EU Accessibility Act FAQ

The European Accessibility Act, or EAA, is an EU directive that harmonises accessibility requirements for selected products and services. Its purpose is to improve the internal market for accessible products and services by reducing barriers created by divergent Member State rules.

The EAA is not a general accessibility law for every product, website, or service. It applies only where a product or service falls within Article 2 and the relevant national law implementing the Directive.

Member States had to adopt and publish national transposition measures by 28 June 2022 and apply those measures from 28 June 2025. Article 2 applies the product scope to covered products placed on the market after 28 June 2025 and the service scope to covered services provided to consumers after 28 June 2025.

For products, the date attaches to placement on the market, not only to the model's launch date. A model designed or first sold earlier can still require a product-side assessment when individual units are placed on the Union market after 28 June 2025. Check the implementing law and facts for the relevant Member State rather than treating a legacy model as automatically outside scope.

Article 32 adds transitional measures. Service providers may continue using products lawfully used before 28 June 2025 to provide similar services during a transitional period ending on 28 June 2030. Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but not for more than five years from that date. Member States may also allow self-service terminals lawfully used before 28 June 2025 to continue until the end of their economically useful life, with a maximum of 20 years after entry into use.

Article 2 covers specific products placed on the market after 28 June 2025. Covered products include consumer general purpose computer hardware systems and operating systems; payment terminals; ATMs, ticketing machines, check-in machines, and certain interactive information terminals used for covered services; consumer terminal equipment with interactive computing capability for electronic communications services; consumer terminal equipment used for access to audiovisual media services; and e-readers.

Annex I then describes product accessibility requirements, including accessible information about product use and accessibility features, user interface and functionality design, support service information where available, and additional rules for packaging and instructions for many products.

Article 2 covers services provided to consumers after 28 June 2025 in named categories: electronic communications services, with an exception for transmission services used for machine-to-machine services; services providing access to audiovisual media services; specific elements of air, bus, rail, and waterborne passenger transport services; consumer banking services; e-books and dedicated software; and e-commerce services. It also applies to answering emergency communications to the single European emergency number 112.

For passenger transport, Article 2 does not make every transport activity subject to every EAA service rule. It lists websites, mobile services and apps, electronic tickets and ticketing, transport service information including real-time travel information, and interactive self-service terminals. For urban, suburban, and regional transport services, only the EU-located interactive self-service-terminal element applies, excluding terminals integrated into vehicles, aircraft, ships or rolling stock.

The Directive itself sets legal accessibility requirements in Annex I. Article 15 recognises a presumption of conformity for the requirements covered by an OJEU-cited harmonised standard. It separately provides for technical specifications established by Commission implementing acts, with a presumption limited to the requirements those specifications cover.

EN 301 549 is the European ICT accessibility standard for software, web pages, mobile applications, desktop applications, hardware, and combinations of hardware and software. V3.2.1 is harmonised for 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.

Do not treat a WCAG checklist alone as full EAA compliance. For web and mobile interfaces, WCAG-style evidence can be useful, but the EAA assessment still has to cover the actual Article 2 category and the relevant Annex I requirements, including product information, support services, payments, identification, e-book, transport, banking, or audiovisual access requirements where applicable.

The EAA defines a microenterprise as an enterprise with fewer than 10 persons and either annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million.

The exemption is not the same for services and products. Article 4 says microenterprises providing services are exempt from complying with the service accessibility requirements referred to in Article 4(3) and from obligations relating to those requirements. For microenterprises dealing with products, the Directive does not create the same broad product exemption. Instead, it lightens some administrative burden, including an Article 14 documentation exemption when a product microenterprise relies on fundamental alteration or disproportionate burden.

Article 14 does not create a broad opt-out. It says the Article 4 accessibility requirements apply only to the extent compliance does not require a significant change that fundamentally alters the basic nature of the product or service and does not impose a disproportionate burden on the economic operator.

Economic operators must assess whether compliance would create a fundamental alteration or, using Annex VI criteria, a disproportionate burden. Except for microenterprises dealing with products, they must document that assessment and keep relevant results for five years from the last making available of a product on the market or after a service was last provided. If requested by market surveillance authorities or service compliance authorities, they must provide a copy of the assessment; a microenterprise dealing with products must instead provide the relevant facts when a market surveillance authority requests them.

Service providers relying on disproportionate burden must renew the assessment when the service is altered, when authorities request it, and at least every five years. Operators that receive funding outside their own resources from public or private sources specifically to improve accessibility cannot rely on disproportionate burden.

Annex V requires a service provider to include information assessing how the service meets the accessibility requirements in the general terms and conditions or an equivalent document. That information must describe applicable requirements and, as relevant, the design and operation of the service.

Where applicable, the information must include a general description of the service in accessible formats, descriptions and explanations needed to understand operation of the service, and a description of how the relevant Annex I accessibility requirements are met. Annex V also requires information showing that the service delivery process and monitoring ensure compliance with Annex V point 1 and the applicable Directive requirements.

The Directive expressly supports several evidence types. For products, Annex IV requires technical documentation that makes it possible to assess conformity with the relevant accessibility requirements and, where Article 14 is used, to demonstrate fundamental alteration or disproportionate burden. For services, Annex V requires information explaining how the service meets accessibility requirements and how service delivery and monitoring ensure compliance.

For Article 14, the Directive requires documented assessment results to be kept for five years, except for the specific microenterprise product-documentation derogation. A practical evidence file should therefore be built around the exact legal duty being answered, not around generic accessibility labels.

The Directive does not set a single EU-wide fine amount. Article 30 requires Member States to lay down rules on penalties for infringements of national provisions adopted under the Directive and to ensure those rules are implemented.

Article 30 says penalties must be effective, proportionate, and dissuasive, and accompanied by effective remedial action in case of non-compliance by the economic operator. Product market surveillance and service compliance procedures are also handled through Member State authorities under the Directive.