The European Accessibility Act (EAA), Directive (EU) 2019/882, is often described as a law every employer must comply with. That is not what it does. The EAA is an internal-market law about certain products placed on the market and certain services provided to consumers. It sets accessibility requirements for the businesses that make, import, distribute or provide those products and services. It does not set requirements for the systems an organisation uses internally to run its workplace. In fact, the word "employer" does not appear in the directive.
This guide explains what the EAA means for you as an employer, what it does not require, and which rules apply to workplace accessibility instead. For a general overview of the Act itself, see our separate explainer on the European Accessibility Act.
Who the EAA applies to
Article 1 says the purpose of the directive is to approximate national accessibility requirements "for certain products and services" so that diverging rules do not become barriers to the internal market.
Its obligations fall on economic operators, which the directive defines as "the manufacturer, the authorised representative, the importer, the distributor or the service provider". Article 4 requires Member States to ensure that economic operators only place on the market products, and only provide services, that meet the accessibility requirements in Annex I.
The scope is set out as closed lists in Article 2:
- Products placed on the market after 28 June 2025, such as consumer computers and operating systems, payment terminals, ATMs, ticketing and check-in machines, consumer smartphones and similar terminal equipment, and e-readers.
- Services provided to consumers after 28 June 2025, such as electronic communications services, access to audiovisual media services, elements of passenger transport services, consumer banking services, e-books and e-commerce services.
A consumer is defined as a person who buys the product or receives the service "for purposes which are outside his trade, business, craft or profession". A service provider is someone who provides a service, or offers to provide it, "to consumers in the Union".
When an employer is also covered
Being an employer does not bring an organisation into scope. Being an economic operator for a listed product or service does. A bank that offers consumer banking services, an online shop, a telecoms operator or a passenger transport company is covered for those consumer-facing services, whatever its role as an employer. The obligations attach to the product or service offered to the public, not to the organisation's staff systems.
What is not in scope: internal workplace systems
HR and payroll software, intranets, learning management systems, staff self-service kiosks and time-recording terminals are not on the Article 2 lists when they are used internally by employees. Employees using them are not acting as consumers within the directive's definition. The EAA therefore creates no obligation for an employer to make these internal systems conformant.
That does not leave workplace accessibility unregulated — other laws cover it.
What does apply to workplaces
Reasonable accommodation under Directive 2000/78/EC
Council Directive 2000/78/EC establishes a general framework for equal treatment in employment and occupation. It applies to both the public and private sectors, including recruitment, working conditions and vocational training.
Article 5 requires reasonable accommodation: employers "shall take appropriate measures, where needed in a particular case, to enable a person with a disability to have access to, participate in, or advance in employment, or to undergo training", unless this would impose a disproportionate burden. Recital 20 gives examples, including adapting premises and equipment, patterns of working time, the distribution of tasks, or the provision of training.
In practice, this is where an inaccessible internal system becomes a legal issue: if a disabled employee or applicant cannot use your HR portal or learning platform, the question is whether you have taken appropriate measures for that person.
The Web Accessibility Directive for public sector bodies
Directive (EU) 2016/2102 requires Member States to ensure that the websites and mobile applications of public sector bodies meet its accessibility requirements. It excludes content of extranets and intranets published before 23 September 2019 until those websites undergo a substantial revision. Recital 34 also notes that Member States may extend the directive to intranet or extranet websites used in the workplace. Public sector employers should therefore check how their national law treats their intranets.
National law
Member States implement the employment framework in their own legislation, and some go further. In Ireland, for example, the Irish Human Rights and Equality Commission explains that under the Employment Equality Acts, employers must make "reasonable accommodation" so that people with disabilities can do their job or apply for one, unless the measures would be a disproportionate burden. Its examples include sign language interpreters, remote work for medical needs, redistributing physical tasks and making premises wheelchair accessible.
Exemptions and the disproportionate-burden assessment under the EAA
If your organisation does provide covered products or services, two different mechanisms can apply.
Microenterprises providing services are exempt. Article 4 exempts microenterprises providing services from the service accessibility requirements. A microenterprise is an enterprise that employs fewer than 10 persons and has an annual turnover or balance sheet total not exceeding EUR 2 million. Microenterprises dealing with products are not exempt in the same way, but they do not have to document a disproportionate-burden assessment.
Any economic operator can rely on the disproportionate-burden or fundamental-alteration exception — but only after an assessment. Under Article 14, the requirements apply only to the extent that compliance does not fundamentally alter the product or service or impose a disproportionate burden. Economic operators must carry out the assessment using the criteria in Annex VI, document it and keep the results for five years. Service providers must renew it when the service changes, when the authorities ask, and in any event at least every five years. An operator that receives outside funding to improve accessibility cannot rely on the disproportionate-burden exception. Even when it applies, the product or service should be made as accessible as possible.
Where things stand now
Member States had to adopt national laws by 28 June 2022 and apply them from 28 June 2025, so the EAA's requirements now apply to covered products and services. Some transitional rules are still running:
- Member States must provide a transitional period ending on 28 June 2030, during which service providers may keep using products they lawfully used to provide similar services before that date.
- Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date.
- Member States may allow self-service terminals lawfully used before 28 June 2025 to stay in service until the end of their economically useful life, but no longer than 20 years after they entered into use.
The practical point: buy accessible
Even though the EAA does not regulate your internal systems, it changes what is on the market. Covered products such as computers, operating systems and payment terminals must meet the EAA requirements when placed on the market. Choosing conformant products and asking suppliers about accessibility is a voluntary but effective way to reduce barriers for your own staff — and makes it easier to meet your reasonable-accommodation duties.
For public buyers, Article 24 states that for products and services within the EAA's scope, its accessibility requirements constitute mandatory accessibility requirements under the EU public procurement directives.
Key takeaways
- The EAA regulates listed products and consumer services, and the economic operators who supply them — not employers as such.
- Internal workplace systems are not in its scope.
- Workplace accessibility is governed by reasonable accommodation under Directive 2000/78/EC and national law, and, for public sector bodies, by the Web Accessibility Directive.
- Microenterprises providing services are exempt; other operators can claim a disproportionate burden only after a documented assessment.
- The EAA has applied since 28 June 2025, with a transitional period to 28 June 2030 and, where Member States allow it, longer for some self-service terminals.
- Buying EAA-conformant products is a simple, voluntary way to improve accessibility at work.