The European Accessibility Act is now in force: what it actually requires

The European Accessibility Act (EAA) has applied since 28 June 2025. If you sell to consumers in the EU, the question is no longer "will this affect us?" but "are we meeting it?" This is a plain-English run-through of who the EAA covers, what it actually asks for, and what to do if you are behind. It is guidance, not legal advice - confirm specifics with the official text or a qualified adviser.

What the EAA is

The EAA is Directive (EU) 2019/882. Rather than leave accessibility rules to fragment country by country, it sets one set of requirements for a defined list of products and services sold to consumers across the EU. It was adopted in 2019, member states had to write it into national law by 28 June 2022, and the requirements have applied to the market since 28 June 2025.

Who it covers

The EAA does not cover every website. It targets specific products and services.

• Products: computers and operating systems, smartphones, TVs with digital television capability, e-readers, ATMs, ticketing and check-in machines, and payment terminals.
• Services: e-commerce, consumer banking, e-books, electronic communications (telephony), access to audiovisual media services, and passenger transport (air, bus, rail and waterborne).

If you run an online shop selling to EU consumers, operate consumer banking, or sell e-books, you are squarely in scope. The duty attaches to the service as experienced by the consumer - your website, your app, your checkout.

The micro-enterprise carve-out (read it carefully)

There is one exemption that is widely misread. Micro-enterprises - fewer than 10 staff and annual turnover or balance sheet of €2 million or less - are exempt, but only when they are providing services. A micro-enterprise that manufactures or distributes a covered product is not exempt. So a tiny online retailer providing an e-commerce service may fall under the exemption; a small firm shipping covered hardware does not.

What "accessible" means in practice

The directive itself is written in terms of functional outcomes, not code. The way you demonstrate conformance is through the EU's harmonised standard, EN 301 549, which for web and mobile content incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. In other words: meet WCAG 2.1 AA on your website and app, and you have a presumption of conformity for the digital part of your obligations.

A practical note on versions: WCAG 2.2 is the current version of the guidelines and is backwards-compatible with 2.1 - it only adds criteria. Meeting WCAG 2.2 AA therefore also satisfies 2.1 AA, so targeting 2.2 is the safe, future-proof choice even though the law still names 2.1.

The dates that still matter

28 June 2025 was the headline, but two transition points remain:

• Existing service contracts signed before that date may continue under the old terms until 28 June 2030, unless they are substantially changed sooner.
• Self-service terminals already in use before 28 June 2025 may keep operating until the end of their economic life, up to a maximum of 20 years.

Neither is a reason to wait. New services, and any meaningful change to an existing one, are expected to be accessible now.

Penalties

The EAA leaves enforcement and penalties to each member state, with the instruction that they be "effective, proportionate and dissuasive." That means the specifics - fines, withdrawal of a product from the market, suspension of a service - vary by country. The reputational and commercial exposure is consistent everywhere: an inaccessible checkout loses customers, and roughly 1 in 6 people live with a significant disability.

What to do now

1. Confirm scope. Are you providing a covered service (e-commerce, banking, e-books, transport, electronic communications) or a covered product to EU consumers? If yes, the EAA applies.
2. Measure against WCAG 2.2 AA. Run an automated scan to catch the obvious failures, then test with a keyboard and a screen reader - automated tools only find a minority of issues. Our free WCAG 2.2 AA checklist lists every Level A and AA criterion in plain English.
3. Fix the blocking issues first. Low-contrast text, missing form labels, keyboard traps and unlabelled controls are common and high-impact. Start there.
4. Publish an accessibility statement describing your conformance status, any known gaps, and how people can get help.
5. Keep it current. Accessibility is not a one-off project; bake it into your release process so new pages don't regress.

For a fuller picture of who the EAA applies to and how it sits alongside the US ADA, see our European Accessibility Act explainer and the compliance deadlines timeline.