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FAQEU

EU Accessibility Act FAQ Covered Products and Services

The EU Accessibility Act does not cover every product or every digital service. Article 2 lists specific products, consumer services, and 112 emergency communications.

This page helps separate product scope from service scope, check Article 3 definitions, and keep a narrow record of why a category is in scope, out of scope, or limited.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections7 primary sources
Overview

Article 2 of Directive (EU) 2019/882 is the starting point for EU Accessibility Act scope. It covers named products placed on the market after 28 June 2025, named services provided to consumers after that date subject to Article 32, and . Member States could defer the national measures for the 112 answering duty until 28 June 2027, so check the applicable national start date. Article 3 then defines key terms such as product, service provider, , , payment terminal, consumer banking services, e-commerce services, and passenger transport service categories. National transposition law controls enforcement, procedure, penalties, and any national option used by the Directive.

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4 of 4 questions
Question 1

Which products are covered by Article 2?

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 : 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.

  • general purpose computer hardware systems and operating systems for those hardware systems.
  • Payment terminals; and ATMs, ticketing machines, check-in machines and interactive information terminals dedicated to covered services. The exclusion for terminals integrated into vehicles, aircraft, ships or rolling stock applies to interactive information terminals, not automatically to every terminal category.
  • terminal equipment with interactive computing capability used for electronic communications services.
  • terminal equipment with interactive computing capability used for accessing audiovisual media services.
  • E-readers.

Which products does the EU Accessibility Act cover?

Article 2 covers general purpose computer hardware systems and their operating systems, payment terminals, specified self-service terminals used for covered services, consumer terminal equipment used for electronic communications services, consumer terminal equipment used for accessing audiovisual media services, and e-readers. Treat the item as a product-side question when the record concerns a manufactured good placed on the Union market and product economic operators such as the manufacturer, importer, or distributor.

Does the EU Accessibility Act cover every connected device or every app?

No. Article 2 lists specific product categories and specific service categories. A connected device, website, mobile app, or software component should be mapped to a listed product or service category before being treated as EAA scope. For example, an e-commerce checkout can be in scope as an e-commerce service, while unrelated third-party content not funded, developed, or controlled by the is excluded from the website and mobile application content scope.

Question 2

Which services are covered by Article 2?

For services, the EAA focuses on -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. Article 2 lists separately, and Article 31 allowed Member States to apply the national measures for that duty as late as 28 June 2027.

Article 3 defines a as a natural person acting for purposes outside that person's trade, business, craft, or profession. The same platform or feature can therefore need separate conclusions for a consumer offer and a business-only offer; technology alone does not settle service scope.

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.

  • Electronic communications services, except transmission services used for machine-to-machine services.
  • Services providing access to audiovisual media services, including services used to identify, select, receive information on, and view audiovisual media services and related accessibility features.
  • Air, bus, rail, and waterborne passenger transport elements: websites, mobile device-based services, electronic tickets and ticketing services, transport service information including real-time travel information, and covered interactive self-service terminals.
  • banking services, including the Article 3 banking and financial service categories listed for consumers.
  • E-books and dedicated software.
  • E-commerce services, defined as services provided at a distance through websites and mobile device-based services by electronic means at the individual request of a with a view to concluding a consumer contract.
  • Answering emergency communications to the single European emergency number 112.

Which services does the EU Accessibility Act cover?

Article 2 covers electronic communications services, access services for audiovisual media services, specified digital and terminal elements of air, bus, rail, and waterborne passenger transport services, banking services, e-books and dedicated software, and e-commerce services. These listed services must be provided to consumers, meaning natural persons acting outside their trade, business, craft, or profession. Article 2 separately covers , and Member States could defer the national measures for that duty until 28 June 2027.

How should transport services be scoped under the EU Accessibility Act?

For air, bus, rail, and waterborne passenger transport, Article 2 focuses on websites, mobile device-based services including apps, electronic tickets and ticketing services, transport service information including real-time travel information, and interactive self-service terminals located in the Union. Urban, suburban, and regional transport services are treated more narrowly: only the interactive self-service terminal element under Article 2(2)(c)(v) applies.

Question 3

Where are the product-service boundaries and exclusions?

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.

