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The European Accessibility Act: who it covers, from when, and what a software vendor does

The European Accessibility Act is an EU directive that sets accessibility requirements for a list of consumer products and services. It has applied since 28 June 2025, through each member state’s own law. Here is what it covers, what meeting it means in practice, who enforces it, and what a software vendor should do. This guide explains the law in plain words. It is not legal advice.

Accessibility · Published

In short

  • The European Accessibility Act is Directive (EU) 2019/882. Its rules have applied since 28 June 2025, through each EU member state’s national law.
  • It covers a fixed list: products such as computers, phones and e-readers, and services to consumers such as e-commerce, banking, e-books and passenger transport websites and apps.
  • Microenterprises that provide services, those with fewer than 10 staff and no more than EUR 2 million in turnover or balance sheet, are exempt from the service requirements.
  • Aim for WCAG 2.2 Level AA. A product or service that follows a harmonised standard cited in the EU’s Official Journal is presumed to conform. For websites and apps, the standard is EN 301 549, which builds on WCAG 2.1 Level AA in the version cited today; version 4.1.1 moves to WCAG 2.2 Level AA.
  • Each member state enforces it, with penalties it sets itself.
  • Software sold only to businesses isn’t on the list. Software that runs part of a covered consumer service, such as an online shop’s checkout, has to meet the requirements that apply to that service.

What the European Accessibility Act is

The European Accessibility Act (EAA) is Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services. It was published in the Official Journal on 7 June 2019 and entered into force on 27 June 2019.

A directive isn’t applied directly. Each member state writes it into its own law. Member states had until 28 June 2022 to adopt their national laws, and those laws apply from 28 June 2025. A business follows the national law of each member state where it sells, and the details can differ between them.

The Act sets common requirements so that a product or service accessible in one member state meets the rules in the others.

Which products it covers

Products placed on the market after 28 June 2025:

  • Consumer general-purpose computers and their operating systems.
  • Self-service terminals: payment terminals, ATMs, ticketing machines, check-in machines and interactive information terminals. Terminals built into vehicles, aircraft, ships and trains are excluded.
  • Consumer devices with interactive computing used for electronic communications, such as smartphones.
  • Consumer devices with interactive computing used to access audiovisual media, such as smart TVs.
  • E-readers.

Which services it covers

Services provided to consumers after 28 June 2025:

  • Electronic communications services, such as phone and messaging services.
  • Services that give access to audiovisual media, such as streaming apps.
  • Air, bus, rail and waterborne passenger transport: their websites, mobile apps, electronic tickets, travel information and interactive self-service terminals. Urban, suburban and regional transport is covered only for its interactive self-service terminals.
  • Consumer banking services, such as payment accounts, payments, credit and electronic money.
  • E-books and the software used to read them.
  • E-commerce services: websites and mobile apps that sell to consumers at a distance.

The list is about services to consumers. Software sold only to businesses for their own use isn’t on it.

For websites and apps of covered services, some content is excluded: prerecorded audio and video and office documents published before 28 June 2025, online maps when the essential information is given in an accessible digital form, content from third parties that the provider doesn’t fund, develop or control, and archives not updated after 28 June 2025.

From when

DateWhat happens
27 June 2019The directive enters into force.
28 June 2022Deadline for member states to adopt their national laws.
28 June 2025The national laws apply to the products and services listed above.
Until 28 June 2030Service providers may keep using products they lawfully used before 28 June 2025 to provide similar services. Service contracts agreed before 28 June 2025 may continue unchanged until they end, for at most five years from that date.
Up to 20 years after first useA member state may allow self-service terminals already in lawful use to stay in use until the end of their working life, for at most 20 years.

Each member state sets its own transition rules within these limits.

The microenterprise exemption

A microenterprise employs fewer than 10 people and has an annual turnover, or an annual balance sheet total, of no more than EUR 2 million.

  • Services. A microenterprise that provides a covered service is exempt from the service requirements.
  • Products. A microenterprise that makes, imports or distributes a covered product isn’t exempt. It has lighter paperwork: when it relies on the disproportionate-burden exception below, it doesn’t have to document its reasoning or notify the authorities, though it must give the relevant facts to an authority that asks.

Two exceptions every provider can use

The requirements apply only as far as meeting them doesn’t fundamentally alter the product or service, and doesn’t impose a disproportionate burden on the business. A business that relies on either exception has to weigh it against criteria the directive lists, write down the reasoning and keep it for five years. A service provider reviews it again when the service changes, when an authority asks, and at least every five years. A business that receives outside funding to improve accessibility can’t claim a disproportionate burden.

