EU Accessibility Act vs Web Accessibility Directive Scope, evidence, and enforcement
The European Accessibility Act applies to selected products and consumer services, while the Web Accessibility Directive applies to websites and mobile applications of public sector bodies.
This comparison helps decide whether an accessibility issue belongs to EAA product/service compliance, public-sector web and app accessibility, or both.
The European Accessibility Act and the Web Accessibility Directive both address accessibility, but they do not regulate the same fact pattern. The EAA is an internal-market directive for specified products and consumer services. The Web Accessibility Directive is a public-sector digital accessibility directive for websites and mobile applications. Overlap can occur where a provides an online service that also falls within an EAA service category, but the scope test, evidence record, monitoring route, and enforcement route still need to be kept distinct.
Side-by-side comparison
European Accessibility Act vs Web Accessibility Directive
A practical comparison for teams deciding whether to run EAA conformity work, Web Accessibility Directive monitoring work, or both.
Use the EAA column for specified products, consumer services, economic operators, service providers, conformity evidence, Article 14 assessments, market surveillance, and national penalties.
Second framework
Web Accessibility Directive
Use the Web Accessibility Directive column for websites and mobile applications of public sector bodies, accessibility statements, user feedback routes, monitoring, reporting, and complaint mechanisms.
European Accessibility Act vs Web Accessibility Directive
Applies to specified products placed on the market and specified services provided to consumers after 28 June 2025, including ICT hardware and operating systems, payment and self-service terminals, electronic communications, audiovisual media access services, passenger transport service elements, consumer banking, e-books, e-commerce, and 112 emergency communications.
Applies to websites and mobile applications of public sector bodies in EU Member States. It excludes public-service broadcasters, qualifying NGOs, and specified content categories; Member States may exclude school, kindergarten, and nursery sites except essential online administrative functions.
Start with the actor, asset, and content. A public-sector site or app points to Directive 2016/2102, while a covered product or consumer service points to the EAA. Record content-level exclusions instead of treating an entire covered site as exempt.
Product duties sit with economic operators such as manufacturers, importers, distributors, and authorised representatives; service duties sit with service providers. Importers and distributors can become responsible as manufacturers when they market or modify products in ways that affect conformity.
The primary duty holder is the responsible for the website or mobile application, with Member States responsible for monitoring, reporting, training support, awareness, and enforcement mechanisms.
Do not assign all work to a single web owner. Product conformity, service operation, public-sector content, procurement, and monitoring may belong to different accountable teams.
EAA obligations are tied to Annex I accessibility requirements for covered products and services, product conformity assessment, EU declaration of conformity, CE marking for products, service information, ongoing service conformity, and corrective measures for non-conformity.
Web Accessibility Directive obligations require public-sector websites and apps to be perceivable, operable, understandable, and robust, supported by accessibility statements and user reporting routes.
Shared design controls can be reused, but EAA conformity artifacts and Web Accessibility Directive statements answer different legal questions.
The EAA allows accessibility requirements to apply only to the extent they do not cause a fundamental alteration or disproportionate burden. Economic operators must assess and document that position, keep relevant results for five years, and provide the assessment to authorities on request, subject to microenterprise-specific rules.
The Web Accessibility Directive permits a to avoid specific requirements that impose a disproportionate burden after an initial assessment of its size, resources, nature, estimated costs, and benefits for persons with disabilities. The accessibility statement must identify the non-accessible parts and provide accessible alternatives where appropriate.
A burden analysis is not portable by label alone. Keep the EAA Article 14 assessment separate from the public-sector body's Web Accessibility Directive assessment and statement disclosure.
For EAA products, keep technical documentation, conformity assessment records, EU declaration of conformity, CE marking evidence, instructions and accessibility information, operator traceability, complaints, and corrective actions. For services, keep the accessible public information explaining how requirements are met and the procedures that maintain conformity.
For public-sector websites and apps, keep the regularly updated accessibility statement, assessment basis, non-accessible content and reasons, alternatives where appropriate, feedback and information-request records, remediation evidence, and links to the national enforcement procedure. Member State authorities separately keep monitoring samples and Commission reports.
Maintain a shared evidence index only if each artifact is tagged to the exact directive, scope decision, standard clause, owner, system boundary, and date it supports.
Member States had to adopt and publish EAA transposition measures by 28 June 2022 and apply them from 28 June 2025. EAA Article 2 also uses 28 June 2025 for products placed on the market and services provided to consumers.
