Accessibility laws · European Union

European Accessibility Act (EAA)

The European Accessibility Act has applied since June 28, 2025, and it reaches far fewer websites than the name suggests. It does not regulate every website in the European Union. It regulates a closed list of products and consumer services, and your website only comes into it when the site is part of selling or delivering something on that list. Small service providers are exempt outright. So the first two questions are whether what you sell is on the list, and whether you are big enough to be caught.

Main application date: Jun 2025
EU member states: 27
Web standard in EN 301 549: 2.1 AA
Employee cap for the exemption: <10

What the EAA Covers

The European Accessibility Act, formally Directive (EU) 2019/882, sets accessibility rules for a named list of products and consumer services sold across the union. The list is the whole game, so it is worth reading slowly. The covered services are e-commerce, consumer banking, electronic communications such as phone and messaging, and access to audiovisual media such as streaming. E-books and the software built to read them are on the list too, along with parts of air, bus, rail and waterborne passenger transport. Answering calls to 112, the single European emergency number, is covered separately. The covered products are consumer computers and their operating systems, self-service terminals such as payment terminals, ATMs, ticketing machines and check-in machines, smartphones and similar terminal equipment, and e-readers. Two limits are easy to miss. Passenger transport is only partly covered, and urban, suburban and regional services sit outside most of the service requirements. What ties the rest together is ordinary daily life, the kind of errand nobody thinks twice about until it is blocked. The EU wrote this law so a disability is not the reason somebody cannot pay for something, read a book, make a call, or get where they are going.

One structural fact shapes everything else. The EAA is a directive, not a regulation, so the EU never wrote a law that lands on your desk directly. Each of the 27 member states had to put it into its own national statute by June 28, 2022. Those statutes started to bite three years later, on June 28, 2025. The gap was deliberate. What it means in practice is that nobody is ever prosecuted under Directive (EU) 2019/882. They are prosecuted under their own country's version of it. The technical requirements in Annex I, the part of the directive that spells out what accessible means, are the same everywhere. The regulator and the penalty are not, and the spread is wider than most owners expect. Ireland made non-compliance a criminal offense, with a fine up to €60,000 or 18 months in prison on conviction on indictment. Germany fines up to €100,000 and can shut a service out of the German market. Same directive, same Annex I, two very different bad days.

There are two tracks under this law and they work differently. If you sell a covered service, your job is to meet Annex I and publish information saying how you do it. If you place a covered product on the EU market, you are in a full product regime, with conformity assessment, an EU declaration of conformity and a CE mark. The mark goes on the product or its data plate, and where that is not possible or is not warranted by the nature of the thing, on the packaging and the accompanying documents instead. Most of this page speaks to the service track, because that is where a website lives. That is also our honest limit. An audit of your website answers the website question, and no audit can certify a whole service, let alone a product line, as EAA conformant. Anyone who tells you otherwise is selling you a certificate, not an answer.

Whether It Applies to You

You provide one of the covered services to consumers in the EU. An online store, consumer banking, electronic communications, access to audiovisual media, e-books, or the covered parts of passenger transport all count. Where your company is registered makes no difference at all. A business run out of Texas or Manchester is covered on the same terms as one in Paris. What the law follows is the service reaching a consumer in the EU, not the address on your paperwork.
You place one of the covered products on the EU market, such as a consumer computer, a smartphone, a payment terminal, an ATM, a ticketing or check-in machine, or an e-reader. Products run on their own track, with conformity assessment, an EU declaration of conformity and CE marking. That track opened on the same June 2025 date as the services. And the microenterprise exemption covers services only, so a nine-person company selling e-readers carries the full duty.
You may be out of scope altogether as a microenterprise, and this is the test worth getting right. It has two halves and both have to be true. First, you have fewer than 10 employees. Second, either your annual turnover or annual balance-sheet total is no more than €2 million. The money half is satisfied by one figure or the other, not both, so a nine-person shop turning over €2.5 million with a €1 million balance-sheet total still qualifies. Article 4(5) then exempts a microenterprise providing services from the accessibility requirements and from every obligation attached to them. That is not a lighter duty. It is no duty at all.

