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The supported limits are narrow. Service microenterprise status removes the specified service accessibility compliance duties, but it should be evidenced with the Directive's definition. Article 14 is requirement-specific and product-or-service-specific. It does not remove the duty to comply with accessibility requirements that remain achievable without fundamental alteration or disproportionate burden.

Authority visibility also matters. Product market surveillance authorities check whether an Article 14 assessment was conducted, review the assessment and Annex VI criteria, and check compliance with applicable accessibility requirements. For services, the authorities responsible for checking service compliance also check the Article 14 assessment.

Start with scope. Identify whether the purchase is for an EAA-covered product, an EAA-covered service, or ICT that supports one of those services. The Commission describes the EAA as covering selected products and services important for persons with disabilities, and the Directive makes Annex I accessibility requirements mandatory for the products and services referred to in Article 2 when public procurement rules require accessibility criteria.

Then turn that scope into acceptance criteria. Each criterion should say which accessibility requirement is being accepted, what supplier evidence is required, how defects will be classified, what remediation proof is needed before acceptance, and which claims are not accepted without additional evidence.

EN 301 549 is useful procurement evidence for ICT because it defines accessibility requirements for ICT products and services, including software, hardware, and combinations of both. It can make supplier evidence more testable when the report identifies the exact version of the standard, the clauses assessed, the product or service version, the test method, and the result for each relevant requirement.

The boundary matters. Under the EAA, harmonised standards or parts of standards create a presumption of conformity only for the accessibility requirements they cover and only where their references have been published in the Official Journal of the European Union. Procurement wording should therefore ask suppliers to explain coverage gaps, partially applied standards, and alternative solutions instead of treating one standard name as a blanket conformity claim.

The acceptance pack should let a buyer, auditor, or authority understand what was assessed without relying on sales language. It should separate product evidence from service evidence because the Directive uses different documentation mechanisms for products and services.

For product purchases, the Directive points to technical documentation, conformity assessment, an EU declaration of conformity, CE marking, and records that authorities can request. For services, it requires information explaining how the service meets applicable accessibility requirements and procedures that keep the service conforming when the service, requirements, standards, or technical specifications change.

Procurement language should be narrow enough to be verifiable. Instead of saying that a supplier must be 'fully EAA compliant', require evidence that the named product or service meets the applicable EAA accessibility requirements for the bought configuration and use case, or identify the gaps and the corrective action plan.

Do not make the buyer's acceptance decision broader than the evidence. A standards report may support a clause set, a supplier declaration may support a product model, and service information may support a live service process; none of them automatically proves every EAA, procurement, CE-marking, or future-change obligation.

Start with the default rule: Member States apply the EAA national measures from 28 June 2025, and service providers must design and provide in-scope services in accordance with the applicable accessibility requirements.

Article 32 then narrows what may continue. During the transition period ending on 28 June 2030, service providers may continue providing services using products that were lawfully used by them to provide similar services before the end of that period. This should be recorded as a product-use transition position, not as proof that the whole service is outside the EAA.

A separate contract rule applies to service contracts agreed before 28 June 2025. Those contracts may continue without alteration until they expire, but not for longer than five years from 28 June 2025. A renewal, amendment, replacement contract, new service launch, or materially changed service should therefore be treated as a trigger to reassess the service instead of relying on the old-contract position.

A service-provider transition file should prove why the transition rule applies to the specific service, contract, product, or terminal. It should not say only that the service existed before the EAA application date.

For services, Article 13 requires service providers to prepare information explaining how services meet applicable accessibility requirements, make that information publicly available in written and oral format including in an accessible manner, and keep it for as long as the service is in operation. Keep the Article 32 transition record next to that service information so a competent authority can understand both the conformity position and any temporary reliance on transition.

Article 13 requires service providers to keep procedures in place so the provision of services remains in conformity. It expressly calls out changes in the characteristics of the service, changes in applicable accessibility requirements, and changes in harmonised standards or technical specifications used for the conformity position.

Those same triggers should reopen any Article 32 transition position. A changed service, altered contract, replaced product, relocated or upgraded terminal, new supplier, new harmonised-standard claim, complaint, incident, or authority request may mean the old transition evidence no longer matches the service being provided.

