Accessibility Is Now a Legal Requirement for Many EU Businesses
The European Accessibility Act came into force on 28 June 2025. It sets a single set of accessibility requirements across all 27 EU member states – replacing the patchwork of national rules that made compliance expensive and inconsistent for cross-border businesses. If you sell certain products or services to consumers in the EU, there is a good chance it applies to you.
Here is what it requires, who is in scope, and what happens if you are not compliant.
What Is the European Accessibility Act?
The European Accessibility Act (Directive (EU) 2019/882) is an EU directive adopted in April 2019. It was designed to do two things: improve access for people with disabilities, and create a single harmonised market for accessible products and services by removing the legal fragmentation that existed across EU countries.
Because it is a directive, each member state had to transpose it into national law by 28 June 2022. Enforcement started on 28 June 2025.
Which Products and Services Does It Cover?
The EAA applies to a specific list of products and services – not everything a business sells.
Products in scope:
- Computers and operating systems
- Smartphones and consumer terminal equipment used for electronic communications
- TV equipment related to digital television services
- ATMs and payment terminals
- Ticketing and check-in machines
- Interactive self-service information terminals
- E-readers
Services in scope:
- Electronic communications services (telephony, messaging)
- Audiovisual media services
- Passenger transport services – air, rail, bus, waterborne (websites, apps, ticketing, real-time travel info)
- Consumer banking services
- E-books and dedicated e-book software
- E-commerce services
For transport services, the requirements cover websites, apps, and digital interfaces – not physical infrastructure or vehicles.
Who Does the EAA Apply To?
The directive applies to manufacturers, importers, distributors, and service providers dealing in covered products and services. Crucially, it applies to any business selling into the EU – including non-EU companies. If you are a US or UK business with EU customers buying your covered products or services, you are in scope.
There is no general size threshold that exempts you. One exception exists: microenterprises providing services (fewer than 10 employees and under €2 million in annual turnover or balance sheet) are exempt from the service-side obligations. But this exemption does not apply to businesses manufacturing or selling covered products, regardless of size.
Standard SMEs – 10 to 249 employees – have no exemption and are fully in scope.
What Does It Actually Require?
The technical requirements are set out in Annex I of the directive and follow four principles that will be familiar if you have worked with web standards:
- Perceivable – information must be available in ways users can perceive (text alternatives, captions, adaptable layouts)
- Operable – interfaces must be usable via keyboard and assistive technology
- Understandable – content and navigation must be clear and predictable
- Robust – content must work with a range of user agents and assistive tools
These principles align directly with the WCAG framework. The directive does not name a specific WCAG version in its text, but the harmonised European standard it references – EN 301 549 v3.2.1 – incorporates WCAG 2.1 Level AA in full for web content and mobile apps. In practice, WCAG 2.1 AA is the benchmark auditors and national authorities use for digital services.
For physical products, manufacturers must also prepare technical documentation demonstrating conformity, apply CE marking where required, and retain that documentation for five years.
Key Dates and Transition Periods
| What | Deadline |
|---|---|
| New products placed on the market | Must comply from 28 June 2025 |
| Services already provided before 28 June 2025 | Must comply by 28 June 2030 |
| Service contracts agreed before 28 June 2025 | May continue until expiry, no longer than 28 June 2030 |
| Self-service terminals already in use before 28 June 2025 | May continue until end of economic life, no later than 28 June 2045 |
If your business was already providing a service before June 2025, you have until 2030 to comply. If you are launching a new service or putting new products on the market, the rules apply now.
Can You Claim a Disproportionate Burden?
There is a “disproportionate burden” clause in Article 14 that allows businesses to limit or defer compliance if the cost is genuinely disproportionate relative to the benefit. But it is not a blanket opt-out.
To use it, you need to document a formal financial assessment using three criteria: the ratio of compliance costs to total operating costs, the estimated costs and benefits relative to the impact for people with disabilities, and the ratio of net costs to turnover. The assessment must be retained for five years, shared with authorities on request, and revisited every five years or whenever the service changes significantly.
The directive explicitly states that “lack of priority, time or knowledge” are not valid reasons. And even when the exception applies, you are still required to make your product or service as accessible as possible within what is feasible. If your business has received any public or private funding specifically for accessibility, you cannot claim this exception at all.
What Are the Penalties?
Enforcement is handled at the national level, and penalties vary significantly by country. The directive requires penalties to be “effective, proportionate and dissuasive” but leaves the amounts to each member state.
| Country | Maximum Penalty |
|---|---|
| Spain | Up to €1,000,000 |
| Belgium | Up to €200,000 |
| Germany | Up to €100,000 per violation |
| Austria | Up to €80,000 |
| Ireland | Up to €60,000 + potential imprisonment |
| France | Up to €50,000 + possible business suspension |
| Netherlands | Up to €103,000 |
| Italy | €5,000 – €40,000 (or 5% of turnover) |
Early enforcement signals from national authorities suggest a remediation-first approach – regulators are generally asking businesses to fix issues before escalating to fines. But complaint volumes from disability rights groups are rising, and Spain and France in particular have aggressive enforcement structures in place.
Where to Start
The most practical first steps are to check whether your products or services fall within the directive’s scope, then run an audit against WCAG 2.1 AA as the baseline for any digital services you offer. From there, document where gaps exist and build a plan to close them.
The AccessibleEU Centre – funded by the European Commission – publishes guidance and practical resources for businesses working through EAA compliance. Your national market surveillance authority is the body responsible for enforcement in your country.
If your business is also subject to other EU digital regulations, it is worth mapping obligations together. The NIS2 directive covers cybersecurity risk management for many of the same sectors, and the two sets of obligations overlap in areas like digital services and e-commerce.
Quick Answers
When does the European Accessibility Act apply?
From 28 June 2025 for new products and services. Existing services already being provided before that date have until 28 June 2030 to comply.
Does the EAA apply to small businesses?
Yes, with one exception: microenterprises (fewer than 10 employees, under €2 million turnover) providing services are exempt from the service obligations. There is no size exemption for businesses manufacturing or selling covered products.
What accessibility standard should I follow?
WCAG 2.1 Level AA is the de facto benchmark for digital services under the EAA, via the harmonised European standard EN 301 549 v3.2.1.
Does the EAA apply to non-EU businesses?
Yes. Any business placing covered products on the EU market or providing covered services to EU consumers must comply, regardless of where the business is based.
What happens if I cannot afford to comply?
You can document a disproportionate burden assessment under Article 14. But it requires formal financial analysis, is not available if you have received accessibility funding, and still requires you to maximise accessibility within what is feasible.