EU Regulation
European Accessibility Act Compliance Guide
The EAA enforcement deadline was June 28, 2025. Private businesses selling products or services in the EU must now comply, or face significant penalties.
The European Accessibility Act enforcement deadline passed on June 28, 2025. Businesses that have not achieved compliance are now subject to penalties enforced by national market surveillance authorities across EU member states.
What is the EAA?
The European Accessibility Act (Directive 2019/882) is a landmark EU law that harmonizes accessibility requirements across all 27 EU member states. Before the EAA, each member state had different (and often inconsistent) accessibility rules, creating fragmented compliance obligations for businesses operating across borders.
The EAA fills that gap by establishing common accessibility requirements for key products and services. It is primarily a market access law, meaning that non-compliant products and services can legally be barred from the EU market.
Note on scope: The EAA covers private-sector businesses. EU public sector websites and apps are separately governed by the Web Accessibility Directive (WAD), which has been in force since 2018.
Who Does it Apply To?
The EAA applies to manufacturers, importers, distributors, and service providers who place covered products or services on the EU market, regardless of where their business is based. A US-based company selling software to EU consumers must comply.
Microenterprise Exemption
Microenterprises providing services (not products) are exempt. A microenterprise has fewer than 10 employees AND annual turnover or balance sheet total not exceeding €2 million. This exemption is narrow. It does not apply to manufacturers of products.
Fundamental Alteration & Disproportionate Burden
Where compliance would require a fundamental alteration of a product or service, or impose a disproportionate burden, businesses may claim an exemption, but must document their assessment and notify the relevant national authority. This exemption must be reviewed annually.
Products and Services Covered
The EAA covers a defined list of products and services. If your business falls into any of these categories, you must comply:
Computers & Operating Systems
General-purpose hardware and consumer operating systems.
Smartphones & Tablets
Smartphones, tablets, and other interactive consumer devices.
TV Equipment
Consumer terminal equipment with interactive computing capability.
Banking Services
Online banking, payment terminals, ATMs, and financial services.
E-Commerce
Websites and apps for selling products or services to consumers.
E-Books & Readers
Electronic books and dedicated e-reader hardware.
Transport Services
Passenger transport by air, bus, rail, and water: ticketing and travel information.
Electronic Communications
Telephone services, voice over IP, messaging services.
Audiovisual Media
Services accessing audiovisual media (streaming services, video-on-demand).
Technical Requirements
The EAA sets functional accessibility requirements covering how products and services must perform. Annex I of the directive specifies requirements in four categories:
General Use Requirements
Products and services must provide information about their accessibility features. They must avoid overriding the user's platform accessibility settings (e.g., high-contrast mode, large text). Multiple sensory channels must be used where appropriate.
User Interface & Design Requirements
Content must be perceivable, operable, understandable, and robust. Services must be flexible to meet different users' needs and allow sufficient time to complete tasks. Sequential actions must be usable by people who cannot perform simultaneous inputs.
Support Services
Customer support services (help desks, chatbots, online FAQs) must communicate accessibility features and compatibility with assistive technologies.
EN 301 549 and the applicable WCAG version
The EAA's functional requirements are implemented technically through EN 301 549, the European harmonized standard for ICT accessibility. EN 301 549 v3.2.1, the version harmonised in the Official Journal, incorporates WCAG 2.1 Level AA as the technical benchmark for web content. Later revisions of the standard align with WCAG 2.2; check which version your target market's national transposition cites before treating a newer edition as the applicable bar.
In practical terms: WCAG 2.2 adds success criteria to WCAG 2.1 without removing them, so a site that conforms to WCAG 2.2 Level AA also meets the WCAG 2.1 Level AA web content requirements of EN 301 549 v3.2.1 and, by extension, the EAA's web obligations.
WCAG 2.2 New Criteria (Not in WCAG 2.1)
Penalties and Enforcement
Each EU member state is responsible for transposing the EAA into national law and designating enforcement authorities. Penalties vary by country but the EAA requires them to be "effective, proportionate and dissuasive."
Enforcement mechanisms include:
- Market surveillance authorities can order non-compliant products and services to be withdrawn from the EU market
- National authorities can impose fines: some member states have set penalties up to €500,000 or more for serious violations
- Disability advocacy organizations and individuals can file complaints with national authorities
- Member states must establish accessible complaint mechanisms for individuals to report EAA violations
How to Comply
Identify which products and services you offer in EU markets and whether they fall within EAA scope. Check if any exemptions apply.
Commission a professional audit of your web and mobile interfaces against WCAG 2.2 Level AA. Include automated and manual testing.
Fix accessibility failures, prioritizing critical barriers. For products, update design specifications and engineering standards.
For products, ensure conformance with all applicable EN 301 549 clauses, which extend beyond web content to hardware and software interfaces.
Document your conformance using an Accessibility Statement or a formal declaration in line with your member state's requirements.
Ensure product manuals, technical documentation, and websites reflect accessibility features and how to use them.
Require EAA/EN 301 549 compliance from all vendors providing digital components or services.
Primary sources
Standards and regulations change. Verify anything you plan to rely on against the source itself.
This guide is technical information, not legal advice.
It describes accessibility standards and how to test against them. Whether a specific obligation
applies to your organization, and how to answer any regulatory filing, is a question for your counsel.
No consultant can certify legal compliance or guarantee that an organization will avoid a complaint,
claim, or enforcement action.
Last reviewed August 31, 2026.
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