What conformance means in practice

The Act states its requirements in general terms. For websites and mobile apps, it asks that they be perceivable, operable, understandable and robust, the four principles of WCAG.

A product or service that follows a harmonised standard, once the standard’s reference is published in the Official Journal of the EU, is presumed to conform to the requirements that standard covers. For information and communication technology, the European standard is EN 301 549, Accessibility requirements for ICT products and services, published by ETSI, CEN and CENELEC.

  • Version 3.2.1 (2021) builds on WCAG 2.1 Level A and AA for web content. It is the version cited for the EU’s Web Accessibility Directive, which covers public sector websites and apps. AccessibleEU, the Commission’s accessibility resource center, names it as the current reference.
  • Version 4.1.1 (September 2026) moves to WCAG 2.2 Level A and AA. It adds an annex, Annex ZB, that maps its clauses to the Act’s requirements, and AccessibleEU calls it “the first version of EN 301 549 developed specifically with the European Accessibility Act in mind.” It isn’t yet the legal reference. Once the Commission cites it in the Official Journal, following it gives a presumption of conformity with the Act and the Web Accessibility Directive.

In practice, for a website or app: aim for WCAG 2.2 Level AA. It adds six criteria to WCAG 2.1 Level AA, and it is what version 4.1.1 builds on. A product that meets 2.2 AA meets every 2.1 AA criterion except 4.1.1 Parsing, which 2.2 removed. Every WCAG 2.2 A and AA criterion, in plain words.

A service provider also has to publish information on how its service meets the requirements, usually in its general terms and conditions, in written and oral form and in formats people with disabilities can use, and keep it for as long as the service runs.

Who enforces it

Each member state enforces its own national law. It sets up procedures to check that services conform, follow up complaints and check that problems are fixed, and it names the authorities responsible and tells the public who they are. Products are checked by market surveillance authorities, which can require a fix and, when that fails, withdrawal from the market.

Each member state sets its own penalties. The directive requires them to be “effective, proportionate and dissuasive”, with remedial action alongside. It also requires a way for consumers, and bodies acting for them, to take action before the courts or the competent authorities. The amounts and the authorities differ by country, so check the law of each member state where the product is sold.

What a software vendor should do

  1. Check whether the product is on the list. Is it one of the listed products, or does it provide or run a listed consumer service in the EU? A checkout, a banking app or an e-book reader is. An internal tool sold only to businesses usually isn’t.
  2. Check the customers. A customer who runs a covered service has to meet the requirements across that service, including the parts it builds on someone else’s software. Expect that customer to ask how the product meets them.
  3. Aim for WCAG 2.2 Level AA, and measure against EN 301 549. For web and app interfaces, the version cited today asks for WCAG 2.1 Level AA, and version 4.1.1 asks for 2.2 Level AA once it is cited. Cover every screen people use, signed-in screens included, and record what was checked, how and when.
  4. Write it down. Keep the accessibility information a covered service has to publish, and any written reasoning for a disproportionate burden, current. An accessibility conformance report (ACR) in the EU edition of the VPAT® template answers EN 301 549 clause by clause. How to read and write an ACR.
  5. Check the national laws. The member state where a product is sold sets the authority, the penalties and the transition rules.

Questions people ask

When did the European Accessibility Act take effect?

The directive entered into force on 27 June 2019. Its requirements have applied since 28 June 2025, through each member state’s national law.

Does the European Accessibility Act apply to B2B software?

Not on its own. The Act lists services provided to consumers. B2B software falls under it when it is part of a covered consumer service, such as a shop’s checkout or a bank’s app.

Does it apply to companies outside the EU?

The Act applies to products placed on the EU market and services provided to consumers in the EU, wherever the business is based.

Is WCAG 2.1 AA enough?

Aim for WCAG 2.2 Level AA. Today, for web content, 2.1 AA is enough: the version of EN 301 549 cited now builds on WCAG 2.1 Level AA. Version 4.1.1 moves to WCAG 2.2 Level AA, and becomes the reference once it is cited in the Official Journal.

Who is exempt?

Microenterprises that provide services: fewer than 10 people, and no more than EUR 2 million in turnover or balance sheet. Microenterprises that deal in products aren’t exempt.

What are the fines?

Each member state sets its own. The directive requires them to be effective, proportionate and dissuasive, and sets no amounts.

Sources

See it on a product