The European Accessibility Act (EAA) does not apply to all websites. Let’s take a look and see what websites the EAA covers.
Covered Websites
The EAA applies to websites that provide specific categories of consumer services. These include e-commerce, transport, audiovisual media access, and banking.
Ecommerce Websites
If a website allows consumers to shop online, it must meet accessibility requirements. The Directive explicitly states:
“This Directive includes obligations to ensure that e-commerce websites are accessible.” (Recital 35)
It defines e-commerce broadly as services provided:
“at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract.” (Article 3(30))
This captures most online retail platforms.
Transport Services
Transport operators offering services to the public—such as rail, air, or bus—are also covered. This includes their websites and mobile applications. The Directive notes that accessibility rules apply to:
“websites, mobile device-based services including mobile applications developed or made available by operators of passenger transport services within the scope of this Directive or on their behalf, electronic ticketing services, electronic tickets and interactive self-service terminals.” (Recital 33)
The scope includes pre-trip planning, real-time travel updates, and ticket purchases.
Audiovisual Media Access
If a service provides access to audiovisual content, such as streaming video or TV services, its platforms must also be accessible. This includes:
“websites, online applications, set-top box-based applications, downloadable applications, mobile device-based services, digital television services and connected television services.” (Recital 31)
Consumer Banking
Websites and applications that allow consumers to manage bank accounts, make payments, or apply for credit fall within the EAA. Annex I requires that accessibility be ensured for:
“consumer banking services, including identification methods, electronic signatures, security and payment services.“
Who Is Exempt?
Microenterprises
Small businesses are not required to comply if they meet the EU definition of a microenterprise: fewer than 10 employees and annual turnover or balance sheet total of less than €2 million.
The Directive clearly states:
“Microenterprises providing services shall be exempt from complying with the accessibility requirements… and any obligations relating to the compliance with those requirements.” (Article 4(5); Recital 70)
This exemption is intended to avoid imposing disproportionate burdens on very small businesses.
Excluded Content
Even for websites that are covered, some types of content do not have to meet accessibility requirements. According to Article 2(4), this includes:
- “Pre-recorded time-based media published before 28 June 2025“
- “Office file formats published before 28 June 2025“
- “Online maps and mapping services, provided that essential information is made accessible in an accessible digital manner“
- “Third-party content that is neither funded, developed by, nor under the control of, the economic operator concerned“
- “Archived content that is not updated or edited after 28 June 2025“
These carve-outs provide flexibility for legacy content and third-party integrations.
What About Government Websites?
Government and public-sector websites are not the main focus of the EAA. They are already regulated under another law—Directive (EU) 2016/2102. The EAA complements that law by covering private-sector operators in the same domains.
The Directive clarifies:
“Directive (EU) 2016/2102 already lays down obligations for public sector bodies providing transport services… to make their websites accessible.” (Recital 35)
Key Takeaway
The European Accessibility Act does not apply to all websites. It applies to websites offering specific consumer services, such as online retail, transport, banking, and audiovisual content. It excludes microenterprises providing services and allows exceptions for certain content types. For everything outside its defined scope, the law explicitly notes:
“For products and services not falling under the scope of this Directive, the accessibility requirements of this Directive are not binding.” (Recital 13)
Do you have a question about EAA compliance? Do you need help with accessibility?
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