What It Requires

The legal requirements live in Annex I of the directive, which describes what accessible means in functional terms and names no technical standard at all. The directive never names a WCAG version anywhere, whatever you have read elsewhere. For websites the practical reference to test against is EN 301 549, the European standard. The version in force is V3.2.1, and it carries WCAG 2.1 AA plus requirements WCAG does not cover on its own, including non-web documents and software. That same standard is what European public bodies test against under the Web Accessibility Directive, which is a separate instrument with a separate scope. If you are a public body rather than a business, that is your page and this one is not. A revision that moves the web clauses to WCAG 2.2 is drafted and working its way through ETSI's process, and nobody can honestly hand you a published version number or a date for it. Until it lands, V3.2.1 is the bar. Testing against WCAG 2.2 AA now costs you nothing extra and ages better.
Covered services have to prepare information explaining how the service meets the requirements, under Article 13(2) and Annex V. It goes in your general terms and conditions or an equivalent document. It has to describe the service, explain how it works, and say how the relevant Annex I requirements are met. Two parts of Annex V are easy to miss. The information has to exist in written and oral format, in a form people with disabilities can use. And you have to keep it for as long as the service is running, not just until launch week.
Compliance runs for the whole life of the service, and the directive backs that up two ways. Article 13(3) asks you to have procedures in place so the service stays conforming, and to properly account for three kinds of change: a change in how you deliver the service, a change in the requirements, and a change in the standards you leaned on. Rebuild the checkout and that is a change you have to account for. Where the service stops conforming, article 13(4) makes you take corrective measures and tell the authority. Article 14 is the escape hatch owners ask about, and it is narrower than it sounds. You can drop a requirement where meeting it would fundamentally alter the basic nature of what you sell, or where it would be a disproportionate burden. But you still have to apply the requirements as far as they do not impose that burden. The answer is never zero. The test in Annex VI turns on what compliance costs measured against your overall costs, revenue and net turnover. You have to tell the market surveillance authority you are relying on it. And you have to redo the assessment when the service changes, when the authority asks, and at least every five years. So a claim made in 2025 runs out in 2030.

WCAG 2.1 AA is the right benchmark for the website itself, and our Level AA guide and 55-rule library cover it in detail. The service as a whole is judged against Annex I and national law, not WCAG alone. The A to Z glossary explains any unfamiliar terms along the way.

The Annex V information needs substance: a description of the service, the requirements that apply, and how conformity is kept under review. Our free generator produces a solid starting draft, though the evidence about your service has to come from you. Build a free statement draft →

How It Is Enforced

Complaints go to whichever authority your country named when it wrote the directive into national law. There is not one EU regulator. That authority can ask you for evidence, open an investigation, and order you to correct what it finds. For products the directive also plugs into the EU's market surveillance system, which has more teeth than the phrase suggests. An authority there can demand your documentation, evaluate the product itself, and order it withdrawn from the market.

Each member state sets its own penalties, and the directive asks only that they be effective, proportionate, and dissuasive. That leaves real room between countries, and there is no EU-wide fine schedule to look up. A regulator weighs how serious the failure was and how many people it affected. Article 30 then says penalties have to be accompanied by effective remedial action, and the directive's own reasoning spells out why, in the recital saying a penalty must not serve as an alternative to making the thing accessible. You pay, and you still have to fix it. One more thing about numbers. No EU-wide public register of enforcement actions exists, so anyone quoting you an EAA enforcement total is adding up national announcements by hand.

Regulators are not the only route. Article 29 requires member states to give consumers a real way to act under national law, either before the courts or before the competent administrative bodies. It also lets public bodies and private associations with a legitimate interest act on a consumer's behalf or in support of them, with that person's approval. In practice a disability organization can carry the case for somebody who would never file one alone, and the person still has to say yes. There is one carve-out. Article 29 does not cover public procurement procedures, so an accessibility failure inside a tender is handled through procurement remedies instead.

The Dates to Know

Jun 28, 2025The main application date: covered products placed on the market and covered services provided to consumers are in scope from this date. Exceptions and transition rules can change the picture for specific cases
Jun 28, 2030The end of two transition arrangements. Products lawfully in use to provide a similar service before June 28, 2025 can continue until this date, and pre-existing service contracts can run until they expire, but no later than June 28, 2030
20 years maxSelf-service terminals have a separate allowance: a member state can let terminals lawfully in use before June 28, 2025 serve out their economic life, up to a maximum of 20 years after entry into use

Where We Can Help

An honest note first: no vendor can certify your whole service as EAA conformant, including us. What an audit does answer is the website part. The free 10-page scan covers what software can detect, and the $499 audit adds an expert review plus testing by a blind screen-reader user, with a screenshot and suggested fix for each finding, delivered in 5 business days.

Order the $499 audit Scan 10 pages free

This law does not set the web requirement itself. It points at EN 301 549, the European accessibility standard, and that is where the requirement actually lives. Clause 9 of the standard carries WCAG 2.1 Level AA, so a site that already meets Level AA has met the web part of it. The rest of the standard covers ground WCAG never touches, including hardware, two-way voice, documents that are not web pages, and the support channels a customer reaches once the site has already failed them. Several countries adopt the standard under their own national designation, which carries the same requirements under a different name.

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This page is general orientation, current as of August 2026. It is not legal advice and creates no attorney-client relationship. For decisions about your specific situation, consult your own lawyer.