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. Consult your counsel on final determinations.
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)
But the critical question is: When does accessibility become mandatory?
The Two Key Years: 2025 and 2030
There are two important milestones that define when different obligations apply:
June 28, 2025 is when the compliance deadline applies 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.”
June 28, 2030 marks the end of the five-year transitional period during which service providers may continue using existing products that were lawfully in use before June 28, 2025. This is not a separate compliance deadline, but rather the conclusion of the grace period for legacy products used in services.
There is a five-year transition window. 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:
“The Directive grants a five-year transition period for service providers. During this time, existing products used in services—such as self-service kiosks—do not need to meet accessibility requirements unless replaced. These products may continue to be used until the end of their economic life, for up to 20 years, as long as they are not replaced earlier.”
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 |
| New services provided to consumers | June 28, 2025 |
| Legacy products used in services (general) | 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 |
Do you need assistance with EAA compliance? We’d love to help. Just send us a message and we’ll be right with you.
