The European Accessibility Act (EAA), Directive 2019/882/EU, became enforceable on 28 June 2025. It requires that key products and services meet accessibility standards. This article explains scope, obligations, and practical implications.
What Is the European Accessibility Act?
The European Accessibility Act (EAA), formally Directive 2019/882/EU of the European Parliament and of the Council, was adopted on 17 April 2019. It required member states to transpose its requirements into national law by 28 June 2022, with the accessibility requirements becoming enforceable for products and services placed on the market from 28 June 2025.
The EAA is the first EU-wide legislation to impose horizontal accessibility requirements across multiple product and service categories. It is designed to complement the Web Accessibility Directive (2016/2102/EU, which covers public sector websites and apps) and the EN 301 549 accessibility standard.
Why Was It Needed?
Before the EAA, accessibility requirements for private sector products and services varied substantially across EU member states. This fragmented landscape:
Created barriers for disabled people when crossing borders
Imposed compliance costs on businesses operating in multiple markets
Hindered the development of a single market in accessible products and services
The EAA harmonises requirements, so a product or service that meets EAA requirements in one member state should meet them across the EU.
What Is Covered?
Products
The EAA applies to the following product categories placed on the market after 28 June 2025:
Computers and operating systems
Smartphones and mobile phones (other than feature phones)
Television equipment with digital interactive capabilities
ATMs, ticketing machines, and check-in machines
Payment terminals
E-readers
Services
The EAA applies to the following services provided to consumers in the EU after 28 June 2025:
E-commerce services (online retail websites and apps)
What Does Accessibility Mean Under the EAA?
The EAA does not prescribe specific technical standards directly, but requires that covered products and services be:
Perceivable: information and user interface components presentable in multiple ways
Operable: interface operable by a range of users, including keyboard navigation
Understandable: information and operation understandable
Robust: content interpretable by assistive technologies
For digital products and services, these principles align directly with WCAG 2.1 Level AA (Web Content Accessibility Guidelines) — the de facto international standard.
For non-digital elements (physical terminals, built environments), the EAA references the EN 17161 accessibility design standard and product-specific harmonised European standards.
Who Must Comply?
The EAA applies to economic operators placing covered products on the EU market and service providers providing covered services to EU consumers — including non-EU companies operating in the EU market.
Microenterprise Exemption
Microenterprises (fewer than 10 employees and annual turnover/balance sheet under €2 million) providing services are exempt from the EAA. This exemption does not apply to products.
However, if a microenterprise supplies to larger businesses or public bodies that must comply, there may be commercial pressure to meet accessibility standards regardless of the formal exemption.
Disproportionate Burden
Where compliance would impose a fundamental alteration to the nature of the product/service, or a disproportionate burden on the operator, exemptions are available. The disproportionate burden assessment must:
Consider the net benefits of accessibility relative to cost
Document the assessment and the reasons for invoking the exemption
Be reviewed when circumstances change
This exemption is narrower than it appears: the EAA specifies that operators may not use it to justify blanket non-compliance, only specific elements of a product or service.
Enforcement and Penalties
Each EU member state must designate market surveillance authorities responsible for monitoring compliance and imposing penalties. Penalties vary by member state but must be:
Effective
Proportionate
Dissuasive
In practice, enforcement in 2025 is expected to focus initially on larger operators and higher-risk product/service categories (banking, e-commerce, transport).
Consumer redress: The EAA requires member states to ensure consumers can bring complaints and, where necessary, access legal redress.
Relationship With Other Standards and Directives
Framework
Scope
Overlap with EAA
Web Accessibility Directive (2016/2102/EU)
Public sector websites/apps
EAA extends similar requirements to private sector
EN 301 549
ICT accessibility standard
Referenced in both directives
WCAG 2.1 AA
Web accessibility guideline
Effective standard for digital EAA compliance
EU Disability Strategy 2021–2030
Broader disability rights
EAA is a key delivery vehicle
CRPD
International rights framework
EAA intended to advance CRPD Article 9 (accessibility)
Practical Checklist for Organisations
Immediate (if not already done):
Audit covered products/services against WCAG 2.1 AA
Review customer-facing digital interfaces (website, app, booking system) for accessibility
Assess ATMs, ticketing, and payment terminals if applicable
Check whether your organisation qualifies for the microenterprise exemption (services only)
Ongoing:
Document accessibility conformance statements for all covered products/services
Establish a process to receive and respond to accessibility complaints
Include accessibility requirements in procurement of new digital systems and third-party services
Train product, design, and development teams on EAA requirements
Compliance documentation:
Maintain records of accessibility assessments
If claiming disproportionate burden, document the assessment