The European Accessibility Act (EAA) has different requirements for products and services. In this post, we’ll cover the primary takeaways for service providers. Before we get into the details, here’s an overview that will make sense of the requirements.
The EAA has two layers of requirements for service providers:
- The general requirements that all services must meet, covering things like:
- Making information accessible through multiple sensory channels
- Ensuring text is readable and properly formatted
- Making websites and apps accessible
- Providing accessible support services
- Additional requirements for seven specific service types because they are essential services where accessibility is particularly crucial:
- Electronic communications (including emergency services)
- Audiovisual media services
- Long-distance Transport (air, bus, rail, waterborne)
- Local Transport (Urban, suburban, regional)
- Consumer banking
- E-books
- E-commerce
So if you’re operating in one of these seven sectors, you need to:
- Meet all the general accessibility requirements and
- Meet these additional sector-specific requirements because they’re critical services where accessibility barriers could significantly impact people’s lives
For example, a banking service can’t just make their website is WCAG conformant and their support is accessible – they also need to ensure their security and payment systems are accessible because banking is an essential service that everyone needs to access.
This tiered approach recognizes that while all services need to be accessible, some services require extra attention to specific accessibility features due to their importance in daily life.
Now you have a better feel for the requirements, let’s get into specifics. Note that we won’t cover every last detail so you still need to consult the Directive to ensure compliance.
We’ll first define what a service is and then we’ll break down the service accessibility requirements.
Table of Contents
EAA Service Definitions
Reader’s note: scroll to the end of this section to read our interpretation of the services definition which the EAA Directive makes unnecessarily complicated by referencing an Article that references another Article.
(3) ‘service’ means a service as defined in point 1 of Article 4 of Directive 2006/123/EC of the European Parliament and of the Council (27);
(4) ‘service provider’ means any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union;
Obviously, the definition for 3 is horrible because it only references us elsewhere and the footnote link doesn’t go to a page that defines service. Looking up point 1 of Article 4 of the referenced Directive, service is defined as
1) ‘service’ means any self-employed economic activity, normally provided for remuneration, as referred to in Article 50 of the Treaty;
This also isn’t helpful. Again, we have another referenced document and then there’s also the fact that they threw in “self-employed” economic activity.
Here’s the referenced Article 50 of the Treaty:
Article 57
(ex Article 50 TEC)
Services shall be considered to be “services” within the meaning of the Treaties where they are normally provided for remuneration, in so far as they are not governed by the provisions relating to freedom of movement for goods, capital and persons.
“Services” shall in particular include:
(a) activities of an industrial character;
(b) activities of a commercial character;
(c) activities of craftsmen;
(d) activities of the professions.
Without prejudice to the provisions of the Chapter relating to the right of establishment, the person providing a service may, in order to do so, temporarily pursue his activity in the Member State where the service is provided, under the same conditions as are imposed by that State on its own nationals.
Our Intrepretation of Services Under The EAA
Here’s a clear and practical definition of “services” for businesses and organizations aiming to comply with the European Accessibility Act (EAA):
Definition of Services under the EAA
A “service” is any paid, independent activity offered by a business or individual in the European Union (EU) market. Services encompass various sectors and are generally provided in exchange for remuneration. Specifically, this includes:
- Industrial services: such as manufacturing and production-related activities.
- Commercial services: including retail, wholesale, and other trade activities.
- Craft services: covering skilled trades and artisanal work.
- Professional services: such as medical, legal, financial, consulting, and other specialized fields.
Under the EAA, service providers must ensure that their services are accessible to people with disabilities. This applies to both physical and digital services offered in the EU market.
Note that service providers also have specific obligations under the EAA. For simplicity’s sake, we’ll keep this guide focused on the accessibility requirements for services.
Annex I, Section III: General Requirements
Now let’s go through the actual accessibility requirements for services to be EAA compliant:
The provision of services in order to maximise their foreseeable use by persons with disabilities, shall be achieved by:
(a) ensuring the accessibility of the products used in the provision of the service, in accordance with Section I of this Annex and, where applicable, Section II thereof;
This basically means that if a service relies on any products (such as devices, tools, or digital platforms), those products must themselves be accessible to people with disabilities.
In practical terms, any service provider must ensure that all products involved in delivering their service—whether a physical device, software, or digital platform—meet established accessibility standards to maximize usability for people with disabilities. This includes everything from accessible design (e.g., tactile and auditory feedback) to compatibility with assistive technologies (e.g., screen readers).
