Glossary · Accessibility term

European Accessibility Act

Also called: EAA

The European Accessibility Act is the EU law that has required certain consumer products and services to be accessible since 28 June 2025, and the word to hold onto is certain. It is not a general web accessibility law for Europe. It covers a closed list. The entries a website owner cares about are e-commerce, consumer banking, e-books, telecoms, parts of passenger transport and access to audiovisual media. A site is in scope where it delivers one of those, not because it exists. Where you are covered, being outside the EU does not help, because what counts is selling to consumers in the EU rather than where you are established. Where you may not be covered at all is if you are a microenterprise providing a service. That means fewer than 10 people, and turnover or a balance sheet total no higher than two million euros. The Act names no WCAG version. It sets functional requirements and grants a presumption of conformity to harmonised standards, and no standard has been cited for it yet. So a website goes to EN 301 549 for its technical answer, and from there to WCAG 2.1 Level AA, which is the best reading available rather than a presumption anybody can claim.

In practice

Start with scope, because a great deal of the anxiety about this law belongs to businesses that are not covered. The directive lists its products and services and the list is closed. E-commerce services, consumer banking, e-books and their software, electronic communications, access to audiovisual media services, specified parts of air, bus, rail and waterborne passenger transport, and the answering of emergency calls to 112. Urban, suburban and regional transport is largely left out. On the product side it reaches consumer computers and their operating systems, self-service terminals, e-readers and consumer terminal equipment. That half runs a conformity assessment and CE marking regime of its own, which is a separate track from anything a website answers to, apart from the product information you publish online.

Then check the microenterprise exemption before anything else, because it can end the question. A service provider with fewer than 10 people, and either turnover or a balance sheet total no higher than two million euros, is exempt. The requirements do not apply, and neither do the obligations attached to them. It is a services exemption. A microenterprise dealing in covered products gets lighter paperwork rather than a way out. Check the headcount first.

If you are in scope, the working answer for a website is WCAG 2.1 Level AA, reached through EN 301 549 rather than named in the law, and testing against WCAG 2.2 covers it. Reached is doing the work in that sentence, because the presumption of conformity has nothing to attach to under this directive yet. So you are using the best technical answer available, and you cannot hold it up to a regulator as proof. There is a publishing duty attached as well. A covered service provider has to explain how the service meets the requirements, in its terms and conditions or an equivalent document. It has to be in a form people with disabilities can actually read. And it stays up for as long as the service runs.

There is an escape and it is a real one, with paperwork. Where compliance would fundamentally alter the basic nature of what you offer, or impose a disproportionate burden measured against your own costs and turnover, you can rely on that. You still have to make the thing as accessible as you can. A service provider has to redo the assessment whenever the service changes, whenever the authority asks for it, and in any event at least every five years. The relevant authority has to be told you are relying on it in the first place.

Why it matters

The Act applies to businesses outside the EU that sell into it, which catches a lot of owners who assumed it was somebody else's problem. What counts is selling to consumers in the EU rather than being established there. Penalties are set nationally, so the honest answer to what happens if you ignore it is that it depends where your customer is. Ireland made non-compliance a criminal offence carrying up to 18 months on indictment, with company directors personally exposed, and the money ceilings reported in other member states run into tens of thousands of euros. The line worth remembering sits in the directive itself, which says a penalty is not an alternative to making the product or service accessible. Paying is not a way of opting out.

In scope, or not

A UK shop selling clothes to customers in Ireland is providing an e-commerce service to EU consumers, so it is in scope wherever it happens to be registered. The same shop with six staff and turnover under two million euros is a microenterprise providing a service, and the directive exempts it outright. Two facts about one business, and the second is the one nobody checks first.

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