EU Accessibility Act Products and Services in Scope

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 both the terminal type and its actual use. Payment terminals are listed directly. The other named types are automated teller machines, ticketing machines, check-in machines, and interactive self-service terminals providing information, and they are product categories only when dedicated to services covered by the Directive. Information terminals installed as integrated parts of vehicles, aircraft, ships, or rolling stock are expressly excluded from this product category.

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 service accessibility requirements and the obligations linked to those requirements. Article 2 also excludes particular website and mobile-app content: pre-recorded time-based media and office file formats published before 28 June 2025; navigational maps when essential information is provided in an accessible digital manner; third-party content that is neither funded, developed by, nor under the operator's control; and archives containing only content not updated or edited after 28 June 2025. These content exclusions do not by themselves remove the rest of a covered service from scope.

The main application date is 28 June 2025, but Article 32 creates narrow transition branches. Service contracts agreed before that date may continue unchanged until they expire, but not beyond 28 June 2030. Until 28 June 2030, service providers may continue providing similar services with products they lawfully used for that purpose before 28 June 2025. A Member State may also allow an existing self-service terminal to remain in similar service use until the end of its economically useful life, capped at 20 years after entry into use. Record the national rule and the facts for the specific contract, product, or terminal.

Everyday labels can produce the wrong scope result. A scope memo should quote or paraphrase the relevant Article 3 definition, 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.

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.