For service providers who rely upon products, you’ll want to read our EAA product accessibility requirements guide.
(b) providing information about the functioning of the service, and where products are used in the provision of the service, its link to these products as well as information about their accessibility characteristics and interoperability with assistive devices and facilities:
(i) making the information available via more than one sensory channel;
This requirement means that information provided by a service should be accessible in more than one way, so people with different sensory needs can access it.
For example:
- If a service provides information visually (like text on a screen), it should also offer an audio option (like text-to-speech) so that people who can’t see the text can still get the information.
- If there’s an audio announcement (like in a waiting room), there should also be a visual option (like a display screen) for people who can’t hear.
This ensures that everyone, regardless of sensory ability, can access the information.
(ii) presenting the information in an understandable way;
This requirement means that information provided by a service should be clear and easy to understand for everyone, including people with cognitive disabilities or language barriers.
For example:
- Use simple, plain language instead of complex terms or jargon, so the information is easier to grasp.
- Organize content logically, with clear headings and step-by-step instructions, so users can follow along without confusion.
- Provide symbols or images along with text to help explain concepts visually, making it accessible to people who might struggle with reading or understanding certain words.
The goal is to ensure that the information is straightforward and accessible for people with varying levels of understanding or learning styles.
(iii) presenting the information to users in ways they can perceive;
This requirement means that information provided by a service must be accessible in formats that people can detect or sense, regardless of their abilities.
For example:
- Provide text alternatives for audio: If there’s an audio message, also provide it in text form so people who are deaf or hard of hearing can read it.
- Offer audio descriptions or tactile options for visuals: For images, videos, or other visual content, include audio descriptions or tactile alternatives so people who are blind or have low vision can perceive the information.
- Ensure compatibility with assistive technologies: Make sure that the service’s digital content works well with screen readers, magnifiers, or other tools that help people with disabilities access information.
In short, this ensures that everyone, regardless of sensory limitations, has a way to perceive and access the information provided by the service.
(iv) making the information content available in text formats that can be used to generate alternative assistive formats to be presented in different ways by the users and via more than one sensory channel;
This requirement means that any information provided by a service should be available in text formats that can be easily converted into other accessible formats. Text is key because it can be adapted by assistive technologies into various forms for different needs.
For example:
- Text that can be read aloud by screen readers for people who are blind or have low vision.
- Text that can be converted into braille for users with braille displays.
- Text that can be enlarged or adjusted for those who need larger print or different contrast settings.
- Text that can be transformed into symbols or simpler language for users with cognitive disabilities.
By providing content in a flexible text format, the service enables users to adapt information to suit their specific needs and sensory preferences. This makes the information accessible in multiple ways without needing the service provider to create each format individually.
(v) presenting in fonts of adequate size and suitable shape, taking into account foreseeable conditions of use and using sufficient contrast, as well as adjustable spacing between letters, lines and paragraphs;
This requirement means that any text provided by the service must be easy to read under typical conditions by using accessible fonts, sizes, and layout features.
Specifically:
- Font Size and Shape: Use fonts that are large enough to read comfortably and in a simple, clear style. Avoid overly decorative fonts that are hard to decipher, especially at smaller sizes.
- Contrast: Ensure there’s enough contrast between text and background colors, so people with low vision or in dim lighting can still read the text easily.
- Adjustable Spacing: Allow for spacing adjustments between letters, lines, and paragraphs to improve readability. This helps people with visual or cognitive disabilities who may find densely packed text difficult to follow.
In essence, this makes text visually accessible for various users, even in challenging conditions like low light, small screens, or when users have specific visual needs.
(vi) supplementing any non-textual content with an alternative presentation of that content; and
This requirement means that any non-text content provided by a service—like images, videos, graphs, or symbols—must be accompanied by a text-based alternative.
For example:
- Images should have descriptive text (alt text) explaining what the image shows, so people who can’t see it can understand its content.
- Videos should include captions or transcripts for spoken content and audio descriptions for visual details, helping people who are deaf or blind to access the video’s information.
- Graphs or Charts should have summaries or explanations in text form to convey the essential information without needing to see the visual data.
This ensures that all users, including those with visual or hearing disabilities, can understand non-text content through accessible text alternatives.
