EU Accessibility Act FAQ covered services

For this FAQ, the covered service categories are electronic communications services, services providing access to audiovisual media services, listed passenger transport service elements, consumer banking services, e-books and dedicated software, and e-commerce services provided to consumers.

Passenger transport scope is narrower than a whole transport business. The Act lists websites, mobile device-based services and apps, electronic tickets and ticketing services, transport service information including real-time travel information, and interactive self-service terminals located in the EU. For urban, suburban, and regional transport, Article 2 limits the service element to interactive self-service terminals.

Consumer banking services are also defined by category. Article 3 includes consumer credit agreements, specified investment and ancillary services, payment services, payment-account-linked services, and electronic money when provided to consumers.

Covered services other than urban, suburban, and regional transport must satisfy the general service requirements in Annex I Section III unless a scoped exception applies. That means accessible products used in the service, accessible information about how the service works and how those products connect to assistive devices, accessible websites and mobile services, and accessible support information where support services are available. Article 4(3) excludes those three local transport categories from Section III but applies the relevant Section IV self-service-terminal requirement.

Annex I Section IV then adds service-specific duties. Electronic communications services must provide real-time text in addition to voice, total conversation where video is provided, and synchronised emergency communications transmission to the most appropriate public safety answering point where relevant.

Audiovisual media access services must provide accessible electronic programme guides and must transmit accessibility components such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles, and sign language interpretation with adequate quality, synchronisation, and user control.

Consumer banking services must make identification methods, electronic signatures, security, and payment services perceivable, operable, understandable, and robust. Banking information must be understandable without exceeding level B2 of the Council of Europe's Common European Framework of Reference for Languages.

Article 13 requires service providers to design and provide services in accordance with the EAA accessibility requirements, prepare information explaining how the services meet the applicable requirements, make that information publicly available in written and oral formats including accessible formats, and keep it for as long as the service operates.

Annex V explains what that service information should contain: a general description of the service in accessible formats, descriptions and explanations needed to understand service operation, and a description of how the relevant Annex I requirements are met. It also calls for information demonstrating that service delivery and monitoring keep the service compliant.

If a provider relies on fundamental alteration or disproportionate burden under Article 14, the assessment must be documented and retained. Service providers relying on disproportionate burden must renew the assessment when the service is altered, when requested by the authority responsible for checking services, and at least every five years.

Do not describe the EAA as covering every service offered by a bank, transport operator, telecommunications provider, media company, publisher, or online retailer. Check whether the specific consumer-facing service falls into Article 2 and the relevant Article 3 definition.

Do not treat audiovisual media content accessibility and access-service accessibility as the same rule. The EAA covers services providing access to audiovisual media services, including electronic programme guides, and Annex I focuses on transmitting accessibility components with adequate quality, synchronisation, and user control.

Do not assume every transport operation is fully in scope. Article 2 names specific transport service elements and separately limits urban, suburban, and regional transport to interactive self-service terminals.

Do not use harmonised standards as a substitute for the legal scope analysis. Standards can help evidence technical accessibility for ICT components, but the EAA service category and Annex I duty still need to be mapped.