Websites first published after 22 September 2018 had to comply by 23 September 2019, older websites by 23 September 2020, and mobile applications by 23 June 2021.
Do not use the EAA application date to schedule Web Accessibility Directive remediation, and do not use older public-sector web/app deadlines as evidence that EAA product or service conformity is complete.
EAA products are checked through market surveillance and product corrective-action procedures. Services are checked by authorities responsible for service compliance. Member States must set penalties that are effective, proportionate, and dissuasive, with remedial action for non-compliance.
The Web Accessibility Directive relies on Member State monitoring of website and app compliance, reporting to the Commission, user feedback routes, and complaint or enforcement mechanisms.
Escalation playbooks should name the correct route: market surveillance or service-compliance authority for EAA issues, and the monitoring or complaint mechanism for public-sector web and app issues.
Run the EAA workstream when the issue concerns a covered product, covered consumer service, product conformity artifact, service accessibility information, Article 14 exception, market surveillance response, or national EAA penalty exposure.
Run the Web Accessibility Directive workstream when the issue concerns a public-sector website or mobile application, accessibility statement, user feedback route, monitoring sample, reporting obligation, or complaint mechanism.
Run both workstreams when a public-sector website or app is also the channel for an EAA-covered service, but keep separate scope memos and evidence tags.
EAA Article 15 links a presumption of conformity to the applicable Official Journal citation and only the requirements covered. Published EN 301 549 V4.1.1 (2026-09) provides an EAA-oriented technical mapping, but publication alone does not establish that legal presumption.
EN 301 549 V3.2.1 is cited as a harmonised standard for the Web Accessibility Directive and gives a presumption of conformity only for the directive requirements mapped in Annex A. A newer EN or WCAG version does not change that legal baseline until the EU cites it.
Use EN 301 549 as a control map for ICT where appropriate, but record the directive, asset boundary, clause, version, and Official Journal citation each result supports. Do not use the Web Accessibility Directive citation as an EAA presumption.
Earlier EN 301 549 version showing the Web Accessibility Directive relationship and the revision context; use the V4.1.1 source for the published EAA-oriented edition.
Accessibility requirements for ICT products and services
Supports the V3.2.1 harmonised citation for the Web Accessibility Directive and the rule that newer standard versions have no EU legal effect until cited.
The foreword identifies the EAA standardisation request and makes the legal presumption conditional on Official Journal citation.
Scope boundary
European Accessibility Act
Applies to specified products placed on the market and specified services provided to consumers after 28 June 2025, including ICT hardware and operating systems, payment and self-service terminals, electronic communications, audiovisual media access services, passenger transport service elements, consumer banking, e-books, e-commerce, and 112 emergency communications.
Web Accessibility Directive
Applies to websites and mobile applications of public sector bodies in EU Member States. It excludes public-service broadcasters, qualifying NGOs, and specified content categories; Member States may exclude school, kindergarten, and nursery sites except essential online administrative functions.
Operational implication
Start with the actor, asset, and content. A public-sector site or app points to Directive 2016/2102, while a covered product or consumer service points to the EAA. Record content-level exclusions instead of treating an entire covered site as exempt.
Supports the public-sector website and mobile application scope comparison.
websites and mobile applications
Covered actors
European Accessibility Act
Product duties sit with economic operators such as manufacturers, importers, distributors, and authorised representatives; service duties sit with service providers. Importers and distributors can become responsible as manufacturers when they market or modify products in ways that affect conformity.
Web Accessibility Directive
The primary duty holder is the responsible for the website or mobile application, with Member States responsible for monitoring, reporting, training support, awareness, and enforcement mechanisms.
Operational implication
Do not assign all work to a single web owner. Product conformity, service operation, public-sector content, procurement, and monitoring may belong to different accountable teams.
Supports public-sector responsibility and Member State monitoring context.
public sector bodies
Core accessibility obligations
European Accessibility Act
EAA obligations are tied to Annex I accessibility requirements for covered products and services, product conformity assessment, EU declaration of conformity, CE marking for products, service information, ongoing service conformity, and corrective measures for non-conformity.
Web Accessibility Directive
Web Accessibility Directive obligations require public-sector websites and apps to be perceivable, operable, understandable, and robust, supported by accessibility statements and user reporting routes.
Operational implication
Shared design controls can be reused, but EAA conformity artifacts and Web Accessibility Directive statements answer different legal questions.