  • Pre-recorded time-based media published before 28 June 2025.
  • Office file formats published before 28 June 2025.
  • Online maps and mapping services when essential navigational information is provided in an accessible digital manner.
  • Third-party content that is not funded, developed by, or under the control of the concerned.
  • Website and mobile application archives that only contain content not updated or edited after 28 June 2025.
  • Microenterprises providing services are addressed separately in the Directive; do not use the microenterprise concept to remove product-side scope without checking the product provisions.

What is the difference between an EU Accessibility Act product and service decision?

A product decision asks whether a manufactured good falls into one of the Article 2 product categories and which product is responsible. A service decision asks whether a -facing service falls into one of the Article 2 service categories and whether the provider is offering or providing that service on the Union market. For mixed offers, keep both records if hardware, software, and the consumer journey each matter to the conclusion.

Which website or mobile app content is outside EU Accessibility Act Article 2?

Article 2 excludes specific website and mobile application content: pre-recorded time-based media and office file formats published before 28 June 2025, online maps where essential navigational information is accessible digitally, third-party content outside the 's funding, development, or control, and qualifying archives that are not updated or edited after 28 June 2025. These are content exclusions, not automatic exclusions for the rest of a covered service.

Question 4

Evidence records for a category decision

Keep evidence only for facts the scope conclusion actually depends on. A useful record should let a reviewer see the product or service facts, the Article 2 category, the Article 3 definition used, and the source relied on without reconstructing the project history.

Where a product or service is in scope, link the scope record to the accessibility requirements and evidence used for conformity work. Article 4 points covered products and services to Annex I accessibility requirements, while standards or technical specifications may be relevant when used to show how requirements are met.

  • Category conclusion: in scope, out of scope, limited content exclusion, or needs legal review.
  • Facts used: product model or service journey, -facing status, Union market connection, role, and whether the item is product-side, service-side, or both.
  • Article mapping: Article 2 paragraph and category, Article 3 definition if relevant, and any Article 2 website or mobile application content exclusion relied on.
  • Evidence attachments: screenshots or journey descriptions, product specifications, operating-system or terminal classification, service terms, supplier inputs, accessibility test references, and standards mapping where used.
  • Review triggers: new product model, new journey, change in service provider role, change in controlled third-party content, new transport or banking service element, or a change in the standard or technical specification relied on.
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Primary sources

References and citations

European Commission - European Accessibility Act
commission.europa.eu3 citations
Referenced sections
  • Commission overview used to cross-check public examples of EAA covered products and services.
  • Commission overview summarising the EAA product examples, including computers, operating systems, ATMs, ticketing machines, check-in machines, smartphones, and TV equipment.
  • Commission overview listing service examples such as telephony, audiovisual media access, transport-related services, banking, e-books, and e-commerce.
"Products and services covered"
More quoted passages
"services related to air, bus, rail and waterborne passenger transport"
Directive (EU) 2019/882 - Article 2 and Article 3
eur-lex.europa.eu2 citations
Referenced sections
  • Primary legal source for the EAA product categories and the Article 3 definitions of product, economic operator, consumer, and payment terminal.
  • Primary legal source for covered consumer service categories, Article 3 service definitions, and the separate 112 emergency communications scope rule.
"This Directive applies to the following products"
More quoted passages
"services provided to consumers"
ETSI - EN 301 549 ICT accessibility standard overview
etsi.org2 citations
Referenced sections
  • ETSI source for ICT product and service accessibility standard context used in evidence mapping for mixed hardware, software, and service offers.
  • ETSI source explaining that EN 301 549 covers ICT products and services such as software, hardware, and combinations of hardware and software, which helps evidence mixed product-service assessments.
"ICT products and services"
European Commission - harmonised standards overview
single-market-economy.ec.europa.eu2 citations
Referenced sections
  • Commission source for harmonised standards context where standards are used as part of an EAA conformity evidence record.
  • Commission source for the role of harmonised standards in supporting EU product and service conformity assessments where such standards are used.
"Harmonised standards are European standards"
Directive (EU) 2019/882 - Articles 4, 13, 14 and Annex I
eur-lex.europa.eu
Referenced sections
  • Primary legal source for linking Article 2 scope to Annex I accessibility requirements, service-provider conformity procedures, and fundamental-alteration or disproportionate-burden assessments.
"comply with the accessibility requirements set out in Annex I"
Directive (EU) 2019/882 - European Accessibility Act
eur-lex.europa.eu
Referenced sections
  • Primary legal source for Article 2 covered products and services, Article 3 definitions, Article 4 accessibility requirements, Article 14 limits, and Annex I.
"accessibility requirements for products and services"

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