FAQEU

EAA FAQ Service Transition Rules

Article 32 of Directive (EU) 2019/882 gives service providers limited transition rules; it is not a general delay of the European Accessibility Act for services.

This FAQ helps separate new or changed services, existing service contracts, products used to provide similar services, and self-service terminals before relying on a transition position.

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

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

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

For in-scope services, Member State measures under the EU Accessibility Act apply from 28 June 2025, but creates narrow transition rules. Service providers may continue using products lawfully used for similar services during a transition period ending on 28 June 2030, service contracts agreed before 28 June 2025 may continue unchanged only until expiry and no longer than five years from 28 June 2025, and self-service terminals have a separate asset-life rule where Member States provide it.

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4 of 4 questions
Question 1

Which EU Accessibility Act service transition rules apply after 28 June 2025?

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.

then narrows what may continue. During the transition period ending on 28 June 2030, service providers may continue providing services using products that they lawfully used to provide similar services before 28 June 2025. Recital 101 explains that this rule concerns products placed on the market before the application date and says the transition does not protect a replacement product. Record this 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.

  • Use 28 June 2025 as the date from which national EAA measures apply to in-scope services unless a specific transition rule fits the facts.
  • Use 28 June 2030 as the outer (1) transition endpoint for continuing services with qualifying lawfully used products and for unchanged pre-28 June 2025 service contracts that have not already expired.
  • Do not invent extra grace periods, phased enforcement dates, sector-specific deadline extensions, or a blanket 2030 readiness date unless the cited national implementing law or official source supports them.

Which services must be ready for the EU Accessibility Act from 28 June 2025?

In-scope services should be treated as needing EAA-compliant design and provision from 28 June 2025 unless a documented transition rule applies. Article 32 does not postpone the whole EAA for all services until 2030; it allows limited continuation for products used to provide similar services and for service contracts agreed before 28 June 2025, subject to the 28 June 2030 limit.

Can an existing service contract agreed before 28 June 2025 continue unchanged?

Yes, but only within 's limit: a service contract agreed before 28 June 2025 may continue without alteration until it expires, and no longer than five years from 28 June 2025. Record the contract signature date, expiry date, renewal or amendment rights, and whether any alteration has been made.

Do self-service terminals follow the same 28 June 2030 transition endpoint?

Not always. (2) lets Member States provide that self-service terminals lawfully used by service providers before 28 June 2025 may continue to be used for similar services until the end of their , but no longer than 20 years after their entry into use. That is an asset-by-asset rule, so keep the entry-into-use date and national implementation check with the terminal record.

Citations
Question 2

Evidence record for relying on an Article 32 service transition

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 transition record next to that service information so a competent authority can understand both the conformity position and any temporary reliance on transition.

  • Service scope: covered service category, Member States where the service is provided, consumer-facing journey, and responsible service provider.
  • Contract facts: agreement date, expiry date, renewal or alteration terms, change history, and the date by which the contract position must end.
  • Product-use facts: product identifier, service use case, proof it was lawfully used by the provider for similar services, and the 28 June 2030 transition endpoint relied on.
  • Terminal facts: terminal type, location, entry-into-use date, proof of lawful use before 28 June 2025, record, and the relevant national implementation rule.
  • Conformity evidence: Article 13 public service information, Annex I accessibility mapping, testing or supplier evidence, remediation log, complaints or authority correspondence, and any Article 14 assessment if fundamental alteration or disproportionate burden is claimed.
Citations
Recommended next step

Check the Article 32 record before relying on transition

This EAA FAQ helps separate the service, contract, product, and terminal facts before setting a remediation or contract-change plan.

Question 3

Change triggers that should reopen the transition assessment

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 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.

  • Contract alteration or renewal after 28 June 2025: reassess instead of treating the original contract date as enough.
  • Service characteristic change: reassess user journeys, public information, accessibility testing, and support processes.
  • Product or terminal replacement, major upgrade, relocation, or new deployment: check whether the facts still apply.
  • Replacement product: do not carry the predecessor's transition status forward. Assess the replacement against the requirements that apply when it is placed on the market and used for the service.
  • New or changed harmonised standards, technical specifications, national implementing rules, complaints, or authority correspondence: update the conformity and transition record.
  • Non-conformity finding: document corrective measures and competent-authority notifications where required.
Citations
Question 4

Common Article 32 mistakes to avoid

Do not turn a narrow transition provision into an unsupported deadline. Apply 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 (2) option, whether the terminal was lawfully used before 28 June 2025, when it entered into use, and when its ends.

  • Do not say all services have until 28 June 2030; Article 31 application from 28 June 2025 remains the starting point.
  • Do not keep an altered pre-28 June 2025 contract under the unchanged-contract rule without reassessing the alteration.
  • Do not apply the self-service-terminal rule to websites, mobile apps, e-commerce checkout flows, banking portals, or other service elements that are not terminals.
  • Do not publish a terminal deadline from a generic formula without checking entry into use, economic life, and national implementation.
  • Do not use a transition file as a substitute for Article 13 service information, accessibility testing, remediation, or authority-response records.
Citations
Primary sources

References and citations

accessible-eu-centre.ec.europa.eu
Referenced sections
  • AccessibleEU source listing EAA support materials and summarising key EAA timing for implementation context.
"Getting to know the European legislation on accessibility"
commission.europa.eu
Referenced sections
  • Commission policy source identifying the EAA as the EU directive for accessible products and services and explaining its internal-market purpose.
"accessible products and services"
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