European Accessibility Act (EAA): who it covers and what it asks

In short

Not legal advice.This page summarises the text of the directive as I read it. Every EU member state had to write the directive into its own law. Before you decide anything, read the law of the country you sell in and ask a lawyer.

• The official name is Directive (EU) 2019/882. It is dated April 17, 2019 and was published in the Official Journal of the EU, L 151, on June 7, 2019.
• It covers certain products and certain consumer services. E-commerce is one of them.
• Member states apply the rules from June 28, 2025.
• Micro-enterprises providing services are exempt from the requirements for services.
• The directive names neither EN 301 549 nor WCAG. It ties the presumption of conformity to harmonised standards published in the Official Journal of the EU.

What is the EAA?

The EAA is a directive that aligns accessibility requirements for products and services across the EU. Unlike a regulation, it doesn't apply directly. Each member state had to write the text into its own law.

Under Article 31, the deadline for doing so was June 28, 2022. The national laws apply from June 28, 2025.

Public sector websites and apps in the EU have their own text: Directive 2016/2102. Recital 46 asks for the accessibility requirements of the two directives to fit together. The EAA's rules on online selling, on the other hand, don't ask whether the seller is public or private.

Does it apply to US companies?

The directive is about what is offered to consumers in the EU, not where the company is based. Article 2 covers products placed on the EU market and services provided to consumers. A US online shop that sells to people living in the EU should therefore look at it. Where exactly the line is drawn is a question for a lawyer who knows the law of the country you sell in.

Who does it cover?

Article 2 sets out the scope in two lists. The first covers products placed on the market after June 28, 2025. The second covers services provided to consumers after that date.

Services

Service	In the directive
E-commerce	Article 2(2)(f) and 3(30)
Consumer banking services	Article 2(2)(d) and 3(28)
E-books and reading software	Article 2(2)(e)
Passenger transport	Article 2(2)(c)
Electronic communications services	Article 2(2)(a)
Access to audiovisual media services	Article 2(2)(b)

Under Article 3(30), an e-commerce service is a service provided at a distance, through a website or a mobile app, with a view to concluding a consumer contract. Recital 43 applies these rules to the online sale of any product or service.

Consumer banking services are defined in Article 3(28). Consumer credit, payment services, payment accounts and e-money are among them.

Transport has an exception. In urban, suburban and regional transport, only interactive self-service terminals are covered (Article 2(2)(c)).

Products

Product	In the directive
Computers and operating systems	Article 2(1)(a)
Self-service terminal	Article 2(1)(b)
Communications or media device	Article 2(1)(c) and (d)
E-reader	Article 2(1)(e)

If you build an online shop, a banking app or an app that sells tickets, look at the list of services.

Deadlines and transition periods

The key dates are in Articles 31 and 32:

• June 28, 2022: last day for member states to write the directive into national law (Article 31(1)).
• June 28, 2025: the date from which the national rules apply (Article 31(2)).
• June 28, 2027: member states can delay the rules on answering emergency calls to 112 until this date at the latest (Article 31(3)).
• June 28, 2030: end of the transition period. Until then, service providers may keep providing their service with products they used lawfully before (Article 32(1)).

Article 32 adds two details. Service contracts agreed before June 28, 2025 can continue unchanged until they expire, but no longer than five years from that date. Member states can also allow self-service terminals in use before that date to keep running until the end of their economic life, but no longer than 20 years after they were put into use.

Don't read the transition period as a delay for your website or app. I read it as a window for older hardware and running contracts. Ask your lawyer about your case.

The micro-enterprise exemption

Article 3(23) defines a micro-enterprise as an enterprise that employs fewer than 10 persons and whose annual turnover or annual balance sheet total does not exceed EUR 2 million.

Article 4(5) exempts micro-enterprises providing services from the requirements for services and the related obligations. A small online shop within these limits therefore doesn't have to meet the requirements for services.

Products are different. There is no general micro-enterprise exemption. Recital 71 only asks for the burden to be kept low. Article 14(4), for example, frees micro-enterprises dealing with products from documenting their assessment of a disproportionate burden.

Recital 53 also has a warning. The company has to actually meet the conditions of Recommendation 2003/361/EC. Article 4(6) asks member states to offer micro-enterprises guidelines and tools.

