Compliance CalendarEU

EU Accessibility Act deadlines and compliance calendar

Directive (EU) 2019/882 applies to selected consumer products and services, including computers, smartphones, payment terminals, ATMs, ticketing machines, e-readers, electronic communications, banking, e-commerce, e-books, and passenger transport service information.

Use this calendar to separate EU dates from national choices, identify the owner for each product, service, contract, or terminal, and retain the evidence an authority may request.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
3

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

The main EU Accessibility Act application date was 28 June 2025. is the first making available of an individual product on the Union market, so covered products first placed there after that date and covered services provided to consumers after it are within the Directive's date-based scope, subject to the applicable requirements, exclusions, exemptions, and national implementing law. Separate dates and rules cover pre-existing service contracts, products already used to provide services, self-service terminals, 112 emergency communications, evidence retention, reassessment, and the Commission's review cycle.

Section 1

Calendar dates to put in the EAA compliance tracker

Start the tracker with the legal date, affected item, Member State, owner, and operational consequence. Article 31 required Member States to adopt and publish national measures by 28 June 2022 and apply them from 28 June 2025. Article 2 uses 28 June 2025 as the cutover for covered products first placed on the EU market and covered services provided to consumers. means the first making available of an individual product on the Union market, not the start of design, manufacture, or a later resale.

Article 32 treats legacy items differently. Its transition ending on 28 June 2030 allows service providers to continue providing similar services with products they lawfully used before the 28 June 2025 application date. The transition covers that service-provider equipment; it does not delay every accessibility duty or every legacy service. Service contracts agreed before 28 June 2025 may continue without alteration until expiry, but no longer than five years from that date.

Self-service terminals need a separate asset register because their rule is optional for Member States. National law may allow a terminal lawfully used before 28 June 2025 to continue for a similar service until the end of its economically useful life, but never for more than 20 years after entry into use. Article 31 also allowed a Member State to defer the Article 4(8) obligations for answering 112 emergency communications until no later than 28 June 2027.

The calendar also has a regulatory review date. Under Article 33, the Commission must report on the Directive's application by 28 June 2030 and every five years after that. This review cycle does not extend an operator's compliance deadline.

  • 28 June 2022: Member State transposition deadline; legal and policy owners should record the national implementing law for each target country.
  • 28 June 2025: general application date; product, engineering, service, procurement, and release owners should require EAA scope and accessibility evidence before launch or provision.
  • 28 June 2027: latest possible date for Member States applying Article 4(8) obligations on accessible answering of 112 emergency communications; telecom and public-safety owners should check national implementation.
  • 28 June 2030: end of the general service-provider transition period for services using products lawfully used before 28 June 2025.
  • 28 June 2030 maximum for pre-28 June 2025 service contracts: contracts agreed before the application date can continue unchanged until expiry, but not beyond five years from 28 June 2025.
  • Self-service terminal transition: asset owners should record the national legal basis and terminal entry-into-use date because any allowed transition is capped at 20 years after that date.
  • 28 June 2030 and every five years thereafter: Commission application report under Article 33; monitor resulting guidance or legislative proposals, but do not treat the review itself as a change in law.
Recommended next step

Review your EAA calendar evidence

Check whether each EAA milestone has a named owner, national-law note, product or service scope decision, accessibility evidence, and transition status before the next release or renewal.

Section 2

Owner actions before and after each EAA milestone

Use the calendar as a release-control list. For every product or service line, record whether the item is in Article 2 scope, whether an Article 2(4) content exclusion or the microenterprise service exemption applies, which Member State law governs, and whether the record concerns a product first placed on the market, a service provided to consumers, equipment already used for a similar service, or a pre-application service contract.

Product owners should maintain technical documentation, EU declaration of conformity, CE marking status, standards or technical specifications applied, and corrective-action records. Service owners should keep the public information explaining how the service meets accessibility requirements for as long as the service operates.

