The European Accessibility Act (EAA) (Directive 2019/882) is a landmark EU law that mandates accessibility for certain everyday products and services to ensure access to persons with disabilities. This directive applies to both private and public entities.
The EAA will improve access to public transport, banking services, computers, TVs, e-books, online shops, and more. For example, the EAA ensures that ATMs will have visual and audible signals indicating where to insert a bank card or where money is dispensed.
Let’s summarize the key takeaways from the European Accessibility in 3.5 minutes.
Table of Contents
What Are Covered Entities Required to Do?
There are several entities covered by the EAA and each have their own set of responsibilities. Let’s quickly breakdown the main responsibilities for the primary players:
- Product manufacturers must ensure products meet technical accessibility requirements
- Product manufacturers also have a list of administrative requirements (called obligations)
- Service providers must ensure services meet technical accessibility requirements
- Service providers also have a list of administrative requirements (called obligations)
- Importers and distributors must also meet administrative requirements (obligations)
There are many details for the responsibilities for each “economic operator” that are found in the Directive.
What Products and Services Are Covered by the EAA?
There are several products and services required. These are named under Article 2, Scope.
The scope includes, but is not limited to:
Products
- Computers and operating systems
- Smartphones and other communication devices
- TV equipment related to digital television services
- ATMs and payment terminals
- E-readers
- Ticketing and check-in machines
Services
- Phone services
- Banking services
- E-commerce
- Websites, mobile services, electronic tickets, and information sources for air, bus, rail, and waterborne transport services
- E-books
- Access to audiovisual media services (AVMS)
- Calls to the European emergency number 112
How Does the EAA Complement Existing Legislation?
The EAA works alongside other EU accessibility laws in a practical way. For example, while the Web Accessibility Directive covers public sector websites, the EAA covers private sector digital services. Similarly, existing transport and banking regulations already have some accessibility requirements – the EAA adds to these without replacing them. This means companies in these sectors need to meet both their existing accessibility obligations and the new EAA requirements.
The EAA complements, rather than amends, existing EU legislation on accessibility, especially in public procurement and EU structural funds.
This means that the EAA adds to the existing laws without changing them. For example, public authorities must now ensure that products and services they procure meet the EAA’s accessibility standards. Similarly, projects funded by the EU must also comply with these standards, ensuring that accessibility is considered in all stages of planning and implementation.
When is the Deadline for EAA Compliance?
The deadline for EAA compliance is June 28, 2025 so covered entities must ensure that new products and services are accessible. Member States can allow more time for compliance with specific rules, such as for self-service terminals.
The implementation timeline is flexible for certain situations. Services can keep using accessible products they already had in place before June 2025 until 2030. Self-service terminals like ATMs can stay in use until 2045 or until they reach the end of their economic life. However, any new products or major service changes after June 2025 must meet the new requirements right away.
Are Small Businesses Exempted from EAA Compliance?
Some microenterprises or small businesses (fewer than 10 employees) providing services are exempt from compliance, though they are encouraged to make their products and services accessible.
Even though small businesses are exempt, it is beneficial for them to adopt accessibility practices. Accessible products and services can attract more customers, including those with disabilities. Additionally, given the accessibility requirements for larger businesses, microenterprises will need to embrace accessibility to win contracts and compete.
Does the EAA Require WCAG Conformance?
The EAA does not require WCAG conformance but reading through Section III of Annex 1, it’s clear WCAG is a great reference for meeting the EAA technical requirements because (b)(vii) references the four principles of WCAG: perceivability, operability, understandability, and robustness.
Although the EAA doesn’t incorporate WCAG 2.1 AA or any another version, it does align with WCAG principles for web and mobile application accessibility. Thus, striving to meet the Web Content Accessibility Guidelines (WCAG) is a good approach.
How Does EN 301 549 Relate to EAA Compliance?
EN 301 549 is a European standard that defines the requirements that products and services based on information and communication technologies (ICT) should meet. And it’s a rock solid reference for meeting EAA technical requirements as-is.
However, what we’re eagerly waiting for is version 4.1.1 of EN 301 549 which, when published, will be harmonized with the EAA and tell you exactly how to meet the EAA technical requirements and create a presumption of conformity when conformance is reached.
As it stands, EN 301 549 is already the ‘go-to’ technical standard for accessibility in Europe, especially for ICT products and services. Think of it as the detailed instruction manual for meeting EAA requirements.
And entities in conformance with EN 301 549 are likely already meeting many EAA requirements. The standard includes specific technical criteria for everything from webpages to mobile apps to self-service terminals. For example, if your ATM meets EN 301 549 requirements for physical access, visible signals, and audio feedback, it’s well-positioned for EAA compliance.
It’s worth noting that EN 301 549 gets updated regularly – the current version is v3.2.1 (2021) and there are already drafts published for v4.1.1 . You may be able to get a copy by reaching out to the standards committee (it’s apparently online but you need a login).
While following EN 301 549 doesn’t automatically guarantee EAA compliance, it provides a proven technical framework for becoming compliant. Organizations already familiar with the standard will find it easier to adapt to EAA requirements.
What Are the Requirements under the Act?
Organizations need to document their compliance through several specific steps. Manufacturers must create technical documentation showing how their products meet accessibility requirements and keep these records for 5 years. They also need to add CE markings to their products, which shows they meet EU standards. Service providers need to explain how they meet accessibility requirements in their terms and conditions or similar documents. Both products and services require regular checks to make sure they stay accessible even when updated or changed.
The EAA specifies varying accessibility requirements (see Annex I) depending on the product or service. Here is the general requirement:
Products must be designed and produced in such a way as to maximise their foreseeable use by persons with disabilities and shall be accompanied where possible in or on the product by accessible information on their functioning and on their accessibility features.
However, there are numerous details so it’s best to assess your individual requirements under Annex I.
What’s nice is the EAA complements its technical requirements with practical examples in Annex 2.
How is the EAA Enforced?
Each EU country will have its own market surveillance authorities checking products and handling complaints. These authorities can make companies stop selling products that don’t meet requirements, recall non-compliant products, or require fixes to accessibility issues. The penalties will vary by country but must be serious enough to discourage companies from ignoring the rules. Companies that discover their own compliance issues must immediately inform authorities and fix the problems.
The EAA mandates regular compliance checks, complaint reviews, corrective actions, and public awareness about where to file complaints.
Consumers can file complaints from June 28, 2025, onwards if products or services do not meet the new accessibility rules.
Services
Do you need help with EAA compliance?
We’d love to help.
We offer accessibility services including audits, remediation, user testing, documentation (including VPAT/ACR services), training, and consulting.
Also, every organization can benefit from our WCAG Course which trains your team on the Web Content Accessibility Guidelines.
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.
