---
title: "EU Accessibility Act Applicability Test"
canonical_url: "https://www.sorena.io/artifacts/eu/accessibility-act/applicability-test"
source_url: "https://www.sorena.io/artifacts/eu/accessibility-act/applicability-test"
author: "Sorena AI"
description: "Check whether the European Accessibility Act covers a product or consumer service, which role applies, which date matters, and what evidence to keep."
published_at: "2026-05-09"
updated_at: "2026-07-24"
keywords:
  - "European Accessibility Act applicability test"
  - "EAA scope"
  - "Directive (EU) 2019/882"
  - "covered products"
  - "covered services"
  - "Article 14"
  - "European Accessibility Act"
  - "EAA applicability"
  - "accessibility scope"
  - "Article 14 assessment"
---
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# EU Accessibility Act Applicability Test

Check whether the European Accessibility Act covers a product or consumer service, which role applies, which date matters, and what evidence to keep.

*Applicability Test* *EU*

## European Accessibility Act Applicability Test

This test helps decide whether Directive (EU) 2019/882 covers a product placed on the EU market or a consumer service provided in the EU after 28 June 2025.

The record should identify the product or service category, economic-operator role, consumer-facing facts, date trigger, exclusions, microenterprise status, and any Article 14 assessment.

The European Accessibility Act does not cover every digital product, website, terminal, or service. Start with Article 2 scope, then document the EU role, consumer use, timing, exclusions, and any justified Article 14 limitation before assigning accessibility requirements or evidence tasks.

## Definitions

### Article 2 scope of the European Accessibility Act

**Term:** Article 2 scope

Article 2 scope is the closed list of product categories placed on the Union market after 28 June 2025, service categories provided to consumers after that date, and the answering of emergency communications to 112 that Directive (EU) 2019/882 covers. Article 2 also contains specific exclusions for certain website and mobile-application content.

**Why it matters here:** A product, service, website, app, or terminal must match an Article 2 category before Annex I requirements are assigned. Article 14 can limit a particular requirement but cannot expand or replace the Article 2 scope test.

Sources:

- [Directive (EU) 2019/882, Article 2](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882&ref=sorena.io)

## 1. Identify the product or consumer service

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.

- Write a one-line scope description: product model, software, website, app, terminal, service journey, or contract flow.
- Separate product scope from service scope. A payment terminal, e-reader, or consumer device is assessed differently from e-commerce, banking, transport information, or an e-book service.
- For transport, record the exact element being assessed: website, mobile app, electronic ticketing, transport service information, real-time travel information, or interactive self-service terminal.

Sources for this answer:

- [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882&ref=sorena.io) - Article 2 is the binding source for covered product and consumer-service categories and the 28 June 2025 product/service trigger.
- [European Commission Daily News on EAA application](https://ec.europa.eu/commission/presscorner/detail/en/mex_25_1650?ref=sorena.io) - Commission announcement confirming EAA entry into application and examples such as phones, computers, e-books, banking services, and electronic communications.

## 2. Confirm the EU role and consumer-facing facts

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.

- Manufacturer: manufactures a product, or has it designed or manufactured, and markets it under its name or trademark; it should control the product conformity file.
- Importer: places a third-country product on the Union market and should verify access to the required conformity documentation.
- Distributor: makes a product available in the supply chain and should preserve role-specific due-care evidence.
- Service provider: provides or offers a covered service to consumers in the Union and should maintain public accessibility information for the service.

Sources for this answer:

- [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882&ref=sorena.io) - Article 3 defines manufacturer, importer, distributor, service provider, economic operator, consumer, and microenterprise for the applicability record.
- [Blue Guide on the implementation of EU product rules 2022](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A52022XC0629%2804%29&ref=sorena.io) - General EU product-law guidance for distinguishing manufacturer, importer, and distributor responsibilities in product compliance files.

## 3. Apply exclusions, exemptions, and transition checks

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.

- Do not treat every website as covered just because it is digital; tie it to e-commerce, transport, banking, audiovisual access, e-book, electronic communications, or another Article 2 service.
- Apply Article 2(4) to the particular website or mobile-app content, not automatically to the whole covered service. Record whether the content is pre-application-date media or an office file, a map with accessible essential navigational information, third-party content that is neither funded, developed by, nor under the operator's control, or an archive containing only material not updated or edited after 28 June 2025.
- If using the service microenterprise exemption, keep the headcount and the turnover or balance-sheet calculation, including any linked-enterprise facts relevant to the EU SME rules.
- If relying on Article 32 transition, record the legacy product, service contract, lawful-use date, replacement status, the national rule relied on, and the latest permitted end point.

Sources for this answer:

- [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882&ref=sorena.io) - Articles 2, 3, 4, 14, and 32 support the exclusions, microenterprise service exemption, microenterprise definition, and transition checks.

