European Accessibility Act: Who It Covers and What Websites and Apps Need

The European Accessibility Act (EAA) brought accessibility law to the private sector across the European Union. Since 28 June 2025, businesses that sell certain products or provide certain services to EU consumers must make them accessible to people with disabilities. For most software teams, that means websites, mobile apps, online checkouts, e-books, e-tickets and customer account areas must meet detailed accessibility requirements, in practice those of the harmonised standard EN 301 549, which incorporates WCAG 2.1 Level AA for web content.

The Act applies wherever the business is based, so Indian, US and UK companies selling to EU consumers are covered. This guide explains which products and services are in scope, the accessibility requirements, the microenterprise exemption and other exemptions, conformity and information duties, enforcement, and the engineering work behind compliance.

What is the European Accessibility Act?

The EAA is Directive (EU) 2019/882. As a directive, it was transposed into national law by each member state, which had to adopt their laws by 28 June 2022 and apply them from 28 June 2025. Its accessibility requirements are set out in Annex I, and conformity can be presumed where products and services meet harmonised standards published in the Official Journal. For ICT, the relevant harmonised standard is EN 301 549, maintained by ETSI, CEN and CENELEC; its current version incorporates WCAG 2.1 Level AA for web content and similar requirements for software, documents and hardware.

The EAA complements the Web Accessibility Directive (Directive (EU) 2016/2102), which already required public sector websites and apps to be accessible.

History and why the EAA was introduced

Before the EAA, accessibility requirements differed between member states, creating barriers for businesses selling across borders and leaving many people with disabilities unable to use everyday products and services. The EU is a party to the UN Convention on the Rights of Persons with Disabilities, which requires accessible goods and services. The Commission proposed the Act in 2015, and it was adopted in April 2019 with a long implementation period.

The aims are to improve the functioning of the internal market by harmonising accessibility requirements, and to increase the availability of accessible products and services for people with disabilities and older people.

Which products and services are covered?

Products

• Consumer general-purpose computer hardware systems and their operating systems.
• Self-service terminals: payment terminals, ATMs, ticketing machines, check-in machines and interactive information terminals.
• Consumer terminal equipment used for electronic communications (such as smartphones) and for accessing audiovisual media services (such as smart TVs).
• E-readers.

Services

• Electronic communications services, including emergency communications.
• Services providing access to audiovisual media services.
• Elements of air, bus, rail and waterborne passenger transport services: websites, mobile services, electronic tickets, ticketing services and real-time travel information.
• Consumer banking services.
• E-books and dedicated software.
• E-commerce services: services provided at a distance through websites and mobile apps by electronic means at the request of a consumer, with a view to concluding a consumer contract.

E-commerce is the broadest category for software companies: any online shop or service that lets EU consumers buy goods or services online is likely in scope, including its product pages, search, account, cart, checkout and payment steps.

Who is not covered

• Microenterprises providing services, meaning businesses with fewer than 10 employees and an annual turnover or balance sheet total not exceeding 2 million euros, are exempt from the service requirements. Microenterprises dealing in products are not exempt but have lighter obligations.
• Business-to-business services that are not offered to consumers are generally outside the e-commerce category.
• Certain content is excluded from website and app requirements, such as pre-recorded media published before 28 June 2025, archived content not updated after that date, and third-party content not funded, developed or controlled by the provider.

Accessibility requirements

Annex I sets general requirements for products and services, which in practice translate to:

• Information about the product or service provided through more than one sensory channel, in understandable and perceivable ways.
• Websites and mobile apps made accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust, which mirrors the WCAG principles.
• Accessible electronic documents, forms and support information.
• For e-commerce, accessible information about the accessibility of products sold, accessible identification, security and payment methods, and accessible support services.
• For banking, accessible identification methods, electronic signatures, security and payment services, and information at a reading level not exceeding a certain complexity.
• For products, accessible user interfaces, packaging and instructions, and compatibility with assistive technologies.

Meeting EN 301 549 gives a presumption of conformity for the ICT aspects. For web content, that means WCAG 2.1 AA; teams building to WCAG 2.2 AA meet it and are ready for future updates.

