Accessibility isn’t just a requirement for public-sector organizations in the European Union (EU). The European Accessibility Act (EAA) mandates that a range of products and services, including many types of online experiences such as e-commerce websites and mobile apps, are accessible to people with disabilities. The law, which applies to those doing business within the EU, aims to resolve discrepancies in accessibility requirements between different European countries. Originally encoded into law in 2019, the EAA was adopted by individual EU nations starting in 2022. Providers of products and services covered by the EAA have until June 2025 to become compliant. A complaint process and surveillance monitoring will be established, and organizations that fail to meet these requirements may face penalties, including fines.
The EAA covers commonly used hardware and software products, websites, and mobile apps, as well as various services pertaining to industries such as communication, commerce, finance, education, and transportation. Here is a partial list of digital assets and technologies that must comply, organized by industry.
Note: To comply with the EAA, providers must publish accessibility statements indicating how they meet the Act’s requirements.
Note: In addition to meeting product-specific accessibility requirements, providers of these technologies must ensure the accessibility of product packaging, instructions, and labeling.
Note: The EAA’s requirements apply to airlines outside the EU that have departures from the EU.
Note: In addition to meeting product- and content-specific accessibility requirements, these media providers must ensure the services used to deliver said content, and their features, provide equal access for people with disabilities.
Companies that sell technology or software into the public or private sector will want to follow the compliance requirements for the EAA as their customers will be requiring conformance with EAA standards as part of their procurement efforts.
The EAA does not directly address healthcare services unless services offered are the same as any of the previously listed experiences or technologies.
Certain types of products and content will not need to comply with the EAA, such as some time-based media and third-party content. For specific details on exceptions that may apply to your organization, contact us
Does the EAA apply to your organization? We can help you achieve compliance.
While the EAA focuses on functionally meeting the needs of people with disabilities and does not itself provide specific technical standards for accessibility, the voluntary harmonized EU standard EN 301 549 will be used as the presumptive standard of conformity. This means that if you want to show that you meet the EAA, you will likely need to show how you conform to EN 301 549.
EN 301 549 defines technical requirements and currently includes the Web Content Accessibility Guidelines (WCAG) 2.1. However, the standard is slated to be updated as part of supporting the implementation of the EAA and is in the process of being updated to include WCAG 2.2. Because WCAG is an established framework for assessing digital accessibility in the EU, conforming to these criteria at an “AA” level (which includes A and AA criteria) is the best way for organizations to start ensuring they comply with the EAA. Additionally, EN 301 549 has other requirements for certain types of web content, software (such as mobile apps), and hardware that may apply.
To learn more about WCAG 2.2, and to understand how well your digital products meet its criteria, request our WCAG Checklist.
As the leading digital accessibility solution, Level Access equips organizations with the tools and support they need to become, and stay, compliant with directives like the EAA. Through a combination of advanced software and expert-managed services, our end-to-end solution will help your organization conform to WCAG 2.2 AA, meeting requirements of the EAA, reducing the risk of legal penalties, and opening your digital experiences to all users.
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Our risk assessment will help you understand your digital accessibility health score and your current level of EAA compliance.
What is the timeline for EAA compliance?
The Act is well on its way: it was adopted in June 2019 and transposed into national laws in the EU in the summer of 2022. Any products placed on the market, or current content or services offered to consumers after June 28, 2025 will need to be compliant. Digital accessibility is a journey, not a quick box to check. Organizations that will need to be compliant with the EAA should get started now to ensure that the products and services they’ll have available in June 2025 are accessible. For help with scoping and forming a plan of action, reach out to our team.
Which countries does the EAA apply to?
The EAA applies to all economic providers (public or private) providing products or services, or offering to provide products or services, in the European Union (EU). This means that organizations based outside the EU must also adhere to the EAA’s accessibility guidelines when conducting business within the EU market.
Are any organizations exempt from the EAA?
Yes. The EAA does not apply to organizations with fewer than 10 employees and an annual turnover of less than two million euros. Additionally, products and services may be considered exempt if compliance would create an “undue burden,” meaning it would significantly change the nature of their products or services.
What is the difference between the EAA and Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies?
The EU Directive on the accessibility of the websites and mobile applications of public sector bodies requires that all public-sector organizations in Europe make these online experiences accessible to people with disabilities. Organizations that sell into the public sector also need to conform to accessibility standards. In comparison, the EAA is broader in scope, in that it can apply to both public and private-sector organizations. Additionally, the EAA covers products and services beyond online experiences, such as computing hardware, e-books, media equipment, and self-service kiosks.
Will an overlay help with compliance with the EAA?
The European Disability Forum (EDF) and International Association of Accessibility Professionals (IAAP) issued a warning that this technology alone does not guarantee compliance with European accessibility legislation. Read the full statement here.
