European Accessibility Act (EAA) Compliance Guide
The European Accessibility Act — Directive (EU) 2019/882 — is the EU's single biggest expansion of digital accessibility law into the private sector. It took effect for new products and services on June 28, 2025, covers e-commerce, banking, e-books, transport, and consumer devices, and reaches any company selling into the EU market — including companies based outside the EU.
Not legal advice.This guide is educational information about the European Accessibility Act, not legal advice. EAA obligations depend on each member state's national implementing law and your specific products and services. Consult a qualified lawyer in the relevant jurisdiction before making compliance decisions.
The EAA at a glance
Legal instrument
Directive (EU) 2019/882, adopted April 17, 2019
Application date
June 28, 2025 for new products and services
Technical standard
EN 301 549, incorporating WCAG 2.1 AA for web
Enforcement
National market surveillance authorities in all 27 member states
What the European Accessibility Act is
The EAA is an EU directive that harmonizes accessibility requirements for a defined list of products and services across the single market. Unlike the earlier Web Accessibility Directive, which covered only public-sector websites and apps, the EAA targets private businesses. Each member state transposed the directive into national law (the deadline for transposition was June 28, 2022), so in practice you comply with 27 national laws that share the directive's common core.
The directive is built on the EU's internal-market logic: a product or service that meets the harmonized requirements can circulate in every member state without meeting 27 different national accessibility rules. For businesses, that cuts both ways — one standard to meet, but 27 national enforcement regimes if you miss it.
Who the EAA applies to
The EAA applies to economic operators — manufacturers, importers, distributors, and service providers — that place covered products on the EU market or provide covered services to EU consumers. Where the company is headquartered does not matter; what matters is whether the product or service is offered in the EU.
Covered services
| Sector | What it covers |
|---|---|
| E-commerce | Online shops, marketplaces, booking flows, checkout, account management |
| Consumer banking | Online banking, payment services, credit agreements, identification methods |
| Electronic communications | Phone, messaging, and VoIP services and their apps |
| Audiovisual media access | Streaming platforms' apps, EPGs, and websites providing access to content |
| E-books | E-book files and the dedicated software used to read them |
| Passenger transport | Air, bus, rail, and waterborne transport websites, apps, e-tickets, travel info |
Covered products include consumer computers and operating systems, smartphones, tablets, e-readers, TV equipment with digital services, and self-service terminals such as ATMs, payment terminals, and ticketing or check-in machines.
Exemptions and limits
- Micro-enterprise exemption (services only). Service providers with fewer than 10 employees and annual turnover or balance sheet total not exceeding EUR 2 million are exempt from the service requirements. Micro-enterprises dealing in covered products are not exempt, though they face lighter documentation duties.
- Disproportionate burden. An operator may limit compliance where meeting a requirement would impose a disproportionate burden, assessed against the criteria in Annex VI of the directive. The assessment must be documented, kept for inspection, and redone when the service changes or an authority asks — it is a narrow, evidence-based escape valve, not a general opt-out.
- Fundamental alteration. Requirements do not apply where they would require a fundamental alteration in the basic nature of the product or service.
Key dates and the 2030 transition
- April 17, 2019 — Directive (EU) 2019/882 adopted.
- June 28, 2022 — deadline for member states to transpose the directive into national law.
- June 28, 2025 — the EAA applies: products placed on the market and services provided to consumers from this date must comply.
- Until June 28, 2030 — service contracts concluded before June 28, 2025 may continue unchanged until they expire, but no later than this date.
- Self-service terminals — terminals lawfully in use before June 28, 2025 may remain in service until the end of their economically useful life, capped at 20 years.
The transition rules are narrower than many teams assume: they protect pre-existing contracts and installed terminals, not websites or apps. A consumer-facing website or app operating after June 28, 2025 is expected to comply now.
EN 301 549 and WCAG 2.1 AA
The EAA states functional accessibility requirements rather than naming a web standard directly. Conformity is presumed when you meet harmonized standards referenced in the Official Journal of the EU — and for ICT, that standard is EN 301 549. Its web chapter incorporates WCAG 2.1 Level A and AA success criteria, so for websites and apps, WCAG 2.1 AA conformance is the practical technical baseline. EN 301 549 goes further than WCAG alone: it also covers non-web documents, software, hardware, and support services.
Because WCAG 2.2 added criteria on top of 2.1 (published October 2023), auditing against WCAG 2.2 AAis a sensible way to meet today's baseline with headroom as standards and national guidance evolve.
Enforcement: how the EAA is policed
Unlike the lawsuit-driven enforcement model of the US ADA (see our accessibility lawsuit tracker), the EAA is enforced by government authorities. Each member state designates market surveillance authorities for products and authorities responsible for checking service compliance. They can demand documentation, order corrective action, restrict or withdraw non-compliant products and services, and impose penalties under national law. Consumers and disability organizations can also lodge complaints and, in many member states, take action before courts or administrative bodies.
Penalties: set nationally, and they vary
| Member state | Example penalty regime |
|---|---|
| Ireland | Fines up to EUR 60,000 and potential criminal liability for serious offences |
| Germany | Administrative fines up to EUR 100,000 under the BFSG |
| France | Administrative fines per infringement, with separate penalties for missing accessibility statements |
| All member states | Corrective orders, market restrictions, and product/service withdrawal by surveillance authorities |
Indicative examples from national implementing laws; exact amounts and mechanisms vary and change. See our global accessibility laws tracker for jurisdiction-by-jurisdiction detail.
