Does the European Accessibility Act (EAA) require existing products to be compliant by 2030. It does not.
Generally, the EAA only applies to new products placed in the market after June 28, 2025.
Disclaimer: This post is our interpretation of the EAA and does not constitute legal advice. Consult your counsel on EAA compliance.
The Misconception
You may come across states such as:
“There’s a 5-year grace period / grace period for existing products that ends on June 2030.”
“Legacy systems have until 2030 to achieve EAA compliance.”
“All covered products must be accessible by 2030, regardless of when they were introduced.”
However, these statements are incorrect.
What the EAA Actually Says
The European Accessibility Act treats products and services differently. For products, the EAA is entirely forward-looking. Article 2(1) of the directive clearly states: “This Directive applies to the following products placed on the market after 28 June 2025.” However, for services, Article 2(2) applies the directive to “services provided to consumers after 28 June 2025″—meaning existing services must become accessible, while existing products do not.
“This Directive applies to the following products placed on the market after 28 June 2025.”
This means:
- A smartphone sold in 2024 will not need to become EAA-compliant
- An ATM installed in 2023 will not need to be retrofitted for EAA compliance
The directive’s explanatory text reinforces this in Recital 102:
“The accessibility requirements of this Directive should apply to products placed on the market and services provided after the date of application of the national measures transposing this Directive, including used and second-hand products imported from a third country and placed on the market after that date.”
What Actually Happens in 2030
The June 28, 2030 date in Article 32 of the EAA refers to something entirely different: the end of a transitional period for service providers. Article 32(1) states:
“Member States shall provide for a transitional period ending on 28 June 2030 during which service providers may continue to provide their services using products which were lawfully used by them to provide similar services before that date.”
Here’s what really happens:
- Service providers can continue using non-compliant products they already had before June 28, 2025, until June 28, 2030.
- After 2030, service providers must replace non-compliant products with compliant ones when providing covered services.
- The products themselves do not need to become compliant – they simply can’t be used in covered services anymore.
The directive’s explanatory text in Recital 101 makes this crystal clear:
“In order to allow service providers sufficient time to adapt to the requirements of this Directive, it is necessary to provide for a transitional period of five years after the date of application of this Directive, during which products used for the provision of a service which were placed on the market before that date do not need to comply with the accessibility requirements of this Directive unless they are replaced by the service providers during the transitional period.”
A Practical Example
Consider a bank that installed ATMs in 2024. Under the EAA:
- 2025: New ATMs placed on the market must be EAA-compliant
- 2025-2030: The bank can continue using their 2024 ATMs for banking services
- 2030: The bank must stop using the 2024 ATMs for banking services (they must replace them with compliant models)
- Never: The 2024 ATMs themselves don’t need to be made compliant
The bank doesn’t retrofit the old ATMs – they replace them with new, compliant ones.
The Self-Service Terminal Exception
For self-service terminals specifically, there’s an even longer transitional period. Article 32(2) provides:
“Member States may provide that self-service terminals lawfully used by service providers for the provision of services before 28 June 2025 may continue to be used in the provision of similar services until the end of their economically useful life, but no longer than 20 years after their entry into use.”
This means a self-service terminal installed in 2025 could potentially be used until 2045 — without ever becoming EAA-compliant.
Recital 101 explains the rationale:
“Given the cost and long life-cycle of self-service terminals, it is appropriate to provide that, when such terminals are used in the provision of services, they may continue to be used until the end of their economic life, as long as they are not replaced during that period, but not for longer than 20 years.”
The EAA Timeline
June 28, 2025:
- New products must be EAA-compliant when placed on the market
- All services (new and existing) must be EAA-compliant when provided to consumers
- Existing products remain exempt from compliance requirements
- Service contracts signed before this date can continue unchanged (max 5 years)
Conclusion
The EAA does not create a 2030 deadline for existing products to become compliant. Instead, it creates a transition timeline that allows businesses to replace non-compliant products with compliant ones over time.
Announcement: We’re releasing a never before seen product that will make EAA compliance much, much easier on July 7, 2025 on our YouTube channel @europeanaccessibilityact. You do not want to miss this.
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Legal Disclaimer: This post represents our interpretation and analysis of the European Accessibility Act (EAA) and related accessibility requirements and obligations but does not constitute legal advice. While we strive for accuracy, Directives and their interpretation may vary by EU member state and change over time. Consult with legal counsel regarding your specific situation.
Update: This article has been corrected to clarify that existing services must become accessible by June 28, 2025, with an exception only for pre-existing contracts.