*Recommended next step*

*Placement: after evidence section*

## Turn the EAA scope answer into an evidence file

Use the applicability result to brief product, legal, accessibility, procurement, and support teams on the covered category, operator role, required evidence, and review trigger.

- [Open Research Copilot](/solutions/research-copilot.md): Check EAA scope and evidence questions with cited outputs.
- [Talk through implementation](/contact.md): Review your product or service category, operator role, Article 14 basis, and evidence model.

## 4. Use Article 14 only for a documented limitation

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, the assessment must be carried out and documented against Annex VI criteria unless a microenterprise product actor benefits from the documentation derogation. 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.

- For fundamental alteration, describe the basic nature of the product or service and the exact accessibility requirement that would significantly change it.
- For disproportionate burden, record Annex VI cost ratios, estimated benefits for persons with disabilities, and net-cost-to-turnover analysis.
- If public or private funding is provided for improving accessibility, do not rely on disproportionate burden for those funded measures.
- If Article 14 is used for a product, the EU declaration of conformity must state which accessibility requirements are subject to the exception.

Sources for this answer:

- [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882&ref=sorena.io) - Article 14 and Annex VI are the binding sources for fundamental-alteration, disproportionate-burden, renewal, funding, and documentation rules.

## 5. Keep an evidence record that matches the conclusion

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.

- Scope fields: product or service name, category, version, market, consumer journey, EU role, relevant Article 2 point, and date trigger.
- Exclusion or exemption fields: exact basis, facts proving it, owner approval, review trigger, and source citation.
- Product evidence: technical documentation, applied standard or technical-specification mapping, EU declaration of conformity, CE marking status, and Article 14 assessment if used.
- Service evidence: general description in accessible formats, applicable accessibility requirements, explanation of how they are met, monitoring process, non-conformity corrections, and Article 14 assessment if used.
- Decision output: outcome category, controlling article, facts supporting the branch, responsible owner, national law and authority, evidence location, next action, and approval date.
- Review triggers: new product placement, service alteration, replacement of legacy service products, contract change, standard update, authority request, complaint, or reliance on disproportionate burden reaching its renewal point.

Sources for this answer:

- [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882&ref=sorena.io) - Articles 13, 14, 16 and Annexes IV and V support the product and service evidence records listed on this page.
- [European Commission harmonised standards overview](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards_en?ref=sorena.io) - Commission source explaining that harmonised standards can be used to demonstrate compliance when their references are published in the Official Journal.
- [ETSI overview of EN 301 549 for ICT accessibility](https://www.etsi.org/human-factors-accessibility/en-301-549-v3-the-harmonized-european-standard-for-ict-accessibility?ref=sorena.io) - ETSI source for EN 301 549 as an ICT accessibility standard relevant to evidence mapping for ICT-based products and services.

## Primary sources

- [Directive (EU) 2019/882 on accessibility requirements for products and services](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882&ref=sorena.io) - Primary legal source for EAA scope, Article 2 covered products and services, Article 3 roles and definitions, Article 4 microenterprise service exemption, Article 14 limitations, Article 32 transitions, and Annex IV/V evidence records.
  - Quote: "accessibility requirements for products and services"
- [European Commission Daily News on EAA application](https://ec.europa.eu/commission/presscorner/detail/en/mex_25_1650?ref=sorena.io) - Commission source confirming the EAA's entry into application and giving public examples of covered products and services.
  - Quote: "sets common accessibility requirements across the EU"
- [Blue Guide on the implementation of EU product rules 2022](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A52022XC0629%2804%29&ref=sorena.io) - EU product-law guidance used for role-sensitive product evidence, including manufacturer, importer, distributor, conformity documentation, and CE marking context.
  - Quote: "The manufacturer is responsible for the conformity assessment"
- [European Commission harmonised standards overview](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards_en?ref=sorena.io) - Commission source explaining the role of harmonised standards and OJEU references in demonstrating compliance with EU legislation.
  - Quote: "Harmonised Standards"
- [ETSI overview of EN 301 549 for ICT accessibility](https://www.etsi.org/human-factors-accessibility/en-301-549-v3-the-harmonized-european-standard-for-ict-accessibility?ref=sorena.io) - ETSI source for EN 301 549 as an accessibility standard for ICT products and services, relevant when the covered product or service is ICT-based.
  - Quote: "European Standard for ICT Accessibility"

