The European Accessibility Act (EAA) requires all services provided to consumers after June 28, 2025 to be accessible—including services that have been operating for years. This means your existing e-commerce platform, banking app, or digital service must meet EAA accessibility requirements when serving EU consumers after the deadline.
Let’s examine what the directive actually says and what this means for your business.
Disclaimer: This post is our interpretation of the EAA and does not constitute legal advice. Consult your counsel on EAA compliance.
What the Directive Says
The key language comes from Article 2(2) of the EAA:
“Without prejudice to Article 32, this Directive applies to the following services provided to consumers after 28 June 2025”
Notice the critical difference from how products are treated. For products, Article 2(1) states:
“This Directive applies to the following products placed on the market after 28 June 2025”
The distinction is crucial:
- Products: “placed on the market” (a one-time event)
- Services: “provided to consumers” (an ongoing activity)
This means that any service provision occurring after June 28, 2025 must comply with accessibility requirements, regardless of when the service was first launched.
Confirmation from Article 13
Article 13(3) reinforces this ongoing obligation:
“Without prejudice to Article 32, service providers shall ensure that procedures are in place so that the provision of services remains in conformity with the applicable accessibility requirements.”
The phrase “remains in conformity” clearly indicates that services must maintain compliance continuously, not just at launch.
What This Means in Practice
If you operate any of these covered services, they must be accessible starting June 28, 2025:
- E-commerce websites and mobile apps
- Consumer banking services (online banking, payment services)
- Electronic communications services
- E-books and dedicated software
- Passenger transport services (websites, apps, ticketing systems)
- Services providing access to audiovisual media
Example Scenarios:
Banking App launched in 2020: Must be fully accessible for any use after June 28, 2025
E-commerce website operating since 2015: Must meet all accessibility requirements when customers use it after the deadline
Streaming service platform from 2018: Must comply with accessibility standards for all consumer interactions after June 28, 2025
Important Exceptions
While existing services must comply, there are several key exceptions:
1. Microenterprise Exemption
Article 4(5) provides a complete exemption:
“Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements.”
2. Existing Service Contracts
Article 32(1) states:
“Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date.”
This means B2B contracts or long-term consumer contracts signed before the deadline can continue unchanged until June 28, 2030 at the latest.
3. Products Used in Service Delivery
Also from Article 32(1):
“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.”
This allows service providers to continue using non-compliant hardware, servers, or other products in their service delivery until 2030.
4. Self-Service Terminals
Article 32(2) provides an even longer transition:
“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.”
The Fundamental Difference from Products
Recital 102 helps clarify the distinction:
“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”
For products, it’s about market entry. For services, it’s about ongoing provision. This reflects the fundamental nature of services—they’re not manufactured once and sold; they’re continuously delivered to consumers.
What Service Providers Must Do
If you provide covered services to EU consumers, you must:
- Ensure accessibility by June 28, 2025 for all service provisions after that date
- Prepare documentation per Annex V explaining how your service meets accessibility requirements
- Maintain ongoing compliance through procedures that ensure continued conformity
- Keep records of your accessibility efforts and documentation for as long as the service operates
Conclusion
The EAA’s approach to services is straightforward but strict: if you’re providing a service to consumers after June 28, 2025, it must be accessible.
Are you ready to start working towards full compliance?
We’d love to help — contact us and we’ll be right back with you.
