If your organization sells to EU consumers and hasn’t made EAA compliance a priority, now’s the time. The EAA replaces inconsistent national laws with one unified set of accessibility rules across the EU, and enforcement is in effect. The first lawsuits were filed in France in November 2025, confirming that regulators and advocacy groups are moving quickly.
This guide explains EAA requirements, which products and services are covered (including e-commerce platforms and banking services), what the penalties are for non-compliance, and how to start meeting your obligations.
Key insights
What does the EAA do?
The EAA sets accessibility requirements for many consumer products and services sold in the EU. The directive serves two purposes: improving access for the estimated 87 million people with disabilities in the EU and streamlining cross-border commerce. For businesses operating across multiple EU countries, this unified standard means lower compliance costs and simpler legal obligations.
The EAA builds on the EU Web Accessibility Directive (2016/2102), also known as the WAD. While the WAD mandates web accessibility in the European public sector, the EAA extends similar rules to private businesses.
Past EAA milestones and what's next
EAA enforcement is already underway. Here's how the directive has evolved and what's still ahead.
2019:
Directive (EU) 2019/882 (the EAA) was adopted, establishing EU-wide accessibility requirements for the private sector for the first time.
2022:
All 27 EU Member States completed transposition of the EAA into national law.
2025:
Enforcement began June 28. France issued formal legal notices to major retailers in July. Sweden launched market surveillance in October. The first EAA-related lawsuits were filed in French Commercial Court in November.
2026:
The Dutch ACM is actively enforcing EAA requirements for e-commerce and electronic communications. EN 301 549 v4.1.1, incorporating WCAG 2.2, is expected to publish. EU AI Act high-risk obligations begin August 2.
2027:
Service contracts concluded before June 28, 2025, must comply by June 28, 2027. Obligations for emergency communications services also apply from this date.
2030:
The transitional period ends on June 28 for products and services lawfully in use before June 2025. The European Commission will publish its first EAA review.
What are the EAA requirements?
The EAA’s requirements cover both functional accessibility and administrative obligations. On the functional side, covered products and services must meet the POUR principles from the Web Content Accessibility Guidelines (WCAG): Content and functionality must be perceivable, operable, understandable, and robust for people with disabilities.
Conformance with the newest version of the EU’s digital accessibility standard, EN 301 549, is the most straightforward path to meeting EAA requirements. If you conform to EN 301 549, you’re presumed to be compliant with the EAA under Article 15. That said, enforcement authorities can still challenge that presumption if they find evidence that your product or service isn’t accessible in practice, even if it meets the standard.
But functional accessibility is only part of the picture. If you manufacture covered products, you’ll also need to prepare technical documentation, conduct conformity assessments, apply CE marking, and keep records for five years. If you provide covered services, you’ll need to publish an accessibility statement, offer at least one accessible customer support channel where users can ask questions and report issues, and maintain ongoing compliance processes.
What does an EAA accessibility statement need to include?
An EAA-compliant accessibility statement should include:
For deeper insight on what makes an accessibility statement EAA-compliant, including examples and common pitfalls, explore our blog on EAA accessibility statements.
What role does EN 301 549 play in EAA compliance?
EN 301 549 is the EU's unified standard for information and communication technology (ICT) accessibility and the most straightforward path to demonstrating EAA compliance. The current version, EN 301 549 v3.2.1, incorporates WCAG 2.1 Level AA in full. But EN 301 549 goes beyond WCAG to address accessibility for a broader range of ICT products and services, including hardware, mobile apps, documentation, video players, and third-party content integrated into covered digital services. To be EAA-compliant, you need to ensure your full digital experience, including third-party components, meets these standards.
WCAG 2.2 and the EN 301 549 v4.1.1 update
A new version of the European standard, EN 301 549 v4.1.1, is expected to publish in 2026. Once published in the Official Journal of the EU, this is likely to become the technical standard for EAA compliance. This update will incorporate WCAG 2.2, which introduced nine new success criteria compared to WCAG 2.1, covering:
Conforming with WCAG 2.2, the latest version, can help organizations meet the needs of a broader group of users and stay ahead of evolving regulatory expectations. WCAG 2.2 is backwards compatible with WCAG 2.1. So, early adoption creates no compliance conflict while preparing for future obligations.
Exceptions to the EAA
Certain organizations may claim the following exemptions from the EAA requirements.
