European Accessibility Act
(EAA) 2025
The European Accessibility Act (Directive 2019/882) has applied since June 28, 2025. It covers specific products and services offered to EU consumers, such as online shops, banking, e-books, transport ticketing and communication services, wherever the business is based. EN 301 549, which references WCAG 2.1 Level AA for web and software, is the standard used to show conformity.
What Is the European Accessibility Act?
The European Accessibility Act (EAA), officially Directive (EU) 2019/882, is an EU-wide law that harmonizes accessibility requirements across Member States for specific categories of products and digital services sold or provided in the European Union.
Unlike the ADA in the US (which is interpreted through case law), the EAA is a prescriptive legislative framework with specific technical requirements. Its technical standard is EN 301 549, which directly incorporates WCAG 2.1 Level AA for web content and software interfaces.
The law applies to both products and services, so your website, mobile app, and all digital touchpoints are in scope if you sell to EU consumers.
Businesses, EU-based or not, that offer products or services in the regulated categories to consumers in the EU. Being based outside the EU is no exemption. Microenterprises (fewer than 10 staff and an annual turnover or balance sheet of €2 million or less) that provide services are exempt.
Penalties vary by Member State: each EU country sets its own enforcement regime. Sanctions range from financial fines to market withdrawal orders. Member states must set penalties that are effective, proportionate and dissuasive; Germany's BFSG, for example, allows fines of up to €100,000.
National market surveillance authorities, consumer protection bodies, and in many Member States, disability rights organizations have standing to file complaints and initiate enforcement proceedings.
EAA Timeline
Directive (EU) 2019/882, the European Accessibility Act, was adopted. It entered into force on June 27, 2019.
EU Member States required to transpose the directive into national law.
Active enforcement started. Non-compliance penalties now apply to private-sector organizations.
Services using pre-existing products under older contracts must comply by June 28, 2030.
Sectors & Services in Scope
The EAA applies to these specific product and service categories. If your organization operates in any of these sectors and serves EU consumers, you must comply.
E-commerce & Online Retail
Webshops, marketplace platforms, payment services, digital product purchases
Must meet EN 301 549 / WCAG 2.1 AA across entire purchase flow
Banking & Financial Services
Online banking portals, payment apps, investment platforms, insurance services
Full digital service accessibility, including authentication flows
Transport & Travel
Airline booking, train ticketing, urban transport services
Booking, check-in, and real-time information must be accessible
Telecommunications
Broadband, telephone, messaging services, video calling
Consumer-facing digital interfaces must be fully accessible
Media & Audiovisual
Streaming platforms, VOD services, electronic programme guides
Captions, audio description, accessible player controls required
Operating Systems & Software
General-purpose operating systems, consumer hardware, smart devices
User interface and control features must support AT interoperability
EN 301 549 Technical Standard
EN 301 549 is the harmonized European technical standard that specifies accessibility requirements for ICT. Chapter 9 mandates WCAG 2.1 AA for all web content. Other chapters extend accessibility requirements to documents, software, hardware, and support services.
4Functional Performance Statements
Without vision, limited vision, without colour perception, without hearing, limited hearing, without speech, limited manipulation, limited reach & strength, photosensitivity, without cognition
5Generic Requirements
Closed functionality, activation of accessibility features, biometrics, preservation of accessibility info, operable parts
6ICT with Two-Way Voice Communication
Audio bandwidth for speech, real-time text (RTT), caller ID, relay services
7ICT with Video Capabilities
Caption processing, audio description, real-time text, colour depth, resize/reflow video
9Web (WCAG 2.1 AA)
All 50 WCAG 2.1 Level A and AA success criteria, across the perceivable, operable, understandable and robust principles
10Non-web Documents
Applies WCAG 2.1 principles to PDFs, Office documents, and other non-HTML files
11Software
Applies WCAG 2.1 principles to native apps, platform accessibility APIs, user preferences
12Documentation & Support Services
Accessible product documentation, support services available in accessible formats
13ICT Providing Relay or Emergency Services
Emergency service access, relay service interoperability
EAA Compliance Checklist
A practical action list for organizations working toward EAA compliance. Start with Critical items immediately.
Audit all public-facing web properties against WCAG 2.1 AA
Audit mobile applications (iOS, Android, web apps)
Ensure all PDFs and downloadable documents are accessible
Test authentication and payment flows with assistive technologies
Add captions and audio descriptions to all video content
Test keyboard-only navigation throughout entire user journey
Verify colour contrast ratios meet WCAG 2.1 AA minimums (4.5:1 text)
Publish an Accessibility Statement on your website
Establish a feedback mechanism for users to report barriers
Document conformance in a VPAT / ACR for procurement
Train development and content teams on accessibility requirements
Set up continuous monitoring and regression testing in CI/CD
Perform user testing with people with disabilities
Create an accessibility remediation roadmap with owners and dates
Exemptions & Transitional Provisions
The EAA includes limited exemptions, but they must be formally documented. Claiming exemption without documentation is not a defense.