EN 301 549 and its revision

EN 301 549 covers far more than websites. Its chapters set requirements for web content (chapter 9, which follows WCAG 2.1 Level AA), non-web documents such as PDFs (chapter 10), software including mobile apps (chapter 11), documentation and support services (chapter 12), two-way voice communication, video, hardware and other areas. For an online shop or banking app, chapters 9, 10, 11 and 12 are usually the relevant ones.

The version widely cited today is V3.2.1 from 2021, which was developed for the Web Accessibility Directive. A revision, numbered V4, is being prepared to support the European Accessibility Act more directly and to align with newer WCAG content; drafts were circulated in 2025. Until a new version is cited in the Official Journal as the harmonised standard for the EAA, check the current position with the relevant national authority. In practice, building to WCAG 2.2 AA for web content and following EN 301 549 for apps, documents and support channels keeps you aligned with both versions.

Obligations for service providers

• Design and provide services in accordance with the accessibility requirements.
• Publish accessibility information in their general terms and conditions or equivalent (Annex V): a description of the service in an accessible format and how it meets the requirements. This is often done through an accessibility statement.
• Keep the information as long as the service is in operation.
• Ensure continued conformity when services change, and take corrective action if they do not conform, informing authorities.
• Cooperate with authorities and provide information on request.

Disproportionate burden and fundamental alteration

A provider may be exempt from specific requirements if meeting them would fundamentally alter the service or impose a disproportionate burden, based on an assessment using criteria in Annex VI (costs and benefits relative to the provider's size and resources). The assessment must be documented, renewed periodically, and provided to authorities on request. Funding from public or private sources for accessibility cannot be ignored in the assessment.

Obligations for product makers

Manufacturers must ensure products meet the requirements, draw up technical documentation, carry out conformity assessment (internal production control), draw up an EU declaration of conformity and affix CE marking, and provide accessible instructions. Importers and distributors check that these steps have been taken.

Transitional periods

Member states may provide a transitional period until 28 June 2030 during which service providers can continue to provide services using products lawfully used before 28 June 2025. Service contracts agreed before 28 June 2025 may continue unaltered until they expire, but no longer than five years from that date. Self-service terminals lawfully used before 28 June 2025 may continue in use until the end of their economically useful life, but no longer than 20 years after they entered into use. These transitions do not exempt new or redesigned websites and apps.

How to comply, step by step

1. Check scope: which of your products and services fall under the EAA categories, and whether the microenterprise exemption applies.
2. Audit your digital channels against EN 301 549 and WCAG 2.1 AA (or 2.2 AA), including mobile apps and documents.
3. Prioritise critical journeys: registration, login, search, product information, cart, checkout, payment, account management and customer support.
4. Fix design systems and components so every page benefits.
5. Check third-party components: payment widgets, chat tools, cookie banners and embedded media must also be accessible.
6. Publish accessibility information and an accessibility statement with a contact for feedback.
7. Document any disproportionate burden assessments.
8. Build accessibility into your development process so new features conform.
9. Monitor national requirements in the countries where you operate.

Documentation you will need

• Scope assessment of products and services.
• Accessibility audit reports mapped to EN 301 549 and WCAG.
• Accessibility information under Annex V, and an accessibility statement.
• Remediation plans and records of fixes.
• Disproportionate burden assessments, if used.
• For products: technical documentation, EU declaration of conformity and accessible instructions.

Enforcement and penalties

Each member state designates authorities to check compliance of services and to perform market surveillance of products. Authorities can require corrective action, restrict or prohibit services and withdraw products. Penalties are set by national law and must be effective, proportionate and dissuasive; amounts and procedures vary by country, and some laws allow consumers or organisations representing them to bring complaints or court actions. There is no EU-wide certification.

Timeline and cost considerations

The Act has applied since June 2025, so in-scope businesses should already conform or be completing remediation. Cost depends on the size and age of the digital estate, use of custom components, and third-party dependencies. Rebuilding on an accessible design system is often cheaper over time than repeated patching.

