The European Accessibility Act: What Every EU Employer Needs to Know by June 2025

What Is the EAA?

The European Accessibility Act (Directive 2019/882) is an EU directive requiring accessibility of specified products and services placed on the EU market. Member states had until 28 June 2022 to transpose it into national law, with compliance required from 28 June 2025.

While the EAA primarily regulates products and services sold to consumers, it has profound implications for employers because the same products and services are used in workplaces.

What the EAA Covers

Products

• Computers and operating systems: All hardware and software must meet accessibility requirements
• Smartphones and tablets: Must be usable by people with sensory, cognitive, and motor impairments
• Self-service terminals: ATMs, ticketing machines, check-in kiosks, and — critically — any self-service terminal in a workplace (canteen kiosks, meeting room booking screens, time-clock terminals)
• E-readers: Must support accessible formats
• Consumer equipment for telecommunications: Phones, video calls, messaging

Services

• E-commerce: Online shops and marketplaces must be accessible
• Banking services: Online banking, ATMs, payment terminals
• Telecommunications: Phone services, messaging, video calls
• Transport: Websites, apps, ticketing, real-time information
• Audiovisual media services: Streaming platforms, digital TV
• E-books: Digital publications must support accessibility features

The Workplace Connection

Every product and service listed above is used in workplaces:

• Employees use computers and smartphones daily
• Many workplaces have self-service terminals (canteens, meeting rooms, security)
• HR and payroll are increasingly e-commerce style platforms
• Internal banking and expenses processes are digital
• Workplace telecommunications (Teams, Zoom, phone systems) must be accessible
• Training is increasingly delivered as audiovisual/e-learning content

Accessibility Requirements

The EAA specifies functional accessibility requirements based on the European Standard EN 301 549 (which incorporates WCAG 2.1 for web content):

Key Requirements

1. Perceivable: Information must be presentable in ways all users can perceive

- Text alternatives for images

- Captions for audio/video

- Sufficient colour contrast

- Content resizable without loss of function

1. Operable: Users must be able to operate the interface

- Keyboard accessibility (all functions reachable without a mouse)

- Sufficient time to complete tasks

- No content that triggers seizures

- Clear navigation and consistent interfaces

1. Understandable: Information and interface must be understandable

- Readable text (clear language, logical structure)

- Predictable behaviour

- Input assistance (error prevention and correction)

1. Robust: Content must be compatible with assistive technologies

- Screen reader compatibility

- Voice control support

- Alternative input device support

Product-Specific Requirements

• Self-service terminals: Must have speech output, tactile indicators, large text options, hearing loop compatibility, and be reachable from a wheelchair
• Computers: OS must include built-in accessibility features (screen reader, magnification, high contrast, voice control)

What Employers Must Do

1. Audit Workplace Technology

By June 2025, assess whether workplace systems comply with EAA requirements:

• Self-service terminals: Do canteen kiosks, meeting room screens, and time clocks meet accessibility requirements? (Most currently do not.)
• HR systems: Can your HRIS, payroll, and benefits platforms be operated by screen reader? Keyboard only? With voice control?
• Learning platforms: Are e-learning modules captioned? Do they work with assistive technology?
• Communication tools: Do your video conferencing, messaging, and phone systems support accessibility features?
• Intranet: Does your corporate intranet meet WCAG 2.1 AA?
• Document management: Are standard templates accessible? Can documents be read by screen readers?

2. Procurement Policy

Update procurement policies to require EAA compliance:

• New purchases: All new technology, systems, and services must meet EN 301 549
• Vendor assessment: Include accessibility requirements in RFPs and vendor evaluation criteria
• VPAT/ACR: Request Voluntary Product Accessibility Templates from all technology vendors
• Contract clauses: Include accessibility compliance as a contractual requirement with remediation obligations
• Renewals: When existing contracts renew, add accessibility requirements

3. Remediate Existing Systems

For systems that cannot be immediately replaced:

• Prioritise by impact: Focus first on systems used daily by many employees (HR, email, intranet)
• Alternative access: Where a system cannot be made accessible, provide an accessible alternative pathway
• Timeline: Create a remediation roadmap — the EAA allows a transition period for existing products/services until June 2030
• Budget: Allocate specific budget for accessibility remediation

4. Build Internal Capability

• Accessibility expertise: Hire or train staff in digital accessibility (IAAP certification available)
• Developer training: All in-house developers trained in accessible development
• Testing: Regular accessibility testing of workplace systems (automated + manual + user testing)
• Governance: Assign accountability for workplace accessibility compliance

Enforcement

National Market Surveillance

• Each member state designates a market surveillance authority
• Authorities can inspect products and services, request evidence of compliance, and take enforcement action
• Non-compliant products can be withdrawn from the market
• Fines: Set by each member state — expected to be substantial

Employee Rights

• The EAA strengthens the case for reasonable accommodation claims:

- If accessible technology exists (because the EAA requires it), employers cannot argue that accessibility is "unreasonable"

- "We couldn't find an accessible system" becomes less credible when the EAA mandates accessibility

• Combined with the Employment Equality Directive, the EAA creates a powerful framework for workplace accessibility

The Disproportionate Burden Exception

The EAA includes a "disproportionate burden" exception for micro-enterprises (fewer than 10 employees, turnover under €2 million):

• Micro-enterprises may be exempt from some requirements
• This exception is narrow and requires documented justification
• Medium and large employers cannot rely on this exception

Timeline and Preparation

Now (Before June 2025)

• Complete workplace technology accessibility audit
• Update procurement policies
• Begin remediation of critical systems
• Train IT and HR teams

June 2025

• EAA enters force — all new products and services must comply
• National enforcement begins
• Start tracking compliance across workplace systems

2025–2030

• Remediate existing systems on priority basis
• Monitor vendor compliance and escalate non-compliance
• Build accessibility into organisational culture (not just compliance)

June 2030

• All products and services (including those already on the market before 2025) must comply
• Full enforcement of accessibility requirements

Resources

• European Commission: European Accessibility Act — ec.europa.eu/social/accessibility
• EN 301 549: European Accessibility Standard — www.etsi.org
• European Disability Forum: EAA implementation tracker
• Web Accessibility Initiative (WAI): WCAG 2.1 guidelines
• IAAP (International Association of Accessibility Professionals): Certification
• Funka: European accessibility consulting and testing