Practical compliance steps
Confirm whether you are in scope
Map your products and services against the EAA's covered categories, check the micro-enterprise exemption, and identify every EU member state where you sell.
Audit against EN 301 549 / WCAG 2.1 AA
Run a full accessibility audit of websites, apps, documents, and support channels against EN 301 549, which incorporates WCAG 2.1 Level AA for web content.
Remediate prioritized barriers
Fix blocking issues in core user journeys first — checkout, login, forms, payment — then work through remaining WCAG 2.1 AA failures.
Publish an accessibility statement
Document how your service meets the accessibility requirements, in a public, accessible format, as the EAA's service-information duty requires.
Set up accessible support and feedback channels
Ensure customer support, contact methods, and complaint routes are themselves accessible and can handle accessibility feedback.
Build monitoring into your release process
Add automated and manual accessibility checks to CI and design reviews so new releases do not reintroduce barriers.
Get ahead of EAA enforcement
Audit your site against WCAG 2.1/2.2 AA, generate the accessibility statement the EAA expects, and fix barriers before an authority — or a customer complaint — finds them.
Frequently asked questions
Does the European Accessibility Act apply to US companies?
Yes, if they sell covered products or services into the EU market. The EAA applies based on where the product or service is offered, not where the company is established. A US e-commerce site that ships to EU consumers, a US SaaS company with EU customers for a covered service, or a US publisher selling e-books in the EU all fall within scope. Non-EU companies typically meet the requirements through an EU-based importer, distributor, or authorized representative for products, and directly for services. If you deliberately target EU consumers — EU shipping, euro pricing, EU-language storefronts — you should assume the EAA applies.
What is the difference between the EAA and the ADA?
The ADA is a US civil-rights law enforced largely through private lawsuits, and it did not historically name a specific technical standard for most websites. The EAA is an EU product-and-service regulation enforced by government market surveillance authorities in each member state, with a defined technical route to compliance: conformity with the harmonized standard EN 301 549, which incorporates WCAG 2.1 Level AA for web content. The EAA also covers things the ADA does not spell out, such as accessibility of packaging, instructions, support channels, and a public accessibility statement describing how the service meets the requirements.
What does the EAA actually require for a website or app?
Covered services must be perceivable, operable, understandable, and robust — the same four principles as WCAG. In practice, conformance with EN 301 549 (which incorporates WCAG 2.1 Level AA for web content and adds requirements for software, documents, and support services) gives a presumption of conformity. Beyond the interface itself, the EAA requires accessible information about the service, an explanation of how the accessibility requirements are met (usually published in an accessibility statement), and accessible customer support and feedback channels.
What are the EAA deadlines?
The core application date was June 28, 2025: products placed on the EU market and services provided to consumers from that date must comply. Two transition rules soften the edge: service contracts concluded before June 28, 2025 may run unchanged until they expire, but no later than June 28, 2030; and self-service terminals (ATMs, ticketing machines, check-in kiosks) lawfully in use before that date may continue in service until the end of their economically useful life, capped at 20 years. New websites, apps, and services launched after June 28, 2025 get no transition period.
Are small businesses exempt from the EAA?
Only micro-enterprises providing services are exempt — defined as fewer than 10 employees AND annual turnover or balance sheet total not exceeding EUR 2 million. Both conditions must be met. Micro-enterprises that manufacture, import, or distribute covered products are not exempt from the substantive requirements, though they benefit from lighter documentation obligations. Small and medium-sized enterprises above the micro threshold must comply in full. Note that the exemption is per legal entity in the relevant member state's implementation, and member states may still encourage voluntary compliance.
What are the penalties for EAA non-compliance?
Penalties are set by each member state, not by the directive itself, so they vary widely. The directive requires penalties to be effective, proportionate, and dissuasive. Examples from national implementing laws include fines reaching tens of thousands of euros per infringement in Ireland (up to EUR 60,000 and potential criminal liability for serious cases) and administrative fines up to EUR 100,000 in Germany. Beyond fines, market surveillance authorities can order corrective action, restrict or prohibit a product or service on the market, and require withdrawal — and consumers and disability organizations can lodge complaints or take action under national law.
Is WCAG 2.1 AA conformance enough for EAA compliance?
It covers the largest part for websites and apps, but not everything. WCAG 2.1 AA maps to the web chapter of EN 301 549, and meeting it addresses the core interface requirements. The EAA additionally expects accessible non-web documents, accessible support and communication channels, information about the accessibility of the service (usually an accessibility statement), and — for products — accessible packaging, instructions, and labeling. Treat WCAG 2.1 AA as the necessary foundation and EN 301 549 plus the EAA's service-information duties as the complete picture. Auditing against WCAG 2.2 AA is a sensible way to stay ahead of standard updates.
Which sectors does the EAA cover?
Services: e-commerce (any website or app selling to EU consumers), consumer banking and financial services, electronic communications, access to audiovisual media services, e-books and dedicated reading software, and elements of air, bus, rail, and waterborne passenger transport (websites, apps, e-ticketing, real-time travel information). Products: consumer computers and operating systems, smartphones and tablets, self-service terminals (ATMs, payment terminals, ticketing and check-in machines), e-readers, and TV equipment with digital services. If your service lets EU consumers conclude a contract online, e-commerce coverage almost certainly reaches you.