Supports the POUR principles, accessibility statement, and issue-reporting route.
perceivable, operable, understandable and robust
Exceptions and burden
European Accessibility Act
The EAA allows accessibility requirements to apply only to the extent they do not cause a fundamental alteration or disproportionate burden. Economic operators must assess and document that position, keep relevant results for five years, and provide the assessment to authorities on request, subject to microenterprise-specific rules.
Web Accessibility Directive
The Web Accessibility Directive permits a to avoid specific requirements that impose a disproportionate burden after an initial assessment of its size, resources, nature, estimated costs, and benefits for persons with disabilities. The accessibility statement must identify the non-accessible parts and provide accessible alternatives where appropriate.
Operational implication
A burden analysis is not portable by label alone. Keep the EAA Article 14 assessment separate from the public-sector body's Web Accessibility Directive assessment and statement disclosure.
Supports the Web Accessibility Directive disproportionate-burden assessment and statement disclosure.
disproportionate burden
Evidence record
European Accessibility Act
For EAA products, keep technical documentation, conformity assessment records, EU declaration of conformity, CE marking evidence, instructions and accessibility information, operator traceability, complaints, and corrective actions. For services, keep the accessible public information explaining how requirements are met and the procedures that maintain conformity.
Web Accessibility Directive
For public-sector websites and apps, keep the regularly updated accessibility statement, assessment basis, non-accessible content and reasons, alternatives where appropriate, feedback and information-request records, remediation evidence, and links to the national enforcement procedure. Member State authorities separately keep monitoring samples and Commission reports.
Operational implication
Maintain a shared evidence index only if each artifact is tagged to the exact directive, scope decision, standard clause, owner, system boundary, and date it supports.
Supports Web Accessibility Directive accessibility statements, monitoring, reporting, and complaint records.
accessibility statement
Timing and deadlines
European Accessibility Act
Member States had to adopt and publish EAA transposition measures by 28 June 2022 and apply them from 28 June 2025. EAA Article 2 also uses 28 June 2025 for products placed on the market and services provided to consumers.
Web Accessibility Directive
Websites first published after 22 September 2018 had to comply by 23 September 2019, older websites by 23 September 2020, and mobile applications by 23 June 2021.
Operational implication
Do not use the EAA application date to schedule Web Accessibility Directive remediation, and do not use older public-sector web/app deadlines as evidence that EAA product or service conformity is complete.
Supports the separate phased public-sector website and mobile application compliance dates.
websites and mobile applications
Enforcement
European Accessibility Act
EAA products are checked through market surveillance and product corrective-action procedures. Services are checked by authorities responsible for service compliance. Member States must set penalties that are effective, proportionate, and dissuasive, with remedial action for non-compliance.
Web Accessibility Directive
The Web Accessibility Directive relies on Member State monitoring of website and app compliance, reporting to the Commission, user feedback routes, and complaint or enforcement mechanisms.
Operational implication
Escalation playbooks should name the correct route: market surveillance or service-compliance authority for EAA issues, and the monitoring or complaint mechanism for public-sector web and app issues.
Supports Web Accessibility Directive monitoring, reporting, issue reporting, and complaint-mechanism comparison.
monitored by the Member States
Which workstream applies
European Accessibility Act
Run the EAA workstream when the issue concerns a covered product, covered consumer service, product conformity artifact, service accessibility information, Article 14 exception, market surveillance response, or national EAA penalty exposure.
Web Accessibility Directive
Run the Web Accessibility Directive workstream when the issue concerns a public-sector website or mobile application, accessibility statement, user feedback route, monitoring sample, reporting obligation, or complaint mechanism.
Operational implication
Run both workstreams when a public-sector website or app is also the channel for an EAA-covered service, but keep separate scope memos and evidence tags.
Supports the public-sector website and mobile application decision rule.
public sector bodies
Standards and presumption of conformity
European Accessibility Act
EAA Article 15 links a presumption of conformity to the applicable Official Journal citation and only the requirements covered. Published EN 301 549 V4.1.1 (2026-09) provides an EAA-oriented technical mapping, but publication alone does not establish that legal presumption.
Web Accessibility Directive
EN 301 549 V3.2.1 is cited as a harmonised standard for the Web Accessibility Directive and gives a presumption of conformity only for the directive requirements mapped in Annex A. A newer EN or WCAG version does not change that legal baseline until the EU cites it.
