The European Accessibility Act (EAA) sets mandatory administrative obligations and accessibility requirements for products and services across the EU. This guide provides economic operators with the essential framework to understand comply with the EAA.
| Key Point | What It Means for You |
|---|---|
| Compliance Date | The EAA is currently in effect for products placed on the market and services provided after June 28, 2025 |
| Core Principle | Products and services must be accessible to persons with disabilities through functional accessibility requirements |
| Documentation | Economic operators must maintain technical documentation, EU declarations of conformity, and assessment records for 5 years |
| Exemptions | Microenterprises providing services are exempt; fundamental alteration and disproportionate burden provisions apply to all |
| Technical Standards | Accessible.org recommends WCAG 2.1 AA or WCAG 2.2 AA as the technical standard for digital assets |
Table of Contents
Understanding the EAA Framework
The European Accessibility Act establishes a comprehensive framework for accessibility across the internal market. As stated in the Directive, “This Directive should establish mandatory accessibility requirements for products and services covered by it. For products and services not falling under the scope of this Directive, the accessibility requirements of this Directive are not binding.”
The EAA operates on functional accessibility requirements. The Directive specifies these requirements “should be formulated in terms of general objectives” while being “precise enough to create legally binding obligations and sufficiently detailed so as to make it possible to assess conformity.”
Products and Services Covered
Products Subject to EAA Requirements
The Directive applies to products placed on the market after June 28, 2025, including:
- Consumer general purpose computer hardware systems and their operating systems (desktops, notebooks, smartphones, tablets)
- Self-service terminals:
- Payment terminals
- ATMs
- Ticketing machines
- Check-in machines
- Interactive self-service terminals providing information
- Consumer terminal equipment with interactive computing capability for electronic communications
- Consumer terminal equipment for accessing audiovisual media services
- E-readers
Services Within Scope
Services provided to consumers after June 28, 2025 include:
- Electronic communications services (excluding machine-to-machine transmission)
- Services providing access to audiovisual media services
- Air, bus, rail and waterborne passenger transport services, including:
- Websites
- Mobile device-based services and mobile applications
- Electronic tickets and ticketing services
- Real-time travel information delivery
- Interactive self-service terminals
- Consumer banking services
- E-books and dedicated software
- E-commerce services
Economic Operator Obligations
Manufacturers
According to the EAA, manufacturers have the primary responsibility for product compliance. The Directive states: “The manufacturer having detailed knowledge of the design and production process is best placed to carry out the complete conformity assessment.”
Manufacturer obligations include:
- Ensuring products meet accessibility requirements when placed on the market
- Drawing up technical documentation per Annex IV
- Carrying out conformity assessment procedures
- Drawing up EU declaration of conformity
- Affixing CE marking to compliant products
- Keeping documentation for 5 years
- Taking corrective measures for non-compliant products
Importers
The EAA establishes that “Importers should ensure that products from third countries entering the Union market comply with this Directive.” Their obligations include:
- Only placing compliant products on the market
- Ensuring manufacturers have completed conformity assessments
- Verifying CE marking and required documentation
- Indicating their contact details on the product
- Keeping EU declaration of conformity for 5 years
- Maintaining a register of non-compliant products and complaints
Distributors
Distributors must verify products bear CE marking and required documentation before making them available. The Directive requires that “Distributors should ensure that their handling of the product does not adversely affect the compliance of the product with the accessibility requirements.”
Service Providers
Service provider obligations under the EAA include:
- Ensuring services meet applicable accessibility requirements
- Preparing information per Annex V explaining compliance
- Making information available in accessible formats
- Implementing procedures to maintain ongoing conformity
- Taking corrective measures for non-compliance
- Renewing disproportionate burden assessments every 5 years
Fundamental Alteration and Disproportionate Burden
The EAA provides important provisions for situations where full compliance would be unreasonable. Article 14 states: “The accessibility requirements referred to in Article 4 shall apply only to the extent that compliance does not require a significant change in a product or service that results in the fundamental alteration of its basic nature and does not result in the imposition of a disproportionate burden.”
