European Accessibility Act Applicability Test

For products, the EAA scope test starts with whether the item is one of the Article 2 product categories and is placed on the EU market after 28 June 2025. Covered products include consumer general purpose computer hardware systems and their operating systems, payment terminals, certain self-service terminals, consumer terminal equipment with interactive computing capability, and e-readers.

For services, check whether the service is provided to consumers after 28 June 2025 and falls into an Article 2 service category. Covered services include electronic communications services, services providing access to audiovisual media services, specified elements of passenger transport services, consumer banking services, e-books and dedicated software, and e-commerce services.

The applicability answer should name the economic operator role because obligations attach to different actors. Article 3 defines economic operator as the manufacturer, authorised representative, importer, distributor, or service provider; it also defines a consumer as a natural person acting outside their trade, business, craft, or profession.

For products, record whether the organisation manufactures under its own name, imports from outside the EU, distributes another party's product, or acts through an authorised representative. For services, record who provides the service on the Union market or offers it to consumers in the Union.

A product or service can match a covered category and still need a narrower conclusion. Article 2 excludes specific website and mobile-app content, including pre-recorded time-based media and office file formats published before 28 June 2025, certain online maps, third-party content outside the operator's funding, development, or control, and archives that are not updated or edited after that date.

Microenterprise status matters, but it is not a blanket product exclusion. The Directive defines a microenterprise as employing fewer than 10 people and having annual turnover or an annual balance-sheet total no higher than EUR 2 million. Article 4 exempts microenterprises providing services from the service accessibility requirements and related obligations. Microenterprises dealing with products still need a product-scope answer, though Article 14 exempts them from documenting an exception assessment and requires the relevant facts to be supplied if a market surveillance authority asks.

Article 32 also protects some legacy service arrangements. Service providers may continue providing services using products lawfully used for similar services before 28 June 2025 until 28 June 2030. Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no later than 28 June 2030. Member States may also allow self-service terminals already lawfully used before 28 June 2025 to remain in similar service until the end of their economically useful life, capped at 20 years after entry into use; check whether the relevant national law adopted that option.

Article 14 cannot make a product or service out of scope. It limits specific accessibility requirements only where compliance would fundamentally alter the basic nature of the product or service or impose a disproportionate burden on the economic operator.

When Article 14 is used, assess the specific requirement and document the result unless the product-microenterprise documentation derogation applies. Use Annex VI criteria for the disproportionate-burden assessment; for fundamental alteration, explain the significant change to the product or service's basic nature. Service providers relying on disproportionate burden must renew the assessment when the service changes, when the authority requests it, and at least every five years.

The useful output is a scope record that can be checked later by product, legal, procurement, and accessibility teams. It should be precise enough to show why the item is covered, excluded, exempt, transitional, or limited by Article 14.

For covered products, Annex IV points to technical documentation, applied harmonised standards or technical specifications, the EU declaration of conformity, and CE marking evidence. For covered services, Article 13 and Annex V point to public information explaining how the service meets accessibility requirements, descriptions needed to understand service operation, and monitoring information showing that service delivery remains compliant.

End the test with one explicit outcome: covered product; covered service; covered product and service; excluded content only; exempt service microenterprise; transitional arrangement with an end date; out of scope; or covered with one or more Article 14 requirements limited. A mixed offer may need more than one outcome row.