect 30 to 40 percent of accessibility issues. Complement your automated audit with manual expert testing using assistive technologies (screen readers, keyboard-only navigation, magnification tools) and, where possible, user testing with people with disabilities.

For non-web products (mobile applications, desktop software, hardware, self-service terminals), audit against the relevant sections of EN 301 549 that apply to your product category. Document every finding with severity ratings, affected user groups, and the specific requirements that are not met.

Step 3: Remediate and Document

Based on your audit findings, create a prioritized remediation plan. Address the most severe barriers first, those that completely prevent access for certain user groups, followed by issues that create significant difficulties, and then less critical improvements. Organize your remediation work by product or service line and assign clear ownership for each task.

Documentation is a critical part of EAA compliance. Manufacturers must prepare technical documentation demonstrating how their products meet the accessibility requirements, draw up an EU declaration of conformity, and affix the CE marking. Service providers must prepare information explaining how their services meet the accessibility requirements and make this information available to the public.

For digital services, consider creating a detailed accessibility statement that describes your conformance level, known limitations, and the specific standards you have tested against. While the EAA does not mandate an accessibility statement in the same way as the Web Accessibility Directive, having one demonstrates transparency and can serve as evidence of good faith compliance efforts.

Step 4: Establish Ongoing Monitoring

Accessibility is not a one-time project but an ongoing commitment. Every new feature, content update, design change, or third-party integration can introduce new accessibility barriers. To maintain compliance over time, establish a continuous monitoring program.

Integrate automated accessibility scanning into your development pipeline (CI/CD) to catch regressions before they reach production. Schedule regular manual audits, at minimum annually, with more frequent checks for high-traffic or high-impact pages. Train your development, design, content, and QA teams on accessibility best practices so that accessibility is built in from the start rather than retrofitted at the end.

Establish a feedback mechanism that allows users to report accessibility issues and ensure that reports are triaged and addressed promptly. Monitor changes in the regulatory landscape, including updates to EN 301 549 and national implementing legislation, so that your compliance program stays current. Learn more about how our scanner works and how it can support your ongoing monitoring efforts.

Frequently Asked Questions

When did the European Accessibility Act take effect?

The EAA (Directive 2019/882) was adopted in April 2019 and required member states to transpose it into national law by June 28, 2022. Enforcement began on June 28, 2025, meaning all new products and services on the EU market must now meet the accessibility requirements. Products and services already on the market have a grace period until June 28, 2030.

Does the European Accessibility Act apply outside the EU?

Yes. The EAA applies to any business that places products on the EU market or provides services to consumers in the EU, regardless of where the business is headquartered. This territorial application is similar to the GDPR. Businesses in the United States, the United Kingdom, or any other non-EU country that serve EU customers must comply.

What is the difference between the EAA and the Web Accessibility Directive?

The Web Accessibility Directive (2016/2102) applies to public sector websites and mobile apps. The European Accessibility Act (2019/882) applies to the private sector and covers a much broader range of products and services, including e-commerce, banking, consumer electronics, and transport. Both reference EN 301 549 as the harmonized standard, so the technical requirements for web accessibility are aligned.

What technical standard does the EAA reference?

The EAA defines functional accessibility requirements in its Annex I. The harmonized European standard EN 301 549 provides the presumption of conformity. For web content, EN 301 549 maps directly to WCAG 2.1 Level AA and is progressively incorporating WCAG 2.2. Meeting WCAG 2.1 Level AA is the practical baseline for EAA compliance for web-based services.

Are small businesses exempt from the European Accessibility Act?

Micro-enterprises (fewer than 10 employees and annual turnover under 2 million euros) are exempt for services only. The exemption does not apply to products. If a micro-enterprise manufactures or distributes covered products, it must still comply. Explore our accessibility blog for more guides on compliance strategies and regulatory updates.