EAA FAQ Service Transition Rules

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 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.

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.

Do not turn a narrow transition provision into an unsupported deadline. Apply Article 32 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.