Assessment Requirements
Economic operators must carry out and document assessments when relying on these provisions. The Directive requires keeping “all relevant results for a period of five years to be calculated from the last making available of a product on the market or after a service was last provided.”
The assessment must consider criteria in Annex VI. As the EAA notes: “Measures that would impose a disproportionate burden should be understood as measures that would impose an additional excessive organisational or financial burden on the economic operator.” Importantly, “Lack of priority, time or knowledge should not be considered to be legitimate reasons.”
Special Provisions for Microenterprises
Microenterprises receive specific consideration. The Directive recognizes that “The burden of complying with the accessibility requirements for microenterprises therefore, in general, takes a greater share of their financial and human resources.”
- Microenterprises providing services are fully exempt from EAA requirements
- Microenterprises dealing with products are exempt from documenting assessments (but must provide facts if requested)
Technical Requirements and Standards
The EAA establishes that “Products and services which are in conformity with harmonised standards or parts thereof the references of which have been published in the Official Journal of the European Union, shall be presumed to be in conformity with the accessibility requirements.”
For digital accessibility, Accessible.org’s EAA resources recommend implementing WCAG 2.1 AA or WCAG 2.2 AA as your technical standard. These standards provide specific, testable criteria for web content accessibility.
The Accessibility Tracker platform helps economic operators track their accessibility conformance and maintain the documentation required for EAA compliance. This systematic approach ensures you can demonstrate compliance when authorities request information.
Market Surveillance and Enforcement
The Directive establishes that “Member States are responsible for ensuring strong and efficient market surveillance of products in their territories.” Economic operators should be prepared for:
- Requests for documentation from market surveillance authorities
- Cooperation requirements for corrective actions
- Verification of conformity assessments, including fundamental alteration or disproportionate burden claims
For services, “Member States should check the compliance of services with the obligations of this Directive and should follow up complaints or reports related to non-compliance.”
Public Procurement Integration
The EAA integrates with public procurement directives. Article 24 states: “As regards the products and services referred to in Article 2 of this Directive, the accessibility requirements set out in Annex I thereto shall constitute mandatory accessibility requirements within the meaning of Article 42(1) of Directive 2014/24/EU and of Article 60(1) of Directive 2014/25/EU.”
This means EAA-compliant products and services meet public procurement accessibility requirements automatically.
Frequently Asked Questions
Q: When did the EAA requirements become mandatory?
A: The European Accessibility Act requirements apply to products placed on the market and services provided after June 28, 2025. The Directive is currently in effect.
Q: Does my small business need to comply with the EAA?
A: It depends on your business type and size. Microenterprises (fewer than 10 employees and annual turnover or balance sheet under €2 million) providing services are exempt. Microenterprises dealing with products must comply but have reduced documentation obligations. All other businesses must comply fully unless they can demonstrate fundamental alteration or disproportionate burden.
Q: What documentation do I need to maintain for EAA compliance?
A: Manufacturers must maintain technical documentation and EU declarations of conformity for 5 years. Service providers must prepare and maintain information explaining how services meet requirements. If you rely on disproportionate burden or fundamental alteration provisions, you must document and keep assessment results for 5 years. The Accessibility Tracker platform helps organize and store this documentation systematically.
Q: Can I claim disproportionate burden to avoid all EAA requirements?
A: No. The Directive clearly states that exceptions “should not go beyond what is strictly necessary” and you must still make products or services “as accessible as possible.” Additionally, if you receive funding specifically for improving accessibility, you cannot claim disproportionate burden. You must document your assessment and be prepared to justify it to authorities.
Q: What technical standard should I follow for digital accessibility?
A: While the EAA sets functional requirements, Accessible.org recommends following WCAG 2.1 AA or WCAG 2.2 AA as your technical standard for websites, mobile applications, and other digital assets. These internationally recognized standards provide clear, testable success criteria that align with EAA requirements.
Get Started
Do you need help with EAA Compliance? Contact us to ask about an audit or other services.
Our Accessibility Tracker platform also helps track EAA compliance. Sign up for a free plan at AccessibilityTracker.com.