Operational implication
Use EN 301 549 as a control map for ICT where appropriate, but record the directive, asset boundary, clause, version, and Official Journal citation each result supports. Do not use the Web Accessibility Directive citation as an EAA presumption.
Earlier EN 301 549 version showing the Web Accessibility Directive relationship and the revision context; use the V4.1.1 source for the published EAA-oriented edition.
Accessibility requirements for ICT products and services
Supports the V3.2.1 harmonised citation for the Web Accessibility Directive and the rule that newer standard versions have no EU legal effect until cited.
The foreword identifies the EAA standardisation request and makes the legal presumption conditional on Official Journal citation.
Practical decision rule
How to decide which rule controls the next step
Identify the actor first: economic operator, service provider, , or Member State authority.
Identify the asset next: covered product, covered consumer service, public-sector website, public-sector mobile app, or overlapping service channel.
Map evidence to the legal source it actually proves, especially where EN 301 549 tests or remediation logs are reused.
Keep separate exception, monitoring, and enforcement records because EAA Article 14 assessments and Web Accessibility Directive monitoring records are not the same artifact.
Standards source for separating reusable ICT accessibility tests from directive-specific legal evidence.
ICT products and services
1
Section 1
What the EAA covers
Directive (EU) 2019/882 covers specified products placed on the market after 28 June 2025 and specified services provided to consumers after that date. Covered products include consumer computer hardware and operating systems, payment terminals, certain self-service terminals, consumer terminal equipment for electronic communications or audiovisual media access, and e-readers.
Covered services include electronic communications services, access services for audiovisual media services, certain passenger transport service elements, consumer banking services, e-books and dedicated software, e-commerce services, and answering emergency communications to 112. EAA scope depends on the product or service, operator role, and consumer-facing journey, not the mere presence of a website or app.
For products, keep technical documentation, conformity assessment output, EU declaration of conformity, CE marking evidence, operator identity records, and corrective-action records where required.
For services, keep the public information explaining how the service meets the applicable accessibility requirements, the operating procedures that keep the service conforming, and records of changes to standards or service characteristics.
If fundamental alteration or disproportionate burden is relied on, document the assessment and keep the relevant results for the required period unless a specific microenterprise rule applies.
Commission policy overview used to confirm EAA purpose and implementation context.
2
Section 2
What the Web Accessibility Directive covers
Directive (EU) 2016/2102 applies to websites and mobile applications of public sector bodies. The definition includes state, regional, and local authorities, bodies governed by public law, and certain associations formed by them. Member States must ensure that covered sites and apps are perceivable, operable, understandable, and robust.
The Web Accessibility Directive excludes public-service broadcasters and qualifying non-governmental organisations. Content exclusions include office-file formats published before 23 September 2018 unless needed for active administrative processes; pre-recorded media published before 23 September 2020; live time-based media; online maps where essential navigation information is accessible; third-party content outside the body's control; reproductions of some heritage items; intranet and extranet content published before 23 September 2019 until a substantial revision; and archived content that is not needed for active administrative processes and has not been updated or edited after that date. Member States may also exclude schools, kindergartens, and nurseries except for content relating to essential online administrative functions.
Each covered needs a detailed, accessible, and regularly updated accessibility statement using the Commission model, including non-accessible content and reasons, accessible alternatives where appropriate, a feedback mechanism, and the enforcement link. Member States monitor a sample of sites and apps under the Commission methodology and report results to the Commission. These records do not replace EAA product or service conformity evidence when both directives apply.
Use the Web Accessibility Directive when the asset is a public-sector website or mobile application.
Keep the accessibility statement, assessment basis, issue and information-request records, responses, remediation evidence, and links to the national enforcement procedure.
Check each exclusion at content level; an excluded file or live stream does not remove the rest of the website or app from scope.
The phased deadlines were 23 September 2019 for websites first published after 22 September 2018, 23 September 2020 for older websites, and 23 June 2021 for mobile applications. These dates are separate from the EAA's 28 June 2025 application date.
Binding methodology for Member State monitoring samples, simplified and in-depth checks, reporting, and publication of monitoring results.
3
Section 3
How standards and evidence should be reused
EN 301 549 provides a shared ICT control map, but the legal claim behind the evidence matters. V3.2.1 supports the Web Accessibility Directive. ETSI now publishes EN 301 549 V4.1.1 (2026-09). Publication of an edition does not by itself establish an EAA presumption of conformity; verify the relevant Official Journal citation and the requirements it covers. Keep each Directive's legal mapping separate.
