What is the European Accessibility Act?
By WCAG Auditor · Published · Updated
The European Accessibility Act (EAA) — Directive (EU) 2019/882 — is an EU law that sets common accessibility requirements for a range of products and services so they work for people with disabilities across the single market. It applies from 28 June 2025.
This page is a plain-language orientation to the Directive: what it is, who has to act on it, what it covers, and how the European standard EN 301 549 fits into the picture. It is informational, not legal advice — see the note at the end.
Why it exists
Before the EAA, accessibility rules differed from one EU Member State to the next. A business selling the same e-commerce storefront or banking app across several countries could face a different accessibility bar in each one, or none at all in some. The Directive harmonizes the requirements so a product or service that is accessible in one EU country is accessible across the EU — reducing fragmentation and duplicated compliance work for businesses that operate across borders, and giving the estimated tens of millions of people in the EU with a disability a consistent floor of access wherever they are in the single market.
That harmonization cuts both ways. It is a compliance obligation for the organizations in scope, and it is also a design standard: the requirements the EAA sets in motion are largely the same requirements that make a product easier to use for everyone, not only for people who rely on assistive technology. A more legible error message, a form that survives keyboard-only navigation, or captions on a product video all fall under the same umbrella.
When it applies
The EAA’s timeline runs over more than a decade, and it is worth having the full sequence in view rather than just the headline date:
- 17 April 2019 — Directive (EU) 2019/882 was adopted.
- 28 June 2022 — the deadline for EU Member States to transpose the Directive into their own national law.
- 28 June 2025 — the EAA applies. Covered products placed on the market and covered services provided from this date onward must meet the accessibility requirements.
- 28 June 2030 — a transitional date: service providers may continue using products that were already lawfully in use before 28 June 2025, up until this date.
- Up to 20 years — self-service terminals (think ATMs, ticket machines, check-in kiosks) that were lawfully in use before 28 June 2025 may keep running until the end of their economic life, a runway capped at about twenty years.
In practice this means the EAA is already in force today, but it is not a single cliff-edge for every product and service a business runs. Equipment that was already deployed before June 2025 gets a longer runway than something launched or re-launched after it — which is exactly why “are we in scope” and “are we compliant today” can have different answers for the same organization, depending on what was already in the field and when.
Who has to comply
The EAA’s obligations fall on economic operators — manufacturers, importers, distributors and service providers — placing covered products on, or providing covered services in, the EU market. The obligation is ongoing, not a one-time launch checkbox: covered products placed on the market and covered services provided from 28 June 2025 onward have to meet the requirements, subject to the transitional and self-service-terminal allowances described above.
One deliberate carve-out sits inside that obligation. Microenterprises — organizations with fewer than 10 people and annual turnover or balance-sheet total of €2 million or less — that provide services are exempt from the accessibility requirements. Note the scope of that exemption carefully: it is service-specific, the product-side rules are different, and even a microenterprise that is legally exempt still benefits commercially from designing accessibly — nothing stops an exempt organization from building to the standard anyway, and doing so tends to widen its addressable market rather than narrow it. Whether a specific organization qualifies as a microenterprise, and whether a specific offering counts as a covered service or product, is a legal determination for that organization to make.
What it covers
The EAA targets consumer-facing digital products and services, listed in its Annex I:
- E-commerce — consumer-facing online shops and apps, across the buying journey end-to-end.
- Consumer banking — online and mobile banking services, statements and authentication.
- E-books — e-books themselves and the dedicated software used to read them.
- Electronic communications services — and the consumer terminal equipment used with them.
- Access to audiovisual media services — catalogues, players and electronic programme guides.
- Passenger transport — air, bus, rail and waterborne — websites, apps, e-ticketing, real-time travel information, and interactive self-service terminals.
- Self-service terminals — ATMs, ticketing and check-in machines, interactive payment terminals.
- Consumer general-purpose computers — and the operating systems that run on them.
That is a wide net. Most organizations selling digital products or services to EU consumers touch at least one of these categories, often more than one at once — a bank with a mobile app and branch ATMs, for instance, sits inside both consumer banking and self-service terminals. See Am I in scope? for a sector-by-sector breakdown.
Accessibility statements and enforcement
The EAA expects covered economic operators to make accessibility information available — an accessibility statement describing how a product or service meets the applicable requirements — alongside the product or service itself, so a customer or an authority can see the basis for a compliance claim rather than take it on faith.
Market surveillance, meanwhile, is a Member State matter. Each Member State designates its own enforcement authority and sets its own penalties for non-compliance, so what actually happens when a covered product or service falls short can vary from one country to the next, even though the underlying accessibility requirements are the same across the EU.
How EN 301 549 fits in
The EAA itself does not list pixel-level technical requirements — it sets accessibility outcomes. The yardstick used to turn those outcomes into testable, auditable requirements is the European standard EN 301 549.
Its v3.2.1 revision is already cited in the EU Official Journal today, but under a different Directive: the Web Accessibility Directive (EU) 2016/2102, which mainly covers public-sector websites and apps. Meeting EN 301 549 v3.2.1’s applicable clauses confers a presumption of conformity with that Directive, today.
Under the EAA, no revision of EN 301 549 is cited yet. Final draft EN 301 549 V4.1.0 (2026-06) — prepared under the European Commission’s standardisation request C(2022) 6456 — is the first revision to carry the matching Annex ZB for the EAA, and the presumption of conformity applies under the EAA once a revision is cited in the Official Journal. Until then, an EN 301 549 report is the strongest evidence of conformance available for the EAA, not a presumption under it.
EN 301 549 in turn is anchored on WCAG: v3.2.1 maps to WCAG 2.1 AA, and the v4.1.0 (2026-06) final draft maps to WCAG 2.2 AA — which is why version-aware reporting matters, and why a report that quietly mixes the two revisions is worth being suspicious of. The mechanics of the standard itself — its chapters, its clause catalog, and what “presumption of conformity” means in more precise terms — are the subject of EN 301 549, WCAG, and the presumption of conformity.
Getting ready
None of the above requires a law degree to act on: the practical work is identifying which Annex I sectors your products or services fall into, checking whether the microenterprise exemption genuinely applies, and gathering evidence — typically a chapter-by-chapter EN 301 549 conformance report, an EAA-positioned VPAT, and an accessibility statement — that shows where you stand today and what remains open.
This overview is informational only, not legal advice. Whether your specific product or service is in scope, and how the timeline above applies to your organization, is a legal determination for your organization to make. If you want to turn this into evidence rather than a summary, see how we help, check whether you’re in scope, or get in touch.