(vii) providing electronic information needed in the provision of the service in a consistent and adequate way by making it perceivable, operable, understandable and robust;
This requirement ensures that any electronic information provided by a service is accessible and user-friendly, covering four key principles:
- Perceivable: Information should be presented in ways that users can detect through different senses. For example, text should be available in formats compatible with screen readers, images should have alt text, and videos should have captions.
- Operable: Users should be able to interact with the content without barriers. This means that all interactive elements, like buttons or links, must be easy to use with various devices and accessible for people using assistive tools (e.g., keyboard navigation or voice commands).
- Understandable: The information should be clear and easy to follow. This includes using straightforward language, logical organization, and avoiding complex jargon or confusing layouts.
- Robust: The information should work reliably across different devices and assistive technologies. This means ensuring compatibility with various operating systems, browsers, and accessibility tools, so users can access the content regardless of their setup.
Together, these principles aim to make electronic information within a service consistently accessible and usable for all people, regardless of their abilities or technology.
(c) making websites, including the related online applications, and mobile device-based services, including mobile applications, accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust;
This requirement basically looks like WCAG conformance to us. The end sentence references the POUR acronym which is an underlying staple to WCAG requirements. So if your website, web app, etc. is WCAG 2.1 AA conformant, you’ll meet this requirement.
(d) where available, support services (help desks, call centres, technical support, relay services and training services) providing information on the accessibility of the service and its compatibility with assistive technologies, in accessible modes of communication.
This requirement means that if a service offers any type of support—like help desks, call centers, technical support, relay services, or training—it should provide information about the service’s accessibility features and how it works with assistive technologies. Additionally, this support should be accessible in different ways so everyone can use it.
Specifically:
- Accessible Communication Modes: Support should be available through multiple channels that are accessible to people with disabilities, such as phone, text-based chat, video calls with sign language interpreters, or relay services.
- Information on Accessibility and Compatibility: Support staff should be knowledgeable about the service’s accessibility features and how it integrates with assistive technologies like screen readers or braille displays. They should be able to explain these features clearly and help users navigate any accessibility-related issues.
- Training on Accessibility: Training services should be available to help users understand how to use accessibility features, if needed, in formats accessible to users with disabilities.
The goal is to ensure that all users, including those with disabilities, can access support services easily and get the help they need to use the service effectively.
Annex I, Section IV: Requirements For Specific Services
The previous section outlines general requirements. This section outlines specific accessibility requirements for seven key service categories under the EAA. Think of the distinction here as we want you to pay special attention to these specific areas of accessibility when providing services because these are really important to ensuring access.
Here’s a breakdown:
a. Electronic Communications Services must:
- Provide real-time text alongside voice communication
- Include total conversation capabilities when video is offered
- Ensure emergency communications synchronize voice, text, and video (if used)
b. Audiovisual Media Services must:
- Have accessible electronic program guides (EPGs)
- Ensure proper transmission of accessibility features like subtitles, audio descriptions, and sign language
- Allow users to control how these features are displayed
c. Long-distance Transportation Services (air, bus, rail, water) must provide information about:
- Vehicle accessibility and infrastructure
- Assistance for disabled persons
- Smart ticketing and real-time travel updates
- Service status (like lift outages or staff availability)
d. Urban/Suburban/Regional Transport Services must:
- Ensure self-service terminals are accessible
e. Consumer Banking Services must:
- Make identification, electronic signatures, and payment services fully accessible
- Keep information at or below B2 language level (upper intermediate)
f. E-books must:
- Synchronize text and audio when both are present
- Work properly with assistive technologies
- Allow flexible navigation and content presentation
- Include accessibility information in metadata
- Ensure DRM doesn’t interfere with accessibility features
g. E-Commerce Services must:
- Share accessibility information about products being sold
- Ensure accessible identification, security, and payment functions
- Make electronic signatures and payment systems fully accessible
Summary
Service providers need to be aware of any underlying products they use in the carrying out of their service – those need to meet the EAA product accessibility requirements.
But the two sections service providers need to be concerned with the most are:
- general requirements
- requirements for specific services
If you don’t fall under any of the specific services, it’s just the general requirements that you need to focus on.
We offer accessibility services to help your organization with EAA compliance. Our services include audits, remediation, user testing, documentation, training, and consulting.
Feel free to contact us if you need help and we’ll be with you shortly.
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.
