The European Accessibility Act (EAA) establishes a unified regulatory framework for a broad range of products and services in the EU. The EAA aims to ensure that offerings are accessible to people with disabilities and functional limitations —both in physical and digital environments. While accessibility requirements for services apply only if they are offered to EU consumers, requirements for products are not limited to consumer use. The EAA’s objective is to harmonize accessibility standards across the EU, reduce market fragmentation, and promote inclusion.

The EAA was required to be implemented through national legislation by all 27 EU Member States by June 28, 2025. With this deadline now passed, largely harmonized accessibility rules apply across the EU. Companies active in the EU market may need to consider how accessibility is integrated into product design, service delivery, and customer experience.

Scope of the EAA: Covered Products and Services

The EAA’s accessibility requirements apply to a defined list of products and services considered essential for participation in daily life and the internal market. These include both physical goods and digital services, with a strong emphasis on consumer-facing offerings. Sectors such as technology, e-commerce, retail, financial services, and mobility are particularly affected.

Products in scope include smartphones, computers, e-readers, self-service terminals such as ATMs, ticketing, and check-in machines. On the services side, the EAA applies to e-commerce platforms, banking and financial services, telecommunications, transport-related services (such as ticketing and real-time travel information), and audiovisual media services.

Key Accessibility Requirements Under the EAA

The EAA requires that covered products and services be accessible by design. While specific requirements vary by category, the EAA outlines several core requirements:

• Perceivability: Information must be presented in ways that are perceivable to users with different sensory abilities, such as providing text alternatives for images, captions for videos, and audio descriptions.
   
• Operability: Products and services must be usable through a variety of input methods, including assistive technologies. Interfaces should not require actions that users with disabilities cannot perform (e.g., gestures, time-limited responses).
   
• Understandability: Information and user interfaces must be clear and easy to understand, with consistent navigation, readable text, and straightforward instructions.
   
• Robustness: Digital content must be compatible with a wide range of current and future assistive technologies, following recognized standards such as the Web Content Accessibility Guidelines (WCAG).
   
• Accessible Information and Instructions: All instructions, user support, and product information—including manuals, packaging, and digital help content—must be accessible.
   
• Customer Service Accessibility: Support services, including helplines and chatbots, must be accessible to users with disabilities.
   
• Interoperability with Assistive Technologies: Products and services must be designed to work with assistive devices such as screen readers, Braille displays, and alternative input devices.

EAA Exceptions: Microenterprises, Fundamental Alteration, and Disproportionate Burden

The EAA provides for specific exceptions in certain circumstances:

• Microenterprise Exemption: Businesses with fewer than 10 employees and an annual turnover or balance sheet total not exceeding EUR 2 million are exempt from many EAA requirements.
   
• Fundamental Alterations: Accessibility requirements do not apply if compliance would fundamentally change the nature or core functionality of the product or service.
   
• Disproportionate Burden: Requirements may not apply if compliance would impose a disproportionate burden on the company.

Legal and Commercial Risks of Non-Compliance with the EAA

Non-compliance with national implementation laws can result in legal and commercial consequences. Enforcement is governed by the national legal frameworks, so specific consequences vary across Member States. For example, under the German implementing law, authorities may impose administrative fines of up to EUR 100,000 and order corrective measures, including product recalls or withdrawal of non-compliant services from the market. Consumer protection associations and competitors may also take action through competition law, such as issuing formal cease-and-desist demands.

Practical Considerations for Businesses Regarding EAA Compliance

With the EAA regulatory framework now in force, companies may wish to consider the following steps:

• Identify in-scope products and services: Determine which products and services fall within the scope of the legislation.
   
• Conduct a gap analysis: Assess current accessibility features in relation to legal requirements.
   
• Develop an implementation plan: Prioritize technical and organizational changes as needed.
   
• Document exceptions: If relying on exemptions (such as fundamental alteration or disproportionate burden), ensure that assessments are well-reasoned and properly recorded.
   
• Train internal teams: Raise awareness among product, legal, and customer service teams.
   
• Monitor compliance: Establish internal controls and update processes as regulatory standards evolve.