The European Accessibility Act 2025: What Employers and Organisations Must Know

What Is the European Accessibility Act?

The European Accessibility Act (EAA), formally Directive (EU) 2019/882 of the European Parliament and of the Council, was adopted on 17 April 2019. Member states had to adopt and publish the national laws transposing it by 28 June 2022, and to apply those measures from 28 June 2025.

According to the European Commission, the EAA aims to improve the functioning of the internal market for accessible products and services by removing barriers created by different rules in member states. It sits alongside the Web Accessibility Directive (2016/2102), which already obliges public sector bodies to make their websites and mobile apps accessible.

Why Was It Needed?

Before the EAA, accessibility requirements for private sector products and services varied across EU member states. The directive's recitals note that these divergent national rules discourage businesses — especially SMEs and microenterprises — from trading across borders, and limit access for consumers with disabilities.

The EAA harmonises requirements, so a product or service that meets EAA requirements in one member state should meet them across the EU.

What Is Covered?

Products

The EAA applies to the following products placed on the market after 28 June 2025:

• Consumer general purpose computer hardware systems and their operating systems
• Self-service terminals: payment terminals, ATMs, ticketing machines, check-in machines, and interactive self-service terminals providing information
• Consumer terminal equipment with interactive computing capability used for electronic communications services (for example, smartphones)
• Consumer terminal equipment with interactive computing capability used for accessing audiovisual media services (for example, smart TV equipment)
• E-readers

Services

The EAA applies to the following services provided to consumers after 28 June 2025:

• Electronic communications services (phone, internet, messaging)
• Services providing access to audiovisual media services
• Elements of air, bus, rail, and waterborne passenger transport services (including websites, apps, e-ticketing and information)
• Consumer banking services
• E-books and dedicated software
• E-commerce services (online sales of products and services via websites and apps)

It also applies to answering emergency communications to the single European emergency number 112.

What Does Accessibility Mean Under the EAA?

The EAA sets functional accessibility requirements in its annexes rather than naming a single technical standard. For services, websites and mobile apps (and electronic information needed to provide the service) must be made:

• Perceivable
• Operable
• Understandable
• Robust

Products and services that conform to harmonised standards published in the Official Journal are presumed to conform to the EAA's requirements, as far as those standards cover them (Article 15).

In practice, the key European ICT accessibility standard is EN 301 549, which incorporates WCAG 2.1 Level AA for web content. The W3C's policy tracker lists WCAG 2.2 as the WCAG version relevant to the EAA, so building to current WCAG at Level AA is the sensible baseline for digital products and services.

Who Must Comply?

The EAA applies to economic operators (manufacturers, importers, distributors) placing covered products on the EU market and service providers providing covered services to consumers in the EU — including non-EU companies selling into the EU market.

Microenterprise Exemption

A microenterprise is an enterprise that employs fewer than 10 persons and has an annual turnover or annual balance sheet total not exceeding EUR 2 million. Microenterprises providing services are exempt from the EAA's accessibility requirements for services. This exemption does not cover products, although microenterprises dealing with products do not have to document a disproportionate burden assessment.

However, if a microenterprise supplies to larger businesses or public bodies that must comply, there may be commercial pressure to meet accessibility standards regardless of the formal exemption.

Fundamental Alteration and Disproportionate Burden

The accessibility requirements apply only to the extent that compliance does not require a fundamental alteration of the basic nature of the product or service, and does not impose a disproportionate burden on the operator (Article 14). Operators relying on this must:

• Carry out an assessment using the criteria in Annex VI
• Document the assessment and keep the results, providing a copy to the authorities on request
• For service providers, renew the assessment when the service is altered, when authorities request it, and in any event at least every five years

This exemption is narrower than it appears: the directive's recitals state that lack of priority, time or knowledge are not legitimate reasons, and the requirements still apply to the extent they do not impose a disproportionate burden.

Enforcement and Penalties

Each EU member state must designate market surveillance authorities (for products) and authorities responsible for checking compliance of services. Penalties are set nationally but must be:

• Effective
• Proportionate
• Dissuasive

Consumer redress: Member states must ensure that consumers can take action before the courts or competent administrative bodies, and that organisations with a legitimate interest can act on their behalf or in their support.

Transitional measures: Member states may allow a transitional period ending on 28 June 2030 for service providers using products they lawfully used before that date, and self-service terminals already in use can continue until the end of their economically useful life, but no longer than 20 years after entry into use.

Relationship With Other Standards and Directives

Practical Checklist for Organisations

Immediate (if not already done):

• Audit covered products/services against current WCAG at Level AA and EN 301 549
• Review customer-facing digital interfaces (website, app, booking system) for accessibility
• Assess ATMs, ticketing, and payment terminals if applicable
• Check whether your organisation qualifies for the microenterprise exemption (services only)

Ongoing:

• Publish accessibility information for covered services
• Establish a process to receive and respond to accessibility complaints
• Include accessibility requirements in procurement of new digital systems and third-party services
• Train product, design, and development teams on EAA requirements

Compliance documentation:

• Maintain records of accessibility assessments
• If claiming disproportionate burden, document the assessment
• Provide a contact point for accessibility queries

Sources

• Directive (EU) 2019/882 (EAA) — full text: https://www.legislation.gov.uk/eudr/2019/882/contents
• European Commission: European Accessibility Act — https://employment-social-affairs.ec.europa.eu/policies-and-activities/social-protection-social-inclusion/persons-disabilities/union-equality-strategy-rights-persons-disabilities-2021-2030/european-accessibility-act_en
• European Commission: Strategy for the rights of persons with disabilities — https://employment-social-affairs.ec.europa.eu/policies-and-activities/social-protection-social-inclusion/persons-disabilities/union-equality-strategy-rights-persons-disabilities-2021-2030_en
• W3C Web Accessibility Initiative: EU accessibility laws and policies — https://www.w3.org/WAI/policies/european-union/

National enforcement approaches and penalties are subject to member state implementation.