Article 2 of Directive (EU) 2019/882 applies to a defined set of products placed on the EU market and services provided to consumers, not to every digital product or business service.
Use this page to classify covered product and service lines, separate consumer-facing scope from business-only activity, assign the right economic-operator role, and keep evidence for the conclusion.
Structured answer sets in this page tree.
Cited legal and guidance references.
The European Accessibility Act scope test starts with Article 2 and the Article 3 definitions. Record whether the offer is one of the named product categories, one of the named services provided to consumers, or supporting technology used in a covered service. Then record the operator role because product obligations sit with manufacturers, authorised representatives, importers and distributors, while service obligations sit with service providers.
Treat the product list as closed unless a national implementation measure or another Union act creates a separate duty. Article 2(1) covers products placed on the market after the Directive's application date, including consumer general purpose computer hardware systems and their operating systems, specified self-service terminals, consumer terminal equipment for electronic communications, consumer terminal equipment for audiovisual media access, and e-readers.
For self-service terminals, classify the terminal's actual use. Payment terminals are listed directly. Automated teller machines, ticketing machines, check-in machines, and interactive information terminals are covered when they are dedicated to services covered by the Directive, with an express exclusion for information terminals installed as integrated parts of vehicles, aircraft, ships or rolling stock.
Article 2(2) applies to named services provided to consumers. A business-to-business platform, internal employee tool, reseller portal or infrastructure service should not be marked in scope just because it is digital; the record needs to show a consumer recipient and one of the listed service types.
The listed service categories are electronic communications services, services providing access to audiovisual media services, specified passenger transport service elements, consumer banking services, e-books and dedicated software, and e-commerce services. Passenger transport scope is narrower for urban, suburban and regional transport: only the interactive self-service terminal element applies there.
Some common boundary cases are out of scope or exempt: microenterprises providing services are exempt from the accessibility requirements and related obligations, Article 2 also excludes certain website and mobile-app content such as 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 information is provided accessibly, third-party content outside the operator's control, and archived content that is not updated after 28 June 2025.
Most scope errors come from using everyday labels instead of Article 3 definitions. A scope memo should quote or paraphrase the exact definition used, then apply it to the product or service facts.
The most important boundary terms are product, service, service provider, consumer, making available on the market, placing on the market, manufacturer, importer, distributor, economic operator, consumer banking services, e-commerce services, consumer general purpose computer hardware system, interactive computing capability, e-book and dedicated software, and e-reader.
For products, scope is only half of the answer. The record also needs the role. Manufacturers are responsible for design and manufacture against the applicable accessibility requirements, technical documentation, conformity assessment, EU declaration of conformity and CE marking. Importers and distributors have separate verification, handling, cooperation and corrective-action duties.
An importer or distributor can become treated as the manufacturer where it places a product on the market under its own name or trademark, or modifies a product already placed on the market in a way that may affect compliance. That makes private-label and material-change scenarios important evidence points.
Use the Article 2 category, Article 3 definition, operator role, consumer boundary, and evidence attachments to make the scope conclusion reviewable before launch or procurement.
For services, the scope record should identify the consumer-facing service, the Article 2 service category, the provider, the EU market facts, and the product or interface used by the consumer. Subcontracting a part of the service does not by itself remove the service provider's accessibility responsibility for the covered service.
Service providers need evidence that explains how the service meets the applicable accessibility requirements. Annex V points to information in general terms and conditions or an equivalent document, a general service description in accessible formats, explanations needed to understand service operation, a description of how relevant Annex I requirements are met, and monitoring of the service delivery process.
A useful scope file should let product, legal, procurement, support and release teams reproduce the conclusion without rediscovering the law. Keep the record short, but make every conclusion traceable to Article 2, Article 3 and the operator role.
Do not use a single yes/no label without the facts behind it. For mixed offers, classify each product, service, consumer journey and operator role separately because the same business may be a manufacturer for one product line, an importer for another, and a service provider for a consumer digital service.
"the manufacturer declares on his sole responsibility"
"provide it with all information necessary"
"products and services must be accessible"