Benefits and consequences

Accessible stores and services reach more customers, including older users, and usually convert better because forms and flows are clearer. Non-compliance risks enforcement orders, penalties, complaints, reputational harm and exclusion from public procurement, where accessibility is also required.

Common mistakes and challenges for IT companies

• Assuming non-EU businesses are exempt. Selling to EU consumers brings you into scope.
• Relying on overlays instead of fixing code and content.
• Ignoring mobile apps and documents such as invoices and PDFs.
• Inaccessible third-party payment or login widgets.
• Misreading the microenterprise exemption, which covers services only and has strict thresholds.
• No accessibility information published for consumers.

Best practices, tools and technologies

• Use accessible e-commerce themes and components, and test them yourself rather than relying on vendor claims.
• Test checkout and account flows with screen readers and keyboard only.
• Add automated accessibility tests to CI and manual audits before major releases.
• Choose payment and identity providers that publish accessibility conformance information.
• Provide accessible invoices and order confirmations.

We audit and fix online stores and design accessible interfaces through our UI/UX design service.

How the EAA relates to other frameworks

Law or standard	Relationship
WCAG	Technical basis for web requirements through EN 301 549.
EN 301 549	Harmonised European standard giving presumption of conformity for ICT.
Web Accessibility Directive	Covers public sector websites and apps; the EAA covers private sector products and services.
Section 508 and ADA	US equivalents for federal ICT and for public accommodations and governments.
Digital Services Act	Other EU law affecting online platforms; includes some accessibility-related duties for platform interfaces.

Real-world implementation examples

Ahead of June 2025, many European retailers, banks and transport operators ran accessibility programmes on their websites and apps, and accessibility statements became common on EU e-commerce sites. National authorities have begun publishing guidance and monitoring approaches.

An illustrative case for an Indian e-commerce platform selling to customers in Germany and France: the checkout used a custom date picker and payment iframe that screen readers could not use, and product images lacked alternatives. The company replaced the date picker with an accessible component, worked with its payment provider to use an accessible hosted field, added alt text guidance for merchants, and published an accessibility statement in German and French with a feedback contact.

Next steps

1. Confirm which of your services and products are in scope.
2. Audit websites, apps and documents against EN 301 549 and WCAG.
3. Fix critical journeys and shared components first.
4. Publish accessibility information and a statement.
5. Embed accessibility in your development process so new features conform from the first release.

Frequently asked questions

When did the European Accessibility Act start to apply?

National laws implementing it apply from 28 June 2025.

Does the EAA apply to companies outside the EU?

Yes, when they place products on the EU market or provide in-scope services to consumers in the EU.

Does the EAA apply to all websites?

No. It applies to websites and apps that are part of in-scope services, such as e-commerce, consumer banking, transport and e-books. Public sector sites are covered by the Web Accessibility Directive.

Which standard should we follow for the EAA?

EN 301 549, which incorporates WCAG 2.1 Level AA for web content. Building to WCAG 2.2 AA also meets it.

Are small businesses exempt?

Microenterprises (fewer than 10 employees and turnover or balance sheet not exceeding 2 million euros) are exempt from the service requirements, but not from product requirements.

Do B2B companies have to comply?

Generally not for services offered only to businesses, because the e-commerce category concerns consumer contracts. Products in scope must comply whoever buys them.

What are the EAA penalties?

Each member state sets its own penalties and enforcement procedures, which must be effective, proportionate and dissuasive.

Do mobile apps fall under the EAA?

Yes, when they are part of an in-scope service, such as a shopping or banking app.

What is a disproportionate burden?

An exemption from specific requirements where compliance would impose costs out of proportion to the provider's resources and the benefits, based on a documented assessment.

Does the EAA cover customer support channels?

Yes. Support services such as help desks, call centres and online help must provide information about the accessibility of the service and its compatibility with assistive technologies, in accessible ways.

Do we need an accessibility statement?

Service providers must publish information on how their services meet the accessibility requirements; an accessibility statement is the usual way to do this.