EU Accessibility Act deadlines and compliance calendar

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. Placing on the market 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.

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 service accessibility requirements and related compliance obligations under Article 4(5).

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, applicable clauses, and EAA Official Journal reference. ETSI publishes V4.1.1 (2026-09); publication alone is not an Official Journal citation. Use of harmonised standards is voluntary, so an operator may use another technical solution while still having to demonstrate compliance with the binding requirement.