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 coming 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 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.
What industries, products, and services does the European Accessibility Act apply to?
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.
E-commerce and online service providers
- Consumer-facing sites and apps
Note: To comply with the EAA, providers must publish accessibility statements indicating how they meet the Act’s requirements.
Shops and restaurants
- Point-of-sale devices, self-service technologies, and kiosks
Computer / mobile device manufacturing / importing / distribution
- Computers and mobile phones
- Communication and telephony equipment with computer capability
- Media equipment with computer capability
- E-readers
- Point-of-sale devices and self-service kiosks
Note: In addition to meeting product-specific accessibility requirements, providers of these technologies must ensure the accessibility of product packaging, instructions, and labeling.
Airlines and transport
- Websites
- Mobile apps
- Point-of-sale devices, kiosks, and self-service transaction machines
- Electronic tickets and electronic ticketing services
- Delivery of transport service information, including real-time travel information
Note: The EAA’s requirements apply to airlines outside the EU that have departures from the EU.
Financial industry
- Websites
- Consumer banking services
- Mobile apps
- ATMs, point-of-sale devices, kiosks, and self-service transaction machines
- Contact information
Media streaming and telephony providers
- Mobile apps
- Websites
- Communication and telephony equipment with computer capability
- Media equipment with computer capability
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.
Business-to-business (B2B) and business-to-government (B2G) organizations
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.
Healthcare organizations
The EAA does not directly address healthcare services unless services offered are the same as any of the previously listed experiences or technologies.
Exceptions
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.
What is the standard for compliance with the European Accessibility Act?
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 your assets meet EAA compliance requirements, they likely need to conform with 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.
For more practical insight on achieving EAA compliance, explore our complete EAA resource hub.
What are the requirements for European Accessibility Act compliance?
Conforming with EN 301 549 alone won’t guarantee compliance with the EAA. National laws incorporating the EAA outline an array of other requirements for product and service providers, many of which focus on how accessibility is managed within an organization. Common national requirements include implementing accessibility training for employees and monitoring accessibility on an ongoing basis. In many nations, organizations covered by the EAA must also publish an accessibility statement containing:
- Information about the functionality of a product / service
- Documentation of a product / service’s technical accessibility specifications and design processes
- A description of how a product / service meets the EAA’s accessibility requirements
- The names of enforcement authorities to which users can file accessibility complaints
- Additional requirements around accessibility information, packaging, and labelling apply to covered products.
Download our info sheet for a condensed overview of the EAA’s requirements, and how to meet them.
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.
Mitigate legal and business risks by creating inclusive digital experiences
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.
Frequently asked questions
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 an overlay alone does not guarantee compliance with European accessibility legislation. While we agree it does not guarantee compliance, the technology can play an important role when leveraged as part of a comprehensive approach.
An overlay typically consists of two types of technology—automated remediation and user personalization tools.
When integrated into a site, automated remediation can find and fix many common accessibility errors but should never be considered a complete solution. Manual work is required to identify, and fix, more complex accessibility barriers.?
User personalization tools enable the site visitor to customize their experience, adjusting the visual appearance of the site. Examples include altering color contrast, font size, font spacing, cursor size, highlight links, and more. These adjustments make the site more usable for the visitor but do not solve underlying accessibility barriers.