Tag each test result to the asset, service journey, legal instrument, standard clause, product or service boundary, and owner. For the Web Accessibility Directive, EN 301 549 V3.2.1 is the harmonised version cited for a presumption of conformity with the requirements it covers. That citation does not give V3.2.1 an EAA presumption of conformity. An EAA evidence file must check the applicable national law, Annex I requirement, and any standard actually cited for the EAA rather than borrowing the Web Accessibility Directive citation.
A public-sector app audit can inform an EAA e-commerce or transport-service assessment, but it is proof only for the same functions, users, content, standard clauses, and legal requirements. The Web Accessibility Directive's accessibility statement and national monitoring sample do not replace EAA technical documentation, EU declaration, CE marking, service information, or Article 14 assessment.
Map shared digital controls to EN 301 549 or the applicable standard, then separately state whether the evidence supports the EAA, the Web Accessibility Directive, or both.
Keep product conformity evidence separate from public-sector website and mobile app monitoring evidence.
Reopen the mapping when a harmonised standard, technical specification, website/app scope, service journey, supplier component, or consumer-facing feature changes.
Official Commission source confirming that EN 301 549 V3.2.1 is the current harmonised version for the Web Accessibility Directive and that a new version or WCAG edition has no EU legal effect until its reference is published in the Official Journal.
Official ETSI Human Factors page, retrieved 15 October 2026, listing published EN 301 549 V4.1.1 (2026-09). Publication is separate from Official Journal citation.
Recommended next step
Map your accessibility evidence to the right EU rule
Separate EAA product and consumer-service records from Web Accessibility Directive website and mobile app monitoring, then identify which tests, statements, and remediation records can be reused.
Primary legal source for EAA product and service scope, economic operator duties, service-provider records, exceptions, standards, market surveillance, penalties, and application dates.
Primary legal source for EAA scope, covered products and services, operator duties, conformity records, and Article 14 exceptions.
Primary legal source for EAA harmonised standards, technical specifications, and presumption-of-conformity provisions.
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Supports the EAA product and service scope comparison.
Supports EAA economic operator and service-provider role distinctions.
Supports Annex I, conformity, CE marking, service information, and corrective-action requirements.
Supports EAA fundamental alteration, disproportionate burden, documentation, and five-year retention requirements.
Supports EAA technical documentation, declarations, traceability, service information, and corrective-action records.
Supports the EAA 28 June 2022 transposition and 28 June 2025 application dates.
Supports EAA market surveillance, service compliance checks, penalties, and remedial action.
Supports the EAA decision rule for products, consumer services, conformity, standards, and authority response.
Primary legal source for EAA scope, evidence, exceptions, monitoring, enforcement, and dates used in the decision rule.
"accessibility requirements for products and services"
More quoted passages
"presumption of compliance"
"services provided to consumers"
"Obligations of economic operators"
"applicable accessibility requirements"
"fundamental alteration or disproportionate burden"
ETSI source for EN 301 549 as the ICT accessibility standard supporting the Web Accessibility Directive and planned support for the EAA.
ETSI source for the ICT accessibility standard's relationship to Directive 2016/2102 and planned support for Directive 2019/882.
Earlier EN 301 549 version showing the Web Accessibility Directive relationship and the revision context; use the V4.1.1 source for the published EAA-oriented edition.
Show 1 more
Standards source for separating reusable ICT accessibility tests from directive-specific legal evidence.
"Accessibility requirements for ICT products and services"
Official Commission source for the current EN 301 549 V3.2.1 harmonised citation under the Web Accessibility Directive and the legal limits of uncited standard versions.
Official Commission source confirming that EN 301 549 V3.2.1 is the current harmonised version for the Web Accessibility Directive and that a new version or WCAG edition has no EU legal effect until its reference is published in the Official Journal.
Supports the V3.2.1 harmonised citation for the Web Accessibility Directive and the rule that newer standard versions have no EU legal effect until cited.
Published European standard. The cover identifies V4.1.1 (2026-09); its foreword distinguishes publication from Official Journal citation and the resulting legal presumption.
Official ETSI Human Factors page, retrieved 15 October 2026, listing published EN 301 549 V4.1.1 (2026-09). Publication is separate from Official Journal citation.