The main risk is turning a narrow transition provision into an unsupported deadline. Article 32 should be applied to specific records: an existing service contract, a product used to provide similar services, or a self-service terminal with an entry-into-use history.

Avoid relying on shorthand dates without the facts behind them. For example, a terminal analysis should not stop at a generic future removal date; it should show whether the Member State provided the Article 32(2) option, whether the terminal was lawfully used before 28 June 2025, when it entered into use, and when its economically useful life ends.

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.

All covered services 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.

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. The safer scope question is 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.

The European Accessibility Act makes the applicable Annex I accessibility requirements the legal target for covered products and services. Article 15 creates a presumption of conformity only where products or services conform with harmonised standards, or parts of them, whose references have been published in the Official Journal of the European Union and only so far as those standards cover the relevant EAA requirements.

EN 301 549 is the practical ICT bridge. ETSI describes it as a European standard for ICT products and services and says it applies to software, hardware, and combinations of hardware and software. The current EN 301 549 V3.2.1 page says the standard supports the Web Accessibility Directive and is planned to be updated to support Directive (EU) 2019/882.

For WCAG evidence, the important point is narrow: EN 301 549 V3.2.1 reflects WCAG 2.1 content in clauses 9, 10, and 11 for web content, non-web documents, and software, and its Annex C explains how to determine conformance with individual requirements. A WCAG report is strongest when it is written as evidence for those EN 301 549 requirements, not as a standalone EAA conclusion.

A useful WCAG evidence record lets a reviewer reconstruct what was tested and why it was relevant. Treat each record as a clause-level test artifact: identify the asset, the user journey or screen, the EN 301 549 requirement, the WCAG success criterion where applicable, the test method, the result, the defect, and the fix.

For products, the EAA technical documentation must make it possible to assess conformity with relevant accessibility requirements and list harmonised standards or technical specifications applied in full or in part. For services, the service provider must explain how the service meets the applicable accessibility requirements and keep that information for as long as the service is in operation. WCAG evidence should feed those records rather than replace them.

WCAG is not the same thing as EN 301 549, and EN 301 549 is not the whole EAA analysis. EN 301 549 includes functional performance statements and requirements beyond WCAG-derived web criteria, and the EAA includes legal duties about covered products and services, economic operators, conformity assessment, service information, corrective action, and cooperation with authorities.

Do not convert a clean WCAG test into unsupported claims such as 'EAA compliant', 'EN 301 549 compliant', or 'presumed compliant' unless the record shows the exact scope of the claim and the standards or technical specifications actually relied on. If the test covered only sampled pages, say that. If it covered only a checkout journey, say that. If documents, mobile app screens, hardware controls, support services, or procurement evidence were not tested, say that too.

Use this checklist before relying on a WCAG report in an EAA evidence pack. The goal is a bounded, reviewable conclusion: what the test proves, what it does not prove, and what additional EAA or EN 301 549 evidence is still needed.

The product list is closed and category based. A product is not covered merely because it has software, a screen, a web portal, or an accessibility feature. Check whether it fits one of the Article 2 product categories and then identify the product-side economic operator: manufacturer, authorised representative, importer, or distributor.

Article 3 defines a product as a good produced through a manufacturing process, excluding food, feed, living plants and animals, products of human origin, and products of plants and animals relating directly to future reproduction. That definition matters when a connected offer combines hardware, software, and an online service.

For services, the EAA focuses on consumer-facing categories. Article 3 defines a service provider as a natural or legal person that provides a service on the Union market or offers to provide such a service to consumers in the Union.

The service category is not always the same as the underlying sector label. For transport, Article 2 covers specific digital and terminal elements of air, bus, rail, and waterborne passenger transport services, with a narrower rule for urban, suburban, and regional transport services.

Mixed offers need two checks. Hardware and operating systems are product-side items when they are placed on the market. Online journeys, banking, e-books, ticketing, media access, electronic communications, and e-commerce are service-side items when provided to consumers. The same commercial offer can therefore need both a product scope record and a service scope record.

Article 2 also limits some website and mobile application content. These limits do not remove an entire covered service from scope; they identify content types that the Directive says it does not apply to.