The European Accessibility Act: What Every EU Employer Needs to Know by June 2025
16 February 20266 min læsning
A practical guide to the European Accessibility Act (EAA) and its implications for employers — covering which products and services are affected, workplace system requirements, procurement obligations, enforcement, and how to prepare before the June 2025 deadline.
The European Accessibility Act: What Every EU Employer Needs to Know by June 2025
What Is the EAA?
The European Accessibility Act (Directive 2019/882) is an EU directive requiring accessibility of specified products and services placed on the EU market. Member states had until 28 June 2022 to transpose it into national law, with compliance required from 28 June 2025.
While the EAA primarily regulates products and services sold to consumers, it has profound implications for employers because the same products and services are used in workplaces.
What the EAA Covers
Products
Computers and operating systems: All hardware and software must meet accessibility requirements
Smartphones and tablets: Must be usable by people with sensory, cognitive, and motor impairments
Self-service terminals: ATMs, ticketing machines, check-in kiosks, and — critically — any self-service terminal in a workplace (canteen kiosks, meeting room booking screens, time-clock terminals)
E-readers: Must support accessible formats
Consumer equipment for telecommunications: Phones, video calls, messaging
Services
E-commerce: Online shops and marketplaces must be accessible
Telecommunications: Phone services, messaging, video calls
Transport: Websites, apps, ticketing, real-time information
Audiovisual media services: Streaming platforms, digital TV
E-books: Digital publications must support accessibility features
Tags
euaccessibility-tech
The Workplace Connection
Every product and service listed above is used in workplaces:
Employees use computers and smartphones daily
Many workplaces have self-service terminals (canteens, meeting rooms, security)
HR and payroll are increasingly e-commerce style platforms
Internal banking and expenses processes are digital
Workplace telecommunications (Teams, Zoom, phone systems) must be accessible
Training is increasingly delivered as audiovisual/e-learning content
Accessibility Requirements
The EAA specifies functional accessibility requirements based on the European Standard EN 301 549 (which incorporates WCAG 2.1 for web content):
Key Requirements
Perceivable: Information must be presentable in ways all users can perceive
- Text alternatives for images
- Captions for audio/video
- Sufficient colour contrast
- Content resizable without loss of function
Operable: Users must be able to operate the interface
- Keyboard accessibility (all functions reachable without a mouse)
- Sufficient time to complete tasks
- No content that triggers seizures
- Clear navigation and consistent interfaces
Understandable: Information and interface must be understandable
- Readable text (clear language, logical structure)
- Predictable behaviour
- Input assistance (error prevention and correction)
Robust: Content must be compatible with assistive technologies
- Screen reader compatibility
- Voice control support
- Alternative input device support
Product-Specific Requirements
Self-service terminals: Must have speech output, tactile indicators, large text options, hearing loop compatibility, and be reachable from a wheelchair
Computers: OS must include built-in accessibility features (screen reader, magnification, high contrast, voice control)
What Employers Must Do
1. Audit Workplace Technology
By June 2025, assess whether workplace systems comply with EAA requirements:
Self-service terminals: Do canteen kiosks, meeting room screens, and time clocks meet accessibility requirements? (Most currently do not.)
HR systems: Can your HRIS, payroll, and benefits platforms be operated by screen reader? Keyboard only? With voice control?
Learning platforms: Are e-learning modules captioned? Do they work with assistive technology?
Communication tools: Do your video conferencing, messaging, and phone systems support accessibility features?
Intranet: Does your corporate intranet meet WCAG 2.1 AA?
Document management: Are standard templates accessible? Can documents be read by screen readers?
2. Procurement Policy
Update procurement policies to require EAA compliance:
New purchases: All new technology, systems, and services must meet EN 301 549
Vendor assessment: Include accessibility requirements in RFPs and vendor evaluation criteria
VPAT/ACR: Request Voluntary Product Accessibility Templates from all technology vendors
Contract clauses: Include accessibility compliance as a contractual requirement with remediation obligations
Renewals: When existing contracts renew, add accessibility requirements
3. Remediate Existing Systems
For systems that cannot be immediately replaced:
Prioritise by impact: Focus first on systems used daily by many employees (HR, email, intranet)
Alternative access: Where a system cannot be made accessible, provide an accessible alternative pathway
Timeline: Create a remediation roadmap — the EAA allows a transition period for existing products/services until June 2030
Budget: Allocate specific budget for accessibility remediation
4. Build Internal Capability
Accessibility expertise: Hire or train staff in digital accessibility (IAAP certification available)
Developer training: All in-house developers trained in accessible development
Testing: Regular accessibility testing of workplace systems (automated + manual + user testing)
Governance: Assign accountability for workplace accessibility compliance
Enforcement
National Market Surveillance
Each member state designates a market surveillance authority
Authorities can inspect products and services, request evidence of compliance, and take enforcement action
Non-compliant products can be withdrawn from the market
Fines: Set by each member state — expected to be substantial
Employee Rights
The EAA strengthens the case for reasonable accommodation claims:
- If accessible technology exists (because the EAA requires it), employers cannot argue that accessibility is "unreasonable"
- "We couldn't find an accessible system" becomes less credible when the EAA mandates accessibility
Combined with the Employment Equality Directive, the EAA creates a powerful framework for workplace accessibility
The Disproportionate Burden Exception
The EAA includes a "disproportionate burden" exception for micro-enterprises (fewer than 10 employees, turnover under €2 million):
Micro-enterprises may be exempt from some requirements
This exception is narrow and requires documented justification
Medium and large employers cannot rely on this exception
Timeline and Preparation
Now (Before June 2025)
Complete workplace technology accessibility audit
Update procurement policies
Begin remediation of critical systems
Train IT and HR teams
June 2025
EAA enters force — all new products and services must comply
National enforcement begins
Start tracking compliance across workplace systems
2025–2030
Remediate existing systems on priority basis
Monitor vendor compliance and escalate non-compliance
Build accessibility into organisational culture (not just compliance)
June 2030
All products and services (including those already on the market before 2025) must comply
Full enforcement of accessibility requirements
Resources
European Commission: European Accessibility Act — ec.europa.eu/social/accessibility
EN 301 549: European Accessibility Standard — www.etsi.org
European Disability Forum: EAA implementation tracker
Web Accessibility Initiative (WAI): WCAG 2.1 guidelines
IAAP (International Association of Accessibility Professionals): Certification
Funka: European accessibility consulting and testing