Microenterprises
Businesses with fewer than 10 employees AND annual turnover / balance sheet below €2 million are exempt from EAA requirements for services (not products).
Disproportionate Burden
Organizations may claim exemption for specific requirements that would impose a disproportionate burden, but must document this formally with a detailed assessment.
Fundamental Alteration
If compliance would fundamentally alter the nature of a product or service, an exemption may apply. Must be formally substantiated.
Pre-existing Contracts
Service contracts in place before June 28, 2025 have a transitional period until June 28, 2030 before full compliance is required.
Global Compliance Comparison
| Dimension | EAA / EN 301 549 | ADA (US) | Section 508 (US Gov) |
|---|---|---|---|
| Scope | Private sector in 27 EU countries | US public accommodations (interpreted broadly) | US federal agencies & contractors |
| Technical Standard | EN 301 549 → WCAG 2.1 AA | Title II rule: WCAG 2.1 AA; Title III: none set | WCAG 2.0 AA (2018 refresh) |
| Enforcement | Market surveillance authorities, fines, market withdrawal | Federal court litigation, DOJ enforcement | Agency complaints and lawsuits (Section 505) |
| Document Scope | Web + apps + documents + hardware | Web + apps (documents case-by-case) | Web + apps + documents + hardware |
| Accessibility Statement | Service information required (Annex V) | Not required but recommended | Not explicitly required |
| Penalty Type | Administrative fines, withdrawal orders | Injunctive relief, attorney fees (damages under some state laws) | Court-ordered remedies; procurement consequences |
How to Comply with the EAA
A step-by-step path to EAA compliance using EN 301 549 and WCAG 2.1 AA.
Determine if you are in scope
Check whether you offer covered products or services to consumers in the EU, and whether you are a microenterprise (exempt for services) or qualify for another exemption.
Audit against WCAG 2.1 AA / EN 301 549 Chapter 9
Run an accessibility audit that maps findings to EN 301 549 criteria. For web content, that means WCAG 2.1 Level AA.
Fix identified barriers
Prioritise Level A failures, then Level AA. Update HTML, ARIA, and design components to meet the criteria.
Publish the required accessibility information
Service providers must explain how their service meets the accessibility requirements (Annex V), for example in their general terms and conditions. Public-sector bodies publish a formal accessibility statement under the separate Web Accessibility Directive.
Prepare technical documentation
Makers of covered products must prepare technical documentation and an EU declaration of conformity (Annex IV). Providers of covered services must publish how the service meets the requirements (Annex V).
Establish ongoing monitoring
Integrate accessibility testing into your development pipeline and conduct regular audits, especially after major releases.
Frequently Asked Questions
Common questions about European Accessibility Act compliance.
When did the European Accessibility Act (EAA) come into force?
The European Accessibility Act (EU Directive 2019/882) has applied since June 28, 2025. From that date, the products and services it covers must meet its accessibility requirements when they are placed on the EU market or offered to EU consumers. Each EU country sets its own penalties and enforcement, and some transition periods apply, for example to service contracts agreed before that date.
What technical standard does the EAA require?
The EAA sets functional accessibility requirements (Annex I) rather than naming WCAG directly. EN 301 549 is the European standard used to show that ICT meets them, and its web section (clause 9) corresponds to WCAG 2.1 Level AA. Meeting WCAG 2.1 AA (or WCAG 2.2 AA, which includes it) covers the web-content part; other parts of a product or service can have further requirements.
Who does the European Accessibility Act apply to?
The EAA applies to businesses that place products and services on the EU market, including e-commerce websites, mobile apps, banking and financial services, transport services, e-books, and audiovisual media services. Microenterprises (fewer than 10 employees and annual turnover below €2M) are exempt from service requirements.
What are the penalties for EAA non-compliance?
Penalties vary by EU member state. Member states must ensure their national laws include effective, proportionate, and dissuasive penalties. These can include fines, orders to bring products/services into compliance, market withdrawal, and injunctions. The EU Commission can also take action against member states that fail to enforce the directive.
Does the EAA apply to non-EU companies?
Yes. Any business that places products or services on the EU market must comply with the EAA, wherever the company is headquartered. This includes US, UK and Asian companies that offer covered products or services to consumers in the EU. A website merely being reachable from the EU is not enough on its own.
Check Your Site Against the EAA
AccessiSight scans your site against the WCAG 2.1 AA criteria that EN 301 549 Chapter 9 uses, and gives you VPAT documentation and a prioritized list of fixes. Some criteria still need manual review.
Not legal advice. This guide is educational and does not constitute legal advice. How the EAA applies depends on national transposition laws and your products and services; consult a qualified lawyer for your situation.