## Related Topic Guides

- [EAA Accessibility Conformance Statement Template](/artifacts/eu/accessibility-act/accessibility-conformance-statement-template.md): Template language for an EU Accessibility Act conformance statement covering scope, Annex I mapping, service information, standards, support routes, evidence, and limits.
- [EAA Article 14 disproportionate burden workflow](/artifacts/eu/accessibility-act/disproportionate-burden-assessment-workflow.md): A cited EU Accessibility Act workflow for Article 14 fundamental alteration and disproportionate burden assessments, records, reassessment triggers, and evidence.
- [EAA conformance statements: products, services, EN 301 549 evidence](/artifacts/eu/accessibility-act/faq/conformance-statements.md): What an EU Accessibility Act conformance statement should include, with product EU declarations, service information, EN 301 549 and WCAG evidence boundaries.
- [EAA e-commerce checkout accessibility FAQ](/artifacts/eu/accessibility-act/faq/e-commerce-checkout.md): How to test an e-commerce checkout under the European Accessibility Act, including service scope, payment and identification flows, service information, and evidence.
- [EAA e-commerce checkout accessibility guide](/artifacts/eu/accessibility-act/e-commerce-checkout-accessibility.md): EU Accessibility Act guide for e-commerce checkout scope, payment and identification requirements, evidence, standards mapping, and customer information.
- [EAA EN 301 549 and WCAG mapping](/artifacts/eu/accessibility-act/en-301-549-and-wcag-mapping.md): Map European Accessibility Act Annex I requirements to EN 301 549 and WCAG evidence without overstating what WCAG tests can prove.
- [EAA EN 301 549 clause mapping for ICT evidence](/artifacts/eu/accessibility-act/en-301-549-clause-mapping.md): Map EN 301 549 clauses to EU Accessibility Act evidence, Annex I outcomes, product and service records, and gaps that need non-ICT support.
- [EAA procurement clauses and accessibility acceptance criteria](/artifacts/eu/accessibility-act/procurement-language-and-acceptance-criteria.md): Buyer-side EU Accessibility Act procurement language for covered products and services, with supplier evidence, EN 301 549 limits, Article 14 exception records, and acceptance criteria.
- [EAA scope classifier workflow for products and services](/artifacts/eu/accessibility-act/accessibility-scope-classifier-workflow.md): Classify EU Accessibility Act scope by product or service category, consumer use, market or service date, operator role, exclusions, exemptions, Article 14 records, and evidence.
- [EAA testing and conformance evidence | Annex I, EN 301 549 and Article 14](/artifacts/eu/accessibility-act/testing-and-conformance-evidence.md): How to document European Accessibility Act testing evidence: Annex I mappings, product technical files, service information, EN 301 549 boundaries, harmonised-standard limits, and Article 14 exception records.
- [EAA WCAG evidence and procurement acceptance](/artifacts/eu/accessibility-act/wcag-evidence-and-procurement-acceptance.md): How to use EN 301 549 and WCAG evidence in EU Accessibility Act procurement acceptance without overstating presumption of conformity.
- [EN 301 549 clause mapping for the EU Accessibility Act | EAA FAQ](/artifacts/eu/accessibility-act/faq/en-301-549-clause-mapping.md): How to map EN 301 549 and WCAG evidence to EU Accessibility Act Annex I requirements without overclaiming presumption of conformity.
- [EN 301 549 evidence matrix workflow for EAA readiness](/artifacts/eu/accessibility-act/en-301-549-evidence-matrix-workflow.md): Build an EN 301 549 evidence matrix for European Accessibility Act work: scope rows, clause mapping, test evidence, owner sign-off, exception records, and limits of standards evidence.
- [EN 301 549 vs WCAG for EAA evidence](/artifacts/eu/accessibility-act/en-301-549-vs-wcag.md): Compare EN 301 549 and WCAG for European Accessibility Act planning: ICT scope, web-content overlap, harmonised-standard limits, and evidence beyond WCAG-only tests.
- [EU Accessibility Act authority request response FAQ](/artifacts/eu/accessibility-act/faq/authority-response.md): How to answer EU Accessibility Act checks from market surveillance or service authorities with technical documentation, service information, Article 14 records, and corrective actions.
- [EU Accessibility Act checklist for products and services](/artifacts/eu/accessibility-act/checklist.md): Checklist for EAA scope, operator role, Annex I mapping, product technical files, service information, Article 14 assessments, supplier evidence, release checks, and monitoring.
- [EU Accessibility Act compliance operating model](/artifacts/eu/accessibility-act/compliance.md): Build an EU Accessibility Act compliance file for covered products and services: scope, operator roles, Annex I mapping, conformity evidence, Article 14 assessments, corrective actions, and records.
- [EU Accessibility Act deadlines and compliance calendar](/artifacts/eu/accessibility-act/deadlines-and-compliance-calendar.md): Calendar for the EU Accessibility Act: 2022 transposition, 2025 application, 2027 emergency communications timing, 2030 transition rules, owner actions, and evidence records.
