We saw some back and forth on a Reddit thread recently about when the European Accessibility Act (EAA) actually takes effect—and who needs to do what by when. The confusion is understandable: the Directive includes multiple dates, carve-outs, and grace periods. So let’s break it down clearly, using language straight from the Directive.
Disclaimer: This post is our interpretation of the EAA and does not constitute legal advice. Consult your counsel on EAA compliance.
What the EAA Requires
The EAA mandates accessibility for certain products and services sold or provided within the EU. These include:
- E-commerce services
- Banking services
- Transport ticketing and information platforms
- ATMs and self-service terminals
- E-readers and e-books
- Electronic communications services (e.g., mobile plans, internet services)
Microenterprises (fewer than 10 employees and €2 million annual turnover) providing services are completely exempt from accessibility requirements. However, they must still comply if they manufacture, import, or distribute covered products.
But the critical question is: When do administrative obligations and accessibility requirements become mandatory?
The Two Key Years: 2025 and 2030
There are two important milestones that define when different obligations and requirements apply:
June 28, 2025 is the compliance deadline for new products and services.
Starting on this date:
- New products placed on the EU market must meet accessibility requirements.
- New services provided to consumers must be accessible.
From the Directive (Article 2):
“This Directive applies to the following products placed on the market after 28 June 2025…”
“…to the following services provided to consumers after 28 June 2025.”
While products are only covered if “placed on the market after” the deadline, services are covered if “provided to consumers after” the deadline. This means existing services must become accessible, while existing products do not.
June 28, 2030 marks the end of the five-year transitional period, but this only applies to products used in the provision of EAA-covered services—a narrow category. This is not a general compliance deadline for all legacy products, but rather the conclusion of the grace period for the specific products that service providers use to deliver EAA-covered services.
There is a five-year transition window for products used in EAA-covered service provision. However, self-service terminals (including most kiosks and POS systems) get special treatment: they may continue to be used until the end of their economic life—up to 20 years—regardless of the 2030 general transition deadline. During this time:
- Products already in use before June 28, 2025 (such as kiosks or POS systems) may continue to be used until the end of their economic life—up to 20 years—unless they are replaced before then.
- After June 28, 2030, services covered by long-term contracts or transitional clauses may no longer be exempt—but existing products already in use can continue if not replaced, subject to national implementation details.
From Recital 101 of the Directive:
“In order to allow service providers sufficient time to adapt to the requirements of this Directive, it is necessary to provide for a transitional period of five years after the date of application of this Directive, during which products used for the provision of a service which were placed on the market before that date do not need to comply with the accessibility requirements of this Directive unless they are replaced by the service providers during the transitional period. Given the cost and long life-cycle of self-service terminals, it is appropriate to provide that, when such terminals are used in the provision of services, they may continue to be used until the end of their economic life, as long as they are not replaced during that period, but not for longer than 20 years.”
Article 32, Transitional measures, also addresses the timeline:
1. Without prejudice to paragraph 2 of this Article, 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.
Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date.
2. 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.
Here’s a table showing the above EAA deadline information.
| Product/Service Status | Must Be Accessible By |
|---|---|
| New products placed on the market | June 28, 2025 |
| All services provided to consumers (new and existing) | June 28, 2025 |
| Products used in provision of EAA-covered services | May continue until June 28, 2030 unless replaced earlier |
| Service contracts agreed before June 28, 2025 | May continue unchanged until expiry (max 5 years to June 28, 2030) |
| Self-service terminals used in services | May continue until end of economic life, up to 20 years from entry into use |
Important: Most interactive customer-facing devices (like ordering kiosks, ATMs, ticketing machines) qualify as self-service terminals and get the extended 20-year timeline. The 2030 deadline applies to backend products used to deliver services—things like servers, payment processing systems, or other infrastructure that customers don’t directly interact with. If customers touch it or use it directly, it’s likely a self-service terminal with the longer compliance period.
Announcement: We’re releasing a never before seen product that will make EAA compliance much, much easier on July 7, 2025 on our YouTube channel @europeanaccessibilityact. You do not want to miss this.
Do you need assistance with EAA compliance? We’d love to help. Just send us a message and we’ll be right with you.
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.
