Manufacturers of new products and service providers (as well as distributors and importers) must be compliant with the European Accessibility Act (EAA) moving forward. Today is Saturday, June 28, 2025 and so, practically, the EAA goes into effect on Monday.
Here are the Big 3 things that all 4 covered economic operators now need to have in place:
- Know your administrative obligations and technical requirements under the Directive
- Take action to meet the obligations and requirements
- Fully document your compliance
The above bullet points apply to all new products placed in the market and all services provided from here on out. And, of course, there are many sub bullet points for those three general bullets. Here are the primary obligations / requirements for each economic operator distilled into key bullet points.
Disclaimer: This post is our interpretation of the EAA and does not constitute legal advice. Consult your counsel on EAA compliance.
Manufacturers
- Ensure accessibility compliance – Design and manufacture products in accordance with applicable accessibility requirements before placing them on the market
- Conduct conformity assessment – Draw up technical documentation and carry out conformity assessment procedures, including EU declaration of conformity and CE marking
- Maintain documentation – Keep technical documentation and EU declaration of conformity for 5 years after product placement on market
- Product identification and contact details – Ensure products bear identification numbers and provide clear manufacturer contact information on products or packaging
- Post-market surveillance – Monitor compliance, take corrective measures when non-compliance is identified, and cooperate with authorities on enforcement actions
- Fundamental alteration/disproportionate burden – Document assessment if relying on Article 14 exceptions
Importers
- Verify compliance before import – Ensure conformity assessment procedures have been completed by manufacturers and products comply with accessibility requirements
- Documentation verification – Verify CE marking, technical documentation, and required accompanying documents are present
- Product identification – Indicate their name and contact details on products or packaging in easily understood language
- Storage and handling compliance – Ensure storage and transport conditions don’t jeopardize accessibility compliance
- Post-market monitoring – Take corrective action for non-compliant products, maintain registers of non-compliance, and cooperate with market surveillance authorities
Distributors
- Due care verification – Verify CE marking and required documentation before making products available on market
- Non-compliance prevention – Not make products available if they believe products don’t comply with accessibility requirements
- Proper handling – Ensure storage and transport conditions don’t jeopardize accessibility compliance while under their responsibility
- Reporting obligations – Inform manufacturers/importers and market surveillance authorities of non-compliant products
- Authority cooperation – Provide information and cooperate with authorities on corrective actions for non-compliant products
Service Providers
- Accessibility compliance – Ensure services comply with applicable accessibility requirements in Annex I (Note: microenterprises providing services are fully exempt per Article 4(5))
- Documentation per Annex V – Prepare and maintain information explaining how services meet accessibility requirements, available in written and oral formats, kept for as long as service operates
- Fundamental alteration/disproportionate burden assessment – Conduct and document assessments per Article 14 if claiming exemption
- Assessment documentation – Keep assessment results for 5 years from last service provision, renew assessments when service changes or every 5 years
- Notification obligations – Inform authorities when relying on disproportionate burden exemptions (except microenterprises)
- Corrective action – Take measures to address non-compliance and cooperate with authorities on enforcement
- Ongoing compliance procedures – Ensure procedures are in place so service provision remains in conformity with accessibility requirements
Important Transitional Provisions
- Existing service contracts – Contracts signed before June 28, 2025 can continue unchanged until expiration (maximum 5 years)
- Products used in service delivery – Products lawfully used before June 28, 2025 can continue in use until June 28, 2030
- Self-service terminals – Can continue until end of economic life (maximum 20 years from entry into use)
Simple Platform
To help economic operators understand all of the detailed obligations and technical requirements and chart compliance progress, we built the EAA app.
This app enables each economic operator to focus only on their requirements and obligations. Once a role is selected, each operator can clearly see what their to-do checklist is. They can also:
- track progress
- write notes in a comment log under each item
- ask AI to help for each item
- invite other users to edit the checklist
- upload documentation
- invite other users in read-only mode
There’s no other dedicated software or platform on the market for EAA compliance. We’ve studied the EAA for several months and built this app specifically to streamline compliance efforts to be as easy or as simple as possible.
The AI feature is especially nice because now your team has pre-prompted guidance for each to-do item.
Contact us to find out more about how we can help your organization with compliance.
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.
