The European Accessibility Act: Who Must Comply and How

The European Accessibility Act (EAA) — Directive (EU) 2019/882 — is the most significant accessibility regulation to hit the private sector in years. Its core obligations became enforceable on 28 June 2025, and unlike earlier rules that mostly targeted the public sector, the EAA reaches a broad range of private companies selling into the EU. If you have customers in Europe, it likely applies to you even if you’re based elsewhere.

This is general information, not legal advice; obligations vary by member state and product. Consult a qualified advisor and see our accessibility disclaimer.

Who must comply

The EAA covers specific products and services, including:

• E-commerce (online shops and the websites/apps that sell to consumers).
• Banking and financial services for consumers.
• Electronic communications and access to audiovisual media services.
• E-books, ticketing, and certain transport services.
• Consumer computing hardware, smartphones, ATMs, and payment terminals.

It applies to manufacturers, importers, distributors, and service providers operating in the EU market — regardless of where the company itself is headquartered.

The microenterprise exemption

Microenterprises that provide services — fewer than 10 employees and under €2 million in annual turnover — are generally exempt from the service obligations. Note the exemption is narrower for products, and “disproportionate burden” relief must be documented, not assumed. Don’t treat “we’re small” as an automatic pass.

What the standard actually requires

The EAA is outcome-based, but in practice conformance is demonstrated via the harmonized European standard EN 301 549, which for web content incorporates WCAG 2.1 Level AA (with WCAG 2.2 increasingly referenced as the standard evolves). In other words: the technical target is the same WCAG AA criteria covered in our WCAG 2.2 checklist — perceivable content, keyboard operability, sufficient contrast, labeled forms, robust markup, and so on.

Documentation, not just code

A distinctive part of the EAA is the paperwork. Depending on your role you may need to provide accessibility information in your terms/conditions, maintain technical documentation describing how the product or service meets the requirements, and respond to market-surveillance authorities. Accessibility becomes something you can evidence, not just assert.

Enforcement and penalties

Each member state sets its own penalties and enforcement bodies, and they vary — from fines to orders to withdraw a non-compliant service from the market. Because enforcement is national, companies selling across the EU face a patchwork; the safe approach is to meet the common technical bar (WCAG AA) everywhere rather than country by country.

A practical readiness checklist

1. Confirm scope — do your products/services fall under the EAA, and in which member states do you operate?
2. Scan your digital surfaces — get a prioritized, scored view of where your site/app fails WCAG AA today.
3. Remediate by severity — fix Critical and Serious barriers first; verify key flows manually and with assistive tech (see our methodology).
4. Document conformance — prepare the accessibility information and technical documentation the directive expects.
5. Monitor continuously — re-test on releases so you don’t drift out of conformance.

Don’t wait for a complaint

The deadline has already passed, which means the relevant question is no longer “when” but “how exposed are we right now.” A baseline scan turns that uncertainty into a concrete, finite list you can act on. More questions? Start with our FAQ.