Microenterprises with fewer than 10 employees and an annual turnover or annual balance sheet total of no more than €2 million are exempt from EAA service accessibility requirements. This exemption applies to services only, not products. If your business grows past these thresholds, the exemption disappears immediately, so there’s no grace period. It also doesn’t apply if your business has received funding specifically for accessibility improvement.
Article 14 of the EAA lets businesses claim that certain accessibility requirements would impose a disproportionate burden—sometimes called an undue burden—where the cost of compliance outweighs the benefit to people with disabilities. This is not a blanket exemption.
To claim disproportionate burden, you’ll need to document your justification using the criteria in Annex VI of the EAA and make that documentation available to enforcement authorities if requested. The assessment also needs to be revisited at least every five years. And it’s worth noting that this isn’t a way out of accessibility altogether. It only applies to specific requirements that are genuinely impractical to meet.
Supply chain responsibilities
EAA requirements apply across the entire supply chain, not just to the end seller. Manufacturers carry the broadest obligations: design, conformity assessment, technical documentation, and CE marking. From there, importers are responsible for verifying conformity and confirming CE marking is in place before sale. Distributors, in turn, check CE marking and documentation and halt sales of non-compliant products.
At every level, any business in the supply chain is also required to notify regulators in every Member State where non-compliant products or services are being sold. And if a distributor or importer modifies a covered product or places it on the market under their own name, they take on the full obligations of a manufacturer.
Who does the EAA
apply to?
The EAA applies to any business—manufacturer, importer, distributor, or service provider—that sells covered products or services to EU consumers, regardless of where the company is based. That includes organizations based outside the EU, which are also required to appoint an EU-based representative to handle compliance requirements on their behalf.
Products and services covered by the EAA
The table below shows the main categories of products and services covered by the EAA.
| Category | Examples |
|---|---|
| Computers and operating systems | Desktops, laptops, tablets, smartphones |
| Self-service terminals | ATMs, payment terminals, ticketing machines, check in machines, interactive kiosks |
| Electronic communications equipment | Routers, modems, VoIP phones |
| TV and audiovisual media devices | Smart TVs, streaming devices, set-top boxes |
| E-readers | Dedicated e-book reading devices |
| Electronic communication services | Phone and internet services, mobile apps, mobile applications |
| Banking services | Consumer banking, credit, payment, investment, e-money services |
| E-commerce | B2C online services via websites or mobile apps, full customer journey |
| Transportation information services | Websites, mobile apps, electronic tickets, real-time travel information |
| Audiovisual media services | Audio descriptions, sign language interpretation, subtitles for television broadcast, streaming, and on-demand audiovisual media services |
| E-books | Digital books and dedicated software |
| Emergency communications | Calls to the European emergency number 112 |
EAA enforcement: Lawsuits, audits, and penalties
EAA enforcement is now underway across Europe. Through the second half of 2025, most national authorities were focused on building their enforcement capacity. But several have already started auditing organizations, handling complaints, and issuing formal notices.
Financial penalties aren't the only risk. Authorities can also order product withdrawal, ban non-compliant products from national markets, require accessibility audits, and publicly name organizations that fall short. In some jurisdictions, competitors can pursue unfair competition claims against organizations that haven't met their accessibility obligations.
On July 7, 2025, French disability organizations sent formal legal notices to Auchan, Carrefour, E.Leclerc, and Picard Surgelés. When responses proved inadequate, emergency injunctions were filed in French Commercial Court on November 12, 2025—the first EAA-related lawsuits in Europe.
The Auchan case was heard in May 2026 and dismissed on procedural grounds, though the court acknowledged the website’s inaccessibility. The organizations are appealing.
In June 2026, the Carrefour case was heard, and on a major court decision for digital accessibility, the Court ordered the company Carrefour France to make both its e-commerce site and mobile application fully accessible to people with disabilities. Carrefour has six months to comply with this injunction, under penalty of a fine for each day of delay.
The Swedish Post and Telecom Authority (PTS) began inspecting laptops, smartphones, and tablets in October 2025 and opened its first e-commerce regulatory cases. PTS has also received 124 public complaints—110 related to services and 14 related to products—showing that consumers know their rights under the EAA and aren’t hesitant to use them.
The Dutch Consumer and Market Authority (ACM) sent information requests to e-commerce operators globally, including companies headquartered outside the EU. Active enforcement in the Netherlands is expected in the second half of 2026.