- [EU Accessibility Act deadlines and transition plan](/artifacts/eu/accessibility-act/deadlines-and-transition-plan.md): Plan for the European Accessibility Act application date, service-contract transition, self-service terminal transition, 112 derogation, and evidence gates.
- [EU Accessibility Act disproportionate burden decision](/artifacts/eu/accessibility-act/disproportionate-burden-decision.md): How to document an EU Accessibility Act Article 14 disproportionate burden decision with supported criteria, retained evidence, limits, notifications, and review triggers.
- [EU Accessibility Act exemptions and disproportionate burden](/artifacts/eu/accessibility-act/exemptions-and-disproportionate-burden.md): Article 14 EAA guide covering fundamental alteration, disproportionate burden, service microenterprise exemptions, content exclusions, transition limits, and documentation.
- [EU Accessibility Act FAQ: scope, dates, services, Article 14](/artifacts/eu/accessibility-act/faq.md): Clear answers on EU Accessibility Act scope, 28 June 2025 application, covered products and services, microenterprises, Article 14, service information, standards, and penalties.
- [EU Accessibility Act for ecommerce websites](/artifacts/eu/accessibility-act/accessibility-act-for-ecommerce-websites.md): EU Accessibility Act guide for ecommerce teams covering consumer checkout journeys, service information, accessibility evidence, and exceptions.
- [EU Accessibility Act microenterprise exemption and disproportionate burden FAQ](/artifacts/eu/accessibility-act/faq/microenterprise-and-disproportionate-burden-decisions.md): FAQ explaining when EAA microenterprise relief applies, how Article 14 disproportionate-burden assessments work, what Annex VI requires, and what records to keep.
- [EU Accessibility Act penalties and enforcement](/artifacts/eu/accessibility-act/penalties-and-fines.md): How Directive (EU) 2019/882 handles penalties, Member State enforcement, market surveillance for products, and service compliance checks.
- [EU Accessibility Act procurement acceptance criteria | EAA FAQ](/artifacts/eu/accessibility-act/faq/procurement-acceptance.md): How to write EAA procurement acceptance criteria that ask suppliers for scoped accessibility evidence, standards mappings, declarations, and exception records without overclaiming conformity.
- [EU Accessibility Act Product and Service Scope](/artifacts/eu/accessibility-act/product-and-service-category-scoping.md): Scope products and services under the EU Accessibility Act using Article 2 categories, Article 3 definitions, limited content exclusions, microenterprise treatment, and evidence records.
- [EU Accessibility Act products and services in scope](/artifacts/eu/accessibility-act/products-and-services-in-scope.md): Article 2 scope guide for the European Accessibility Act: covered products, covered consumer services, economic-operator roles, Article 3 definitions, and evidence records.
- [EU Accessibility Act Requirements: Annex I, Products, Services](/artifacts/eu/accessibility-act/requirements.md): Map EU Accessibility Act requirements by Article 4, Annex I, product and service obligations, Article 13 evidence, standards, and Article 14 exceptions.
- [EU Accessibility Act service transition rules under Article 32 | EAA FAQ](/artifacts/eu/accessibility-act/faq/transition-services.md): FAQ on EU Accessibility Act Article 32 transition rules for service providers, pre-28 June 2025 contracts, 2030 limits, self-service terminals, evidence records, and change triggers.
- [EU Accessibility Act services: banking, transport, media and e-books](/artifacts/eu/accessibility-act/faq/banking-transport-and-media-services.md): FAQ on which consumer banking, transport, audiovisual media access, electronic communications, e-book, and e-commerce services fall under the EU Accessibility Act.
- [EU Accessibility Act vs ADA and Section 508](/artifacts/eu/accessibility-act/accessibility-act-vs-ada-and-section-508.md): Compare EAA product and consumer-service duties with ADA Title II and III accessibility duties and US federal Section 508 ICT requirements.
- [EU Accessibility Act vs Web Accessibility Directive](/artifacts/eu/accessibility-act/accessibility-act-vs-web-accessibility-directive.md): Compare the European Accessibility Act with the Web Accessibility Directive: scope, covered actors, services, standards, evidence, monitoring, enforcement, and key dates.
- [WCAG Evidence for the EU Accessibility Act and EN 301 549 | EAA FAQ](/artifacts/eu/accessibility-act/faq/wcag-evidence.md): When WCAG test evidence helps EAA work, how it maps through EN 301 549, and why WCAG alone does not prove European Accessibility Act compliance.
- [Which products and services does the EU Accessibility Act cover? | EAA FAQ](/artifacts/eu/accessibility-act/faq/product-and-service-categories.md): Article 2 and Article 3 scope summary for EU Accessibility Act covered products, services, exclusions, product-service boundaries, and records to keep.


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