Try it: am I covered?

Answer four questions. The tool compares your answers with Articles 2, 3 and 4 of the directive and gives a first result. Each reason comes with the article it is based on.

Am I covered?

This question flow needs JavaScript. The same information is in the scope tables and the micro-enterprise section above.

The questions are based on Articles 2, 3 and 4 of Directive (EU) 2019/882. The result is a first check, not a binding answer. National laws can add details. This is not legal advice.

Whatever the result, the final word belongs to the law of the country you sell in. The tool only shows you where to start.

What does it require?

The requirements are in Annex I. For services, sections III and IV apply (Article 4(3)). For websites and mobile apps, the benchmark is four principles: perceivable, operable, understandable and robust.

According to recital 47, these are the four principles of Directive 2016/2102, and they apply to this directive too. WCAG 2.2 also groups its success criteria under the same four principles. I cover the details in the WCAG guide.

Points for specific sectors

• E-commerce (Annex I, section IV (g)): information on the accessibility of the products and services sold, where the responsible economic operator provides it. Identification, security and payment also have to be accessible.
• Consumer banking (section IV (e)): identification, electronic signatures, security and payment follow the four principles. Information is written at a level of complexity no higher than B2 (upper intermediate) of the Council of Europe's Common European Framework of Reference for Languages.
• E-books (section IV (f)): compatibility with assistive technologies, navigable content and accessibility metadata are required. Digital rights management must not block accessibility features.

Payment appears twice in this list, and that's where I look first. On the checkout pattern page I collected the places where it often goes wrong.

Documentation and statement

Article 13(2) and Annex V require you to explain in your general terms and conditions, or an equivalent document, how the service meets the requirements. This information has to be accessible and stay available for as long as the service is offered.

Article 14 allows two exceptions: when a requirement would mean a fundamental alteration of the product or service, and a disproportionate burden. The disproportionate burden is assessed against the criteria in Annex VI, and the results are kept for five years. A service provider relying on a disproportionate burden has to renew the assessment at least every five years. Unless it is a micro-enterprise, it also has to inform the relevant authority.

How it relates to EN 301 549 and WCAG

The text of the directive names neither EN 301 549 nor WCAG. I searched the text for both.

Under Article 15, products and services that meet harmonised standards whose references are published in the Official Journal of the EU are presumed to conform to the directive. The European standardisation organisations write those standards.

According to the W3C's EU policy page, Directive 2016/2102 uses EN 301 549 for public sector websites. That standard includes WCAG 2.1 AA verbatim for web content.

I recommend teams start with WCAG 2.2 AA. WCAG 2.2 is the W3C Recommendation of December 12, 2024, it rests on the same four principles, and it covers the WCAG 2.1 criteria too.

Enforcement and penalties

Market surveillance is up to the member states. Article 23 requires procedures to check whether services conform. Complaints have to be followed up, and it has to be checked whether shortcomings were fixed.

Each country sets its own penalties too. Article 30 requires them to be effective, proportionate and dissuasive. The extent of the non-compliance and the number of units and people affected have to be taken into account.

I don't quote fine amounts, because I haven't read them in any official text. Ask anyone who quotes you an amount for the source. The source should be the law of the country concerned.

What to do, step by step

1. Check the scope. Use the tool above. Then read, with your lawyer, the law of the country you sell in.
2. List your flows. Sign-up, product page, cart, payment and account screens. The directive names payment and identification separately.
3. Test by hand. Navigate with the keyboard, listen with a screen reader. I describe the method step by step in the guide to the accessibility audit.
4. Go through your images. Every product photo needs alt text that describes the product.
5. Write the accessibility information. Add the statement Annex V asks for to your terms and conditions or a page of its own.
6. Simplify the language in banking. Use the B2 limit from Annex I as the benchmark for your copy.

My note

What struck me most when reading the EAA is how much weight payment carries. In both e-commerce and banking, identification and payment are named separately.

In a payment flow I ask first: where does keyboard focus go when the 3-D Secure window opens? Then I look at the labels on the card fields and whether error messages reach the screen reader. These places sit right at the last step of the sale.

If you want your product checked with this lens, the UX Audit includes the core WCAG 2.2 checks. It doesn't replace proof of conformity, but it shows you where to start.