Where an economic operator relies on fundamental alteration or disproportionate burden, Article 14 requires an assessment. The operator must document and keep the results for five years from the last making available of the product or after the service was last provided. A microenterprise dealing with products need not document the assessment, but must provide the relevant facts if a market surveillance authority asks. A microenterprise providing services is exempt from the Directive's requirements and obligations under Article 4(5).

  • Legal owner: identify the national transposition measure and any Member State choices on built environment, 112 timing, transition measures, penalties, and competent authorities.
  • Product owner: freeze the EAA scope decision before placing a covered product on the market and attach the Annex IV technical documentation package.
  • Service owner: publish and retain the Annex V information describing the service, how it operates, and how the relevant Annex I requirements are met.
  • Procurement owner: require suppliers of covered ICT, terminals, e-books, banking, transport, and e-commerce components to provide accessibility evidence before renewal or purchase.
  • Terminal asset owner: keep terminal type, location, service use, entry-into-use date, lawfully-used-before-28-June-2025 status, and planned replacement date.
  • Support and incident owner: keep complaint, non-conformity, authority request, corrective action, withdrawal, and service remediation records tied to the affected requirement.
  • Exception owner: record the exact requirement not applied, the Article 14 basis, Annex VI calculation where disproportionate burden is claimed, authority notification, any accessibility-specific external funding, and the reassessment trigger.
Section 3

Evidence checkpoints for standards, exceptions, and authority requests

A useful EAA calendar has evidence checkpoints, not just reminders. At each major release, renewal, material service change, complaint, and authority request, check whether the record names the applicable Annex I requirements, the standard, technical specification, or other solution used, the test results, unresolved gaps, and remediation owner.

Article 15 gives a presumption of conformity only to the extent that a product or service conforms to a harmonised standard, or part of one, whose reference has been published in the Official Journal of the European Union and that standard covers the relevant EAA requirement. Article 25 separately addresses conformity with accessibility requirements in other Union acts. Do not use Article 25 as the legal basis for an Article 15 presumption.

EN 301 549 is useful technical evidence for ICT, but a mapping to the standard does not by itself establish an EAA presumption of conformity. Verify the specific edition, the applicable clauses, and whether an EAA-related reference has been published in the Official Journal. ETSI listed V4.1.0, dated June 2026, as on approval on 25 July 2026; approval-stage status is not an Official Journal citation. The Commission's standards page also states that use of harmonised standards is voluntary, so an operator may use another technical solution while still having to demonstrate compliance with the binding requirement.

  • Keep one row per product, service, contract, or terminal with the EAA date, Article or Annex reference, owner, evidence link, and status.
  • Record whether the evidence supports full compliance, partial application of a standard, a non-standard solution, a transition rule, or an Article 14 exception.
  • For disproportionate-burden decisions, include Annex VI criteria, accessibility funding status, affected requirement, why full compliance is not applied, and the date for the next reassessment.
  • For service providers relying on disproportionate burden, schedule reassessment when the service changes, when the authority requests it, and at least every five years.
  • Do not publish penalty amounts in a central EU calendar unless the relevant Member State rule is cited; Article 30 leaves penalty rules to Member States and requires them to be effective, proportionate, and dissuasive.
Primary sources

References and citations

etsi.org
Referenced sections
  • ETSI source describes EN 301 549 as a European standard containing accessibility requirements for ICT products and services. Its technical scope does not establish an EAA presumption of conformity.
ec.europa.eu
Referenced sections
  • Commission announcement confirming that the EAA entered into application in the EU on 28 June 2025 for key products and services.
"the European Accessibility Act (EAA) will enter into application in the EU"
commission.europa.eu
Referenced sections
  • Commission overview supports the scope framing for selected products and services such as computers, smartphones, e-commerce, banking, e-books, and transport services.
"The European Accessibility Act covers products and services"
single-market-economy.ec.europa.eu
Referenced sections
  • Commission standards page supports the instruction to check OJEU references before using a harmonised standard as presumption-of-conformity evidence.
"The references of harmonised standards must be published in the Official Journal"
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