In Germany, e-commerce operators began receiving private warning letters from law firms shortly after the EAA transposition took effect—reflecting Germany’s competition law enforcement dynamic, where private parties can pursue non-compliance as an unfair competition claim. Enforcement won’t be evenly paced across all 27 EU Member States, but the direction is consistent.
The EAA requires penalties to be effective, proportionate, and dissuasive—but the specific amounts are set by each Member State. Here’s how the fines break down by country.
| Country | Maximum fine |
| Sweden | ~€900,000 (SEK 10 million) |
| Spain | €600,000 |
| France | €75,000 per violation or daily penalties up to €3,000 (capped at €300,000); for serious breaches, up to 0.1% of worldwide turnover per day (capped at 5% of annual turnover). |
| Netherlands | €90,000 |
| Austria | €80,000 per violation |
| Germany | €100,000 per violation |
| Italy | €40,000 per violation and up to 5% of annual turnover |
| Ireland | €60,000 |
Financial penalties aren’t the only risk. Authorities can also order product withdrawal, ban non-compliant products from national markets, require accessibility audits, and publicly name organizations that fall short. In some jurisdictions, competitors can pursue unfair competition claims against organizations that haven’t met their accessibility obligations.
What are the consequences of non-compliance with the European Accessibility Act?
The EAA will be enforced through market surveillance by individual EU nations, and organizations that fail to comply may face significant consequences. While specific penalties vary from country to country, punitive measures may include steep fines (up to three million euros), the removal of products or services from the market, and the suspension of an organization’s right to do business.
The EAA and ESG
EAA compliance isn't just a legal obligation. For organizations subject to the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), it also supports your environmental, social, and governance (ESG) reporting obligations.
ESRS social standards explicitly address disability inclusion, non-discrimination, and equal access—areas where EAA compliance provides documented, measurable evidence of progress. For those organizations, EAA compliance can be disclosed under "Consumers and end-users" and "Equal treatment and opportunities," making it a tangible demonstration of your commitment to social responsibility.
EAA and the EU AI Act: What changes in 2026?
The EU AI Act (Regulation 2024/1689) becomes fully enforceable on August 2, 2026, integrating accessibility into AI governance. It requires that providers of high-risk AI systems comply with existing, applicable EU laws, including the EAA, and Article 5(1)(b) prohibits AI systems that exploit the vulnerabilities of people with disabilities. If your organization develops or uses high-risk AI systems in the EU, these requirements should be part of your AI compliance planning.
How to achieve EAA compliance
Achieving EAA compliance isn't a one-time project. Your covered products and services need to meet accessibility standards at launch and continue to meet them as your content, features, and third-party integrations evolve. Here are the key steps to get started:
Download our Complete Guide to EAA Compliance for a full roadmap.
Start your EAA compliance journey with Level Access
Level Access helps organizations across Europe and beyond achieve and maintain EAA compliance. Our solution combines platform automation, AI agents, and expert manual evaluation to help you find, fix, and prove accessibility at scale. Get started with a free risk assessment from our experts.
Frequently asked questions
Which organizations are not required to comply with the EAA?
Microenterprises with fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million are exempt from EAA service requirements. This exemption applies to services only, not products. Organizations for whom compliance would impose a disproportionate burden may claim an exemption under Article 14 but must document the assessment using Annex VI criteria and reassess at least every five years.
Does the EAA apply to non-EU companies?
Yes. The EAA applies to any economic operator that places covered products on the EU market or provides covered services to EU consumers, regardless of where the company is headquartered. US businesses serving EU customers must comply with EAA requirements and appoint an EU-based authorized representative.
Does the EAA use WCAG?
Yes. EN 301 549 v3.2.1, the EAA’s harmonized standard, incorporates WCAG 2.1 Level AA in full. The upcoming v4.1.1, expected in 2026, will incorporate WCAG 2.2. EN 301 549 also includes additional requirements beyond WCAG, covering hardware, mobile apps, documentation, and video players.
Can I be fined under the EAA in multiple EU countries simultaneously?
Yes. Each EU Member State enforces the EAA independently through its own designated authorities. A company selling non-compliant products or services across multiple EU countries could face enforcement actions in each jurisdiction. Penalties, enforcement timelines, and complaint processes differ by country.
What must an EAA accessibility statement include?
An EAA accessibility statement must include the service provider’s name and contact details, a description of the service’s accessibility features, a description of any aspects not covered due to disproportionate burden or fundamental alteration and accessible support channel details.