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FAQEU

EU Accessibility Act FAQ covered services

The EU Accessibility Act covers named consumer services, including electronic communications, audiovisual media access, passenger transport elements, consumer banking, e-books and dedicated software, and e-commerce services.

This FAQ helps classify service scope, identify the Annex I service duties that apply, and keep the evidence records needed for service accessibility information and any Article 14 exception.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

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

The EU Accessibility Act does not cover every banking, transport, telecom, media, publishing, or retail activity. For services provided to consumers after 28 June 2025, it covers the categories listed in Article 2 and defined in Article 3, including , then applies Annex I Section III and IV according to Article 4. Member State transposition law controls the national authority, procedure, and penalties.

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4 of 4 questions
Question 1

Which consumer services are covered by the EU Accessibility Act?

For this FAQ, the covered service categories are electronic communications services, , listed passenger transport service elements, , e-books and dedicated software, and 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.

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.

  • Electronic communications services are covered, except transmission services used for machine-to-machine services.
  • Audiovisual media access services include services used to identify, select, receive information on, and view audiovisual media services, including electronic programme guides.
  • E-books are covered together with dedicated software used to access, navigate, read, and use the digital files.
  • are covered when provided at a distance through websites or mobile device-based services by electronic means at the individual request of a consumer with a view to concluding a consumer contract.

Which banking, transport, telecom, media, e-book, and are covered by the EU Accessibility Act?

The EAA covers named consumer service categories: electronic communications services, , specified passenger transport service elements, , e-books and dedicated software, and . For transport, check the exact element first: websites, mobile services and apps, electronic tickets and ticketing services, transport service information, and EU-located interactive self-service terminals are listed; urban, suburban, and regional transport is limited to the self-service terminal element.

Does the EU Accessibility Act treat consumer banking as every financial service?

No. The EAA defines by reference to specific categories: consumer credit agreements, selected investment and ancillary services, payment services, services linked to payment accounts, and electronic money. A banking team should map the consumer journey to those categories before applying the Annex I banking requirements.

Citations
Question 2

What Annex I duties apply to these covered services?

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.

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.

  • Passenger transport services must provide information on vehicle, infrastructure, built-environment accessibility, assistance for persons with disabilities, smart ticketing, real-time travel information, and temporary service availability issues where the listed transport elements are in scope.
  • E-books must support synchronised text and audio when audio is included, avoid blocking assistive technology, allow access, navigation, structure, dynamic layout, flexible presentation, accessibility metadata, and digital rights management that does not block accessibility features.
  • must provide product or service accessibility information when supplied by the responsible economic operator and make identification, security, electronic signature, and payment functionality perceivable, operable, understandable, and robust.
Citations
Question 3

What evidence should a service provider keep?

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.

  • Maintain a service scope register that ties each consumer journey to an Article 2 category and Article 3 definition.
  • Keep an Annex I matrix showing the Section III general service duties and the Section IV category-specific duties that apply to the service.
  • Attach accessibility test results for websites, apps, ticketing, payment, identification, security, media-access, e-book, and support-service components as relevant.
  • Keep supplier inputs for products used in the service, such as payment terminals, ATMs, ticketing machines, check-in machines, interactive information terminals, e-readers, terminal equipment, and media access equipment when those products are part of the service evidence.
  • Retain the public service accessibility statement or equivalent general terms document, monitoring records, remediation logs, authority correspondence, and any Article 14 assessment.

What evidence supports an EU Accessibility Act covered-services assessment?

Keep the Article 2 scope classification, Article 3 definition mapping, Annex I service-requirement matrix, accessible service description, test evidence, supplier evidence for products used in the service, monitoring procedure, remediation log, and public service accessibility information. If Article 14 is used, keep the fundamental-alteration or disproportionate-burden assessment and the authority notification record where required.

Where should EU Accessibility Act service accessibility information appear?

Annex V requires the service provider to include information assessing how the service meets Article 4 accessibility requirements in the general terms and conditions or an equivalent document. The information must describe the service in accessible formats, explain service operation, describe how relevant Annex I requirements are met, and show how service delivery and monitoring keep the service compliant.

Citations
Recommended next step

Classify the covered service before testing

Use the Article 2 service category, Article 3 definition, Annex I duty, and Annex V evidence record to separate covered consumer services from adjacent activities.

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Open Research Copilot

Check an EAA service-scope question against cited EU source material.

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Talk through implementation

Review your service category, Annex I mapping, and evidence record.

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Question 4

What scope boundaries should teams avoid overstating?

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 , 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.

  • Check microenterprise status before assigning service duties: Article 4(5) exempts qualifying microenterprises providing services from the service accessibility requirements in Article 4(3), covering the applicable Annex I Sections III and IV duties and related compliance obligations.
  • Check the customer as well as the sector. The listed banking, transport, media-access, e-book, communications, and e-commerce categories are service-side EAA scope when provided to consumers; a business-to-business offer is not brought into the service list merely by using the same technology.
  • Check website and mobile-app content exclusions before testing archived content, older pre-recorded time-based media, older office files, certain online maps, or third-party content outside the operator's funding, development, or control.
  • Use Article 14 only as a documented exception analysis; lack of priority, time, or knowledge is not an official source reason to omit accessibility work.
Citations
Primary sources

References and citations

European Commission - harmonised standards overview
single-market-economy.ec.europa.eu
Referenced sections
  • Supports the role of harmonised standards whose references are published in the Official Journal when providers use those standards as conformity evidence.
"Harmonised standards"
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