The European Accessibility Act (EAA)

June 28, 2025. That’s when the EAA becomes national law in all 27 EU member states. If your organization sells products or services within the EU, the time to get started on your compliance roadmap is now.

What is the European Accessibility Act?

The European Accessibility Act (EAA) is a directive of the European Union that aims to improve the accessibility of products and services for people with disabilities and the aging population in the EU.

The goal is to remove barriers created by divergent rules in different EU member states. This will make it easier for companies to operate across member states, foster innovation in the development of accessible technologies, and help ensure accessible products and services are more affordable and widely available.

The EAA represents a significant step towards greater inclusivity. It aims to benefit not only people with disabilities and the older population but also businesses by creating a larger, unified market for accessible products and services.

The EAA is transposed into national law and regulations in all EU member states. Though one goal is to harmonize digital accessibility in Europe, each country will have its own specific compliance requirements.

What does the EAA cover?

The European Accessibility Act (EAA) requires specific product and service features and to be accessible for persons with disabilities.

Products

  • Computers and operating systems
  • Smartphones and other communication devices
  • TV equipment related to digital television services
  • ATMs and payment terminals
  • E-readers
  • Ticketing and check-in machines

Services

  • E-commerce
  • Banking services
  • Phone services
  • Websites and mobile services
  • Electronic tickets
  • E-books
  • Access to audio-visual media services (AVMS)
  • Calls to the European emergency number 112

EAA compliance outside the EU

The EAA also applies to any enterprise or business outside the EU that provides services or sells products in the EU.

Service providers must explain in their terms and conditions how a service meets the digital accessibility requirements. As applicable, the information must contain:

  • A broad overview of the service presented in a manner that everyone can understand, regardless of their accessibility needs
  • Detailed guidelines and explanations on using the service
  • An explanation of how the service aligns with the digital accessibility standards listed in Annex I of the European Accessibility Act

Service providers must demonstrate that the service is delivered and monitored in compliance with all applicable requirements of the EAA, and this information must be made available to the public in an accessible format.

Ensuring compliance

It’s important to understand that the EAA is a directive, not a standard. It does not refer to a specific accessibility standard, and leaves it to each country to define its own regulations and adopt a specific standard and conformance level.

Baked into the EAA are the four principles of accessible websites and mobile applications: Perceivable, Operable, Understandable, and Robust (POUR).

Currently, most member states are implementing EN 301 549, which cites WCAG 2.1 AA. Some countries are only citing WCAG 2.1 AA. EN 301 549 specifically goes beyond web to include requirements for documents such as PDFs and devices like kiosks and payment terminals.

Deque recommends complying with more stringent accessibility standards such as EN 301 549. Proactive steps reduce the risk of non-conformance from penalties and reduce the burden on your accessibility and development teams.

EN 301 549

The harmonized standard of accessibility requirements for Information and Communications Technology (ICT) products and services in the EU, Canada and Australia.

WCAG 2.1 AA

A W3C recommendation for making web content more accessible. Version 2.1 was extended by WCAG 2.2 in October 2023.

Penalties for non-compliance

The penalties for non-compliance are not detailed in the directive itself and will vary by jurisdiction and severity. Companies are encouraged to prioritize accessibility to avoid legal and financial repercussions.

The directive does mandate that penalties must be “effective, proportionate, and dissuasive,” and consumers can report infringements to a court or the enforcing body in their country.

Exceptions to EAA coverage

EU Member States hold the authority to grant specific exceptions under certain circumstances.

Microenterprises
The directive does not impose accessibility requirements on companies with less than 10 employees and an annual turnover/balance sheet of less than €2 million.

Disproportionate burden
An organization can receive an exemption for disproportionate burden if it can document that the cost of making its products or services accessible would be significantly more than the value of the increased accessibility to people with disabilities. The directive contains extensive criteria for determining whether something constitutes a disproportionate burden.

Meet EAA requirements with Deque

By working with Deque’s industry experts now, you can build your EAA compliance roadmap and be ready when the directive takes effect on June 28, 2025.

Regional experts

Deque has offices and employees in Europe and worldwide with deep knowledge of local guidelines.

Strategic Consulting

Our Principal Strategy Consultants help build, run and improve the world’s largest digital accessibility programs.

Trusted and proven tools

Our axe accessibility testing tools are the defacto global standard with 875,000+ installs

Frequently asked questions

Microenterprises (defined as a small business with fewer than 10 employees and/or less than €2 Million annual turnover or annual balance sheet total) which provide services are exempted.

The “disproportionate burden” clause within the EAA is designed to balance the goal of widespread accessibility with the practical limitations of some organizations for reasons of proportionality. In certain cases, the cost of compliance may be too high, in which case the economic operator may rely on this exception. The economic operator may use the following for its assessment:

  • The ratio of the costs of compliance to the overall costs of the economic operators.
  • The estimated costs and benefits in relation to the estimated benefits to persons with disabilities and the ratio of the net costs of compliance to the net turnover.

Companies need to analyze and assess whether this exception would apply, and document the assessment.

The directive applies to enterprises outside of the EU that provide services or sell products to consumers within the EU. For instance, US-owned retail websites aimed at consumers in the EU or within a specific country of the EU, or smartphone or e-reader devices sold in the EU by a US-based company. For all countries, the same date applies: June 28, 2025.

There is some ambiguity in the definition of what is similar (and what is new) within the directive. Our interpretation from a software perspective, especially from the context of continuous development, is that it is hard to state that services remain unaltered. Most developed software with updates or changes would not fit into a grace period regime. All changes entail the risk of introducing new accessibility bugs (and the opportunity to fix ones that exist).

Another way of looking at this is that according to WCAG, any change to a page or a user workflow, even if it’s just a piece of content, needs to comply with accessibility standards.