E-commerce services
Any consumer-facing online shop, marketplace, SaaS with consumer signup, subscription service. Includes mobile shopping apps.
EAA
European Union · Private sector
What is the European Accessibility Act?
Directive 2019/882, in force across the EU since 28 June 2025, harmonises accessibility requirements for major private-sector digital products and services — from e-commerce and banking to e-books and transport ticketing.
Directive
2019/882
In force
28 June 2025
Technical target
EN 301 549 · WCAG 2.1 AA
Scope
27 EU member states
The European Accessibility Act (EAA) is Directive 2019/882 of the European Parliament and of the Council. It was adopted in April 2019 and national transposition laws took effect across all 27 EU member states on 28 June 2025.
Unlike the Web Accessibility Directive (2016/2102) — which only applies to the public sector — the EAA extends accessibility obligations to private-sector companies selling specific products and services to EU consumers. This is the biggest expansion of digital-accessibility law in European history.
The technical reference is EN 301 549, the harmonised European standard that wraps WCAG 2.1 Level AA for web content and adds requirements for mobile apps, hardware, self-service terminals and non-web documents. Conformance to EN 301 549 is a presumption of conformance to the EAA.
The EAA does not replace existing laws — it layers on top. A retailer selling into Germany and France must comply with the EAA and with each country’s national transposition, enforcement body and penalty regime.
Scope
Products and services covered
The EAA applies to specific product and service categories, not “all websites.” But the list is broad enough that most consumer-facing digital businesses fall within it.
Consumer banking
Retail banking websites and apps, online account opening, payment services, consumer credit products.
E-books and reading software
E-book files, e-reader apps and dedicated e-reader devices. Publishers must ship reflowable, navigable, screen-reader-compatible EPUBs.
Telecom services
Consumer telecoms, messaging, voice-over-IP, SMS and emergency communications. Includes mobile and fixed-line providers.
Transport ticketing
Air, bus, rail, maritime passenger-transport websites, apps, electronic tickets, check-in and boarding interfaces, real-time travel info.
Self-service terminals
ATMs, ticket machines, check-in kiosks, payment terminals. Hardware + software combined. New terminals placed on market after 28 June 2025 must comply.
Computing hardware + OS
Consumer computing hardware (laptops, tablets, smartphones) and bundled operating systems. Covers built-in accessibility features.
Audiovisual media services
Smart TVs, streaming apps, EPG interfaces. Captioning, audio description and navigational accessibility are required.
Emergency communications (112)
Answering of emergency communications to 112 must support real-time text and synchronised voice and video for Deaf users.
Microenterprise exemption. Businesses with fewer than 10 employees and either annual turnover or balance sheet under €2 million may be exempt from the service provisions (not the product provisions). But they must still document their reasoning and notify national authorities on request.
Non-EU sellers are caught. If you sell products or services to EU consumers, you’re in scope regardless of where you’re incorporated. Non-EU manufacturers need an authorised representative in the Union.
Key requirements
What the EAA actually requires
The EAA itself is functional (“services must be accessible”). The operational detail lives in EN 301 549, which mandates WCAG 2.1 AA for web and adds non-web requirements.
WCAG 2.1 Level AA for all web content
50 success criteria for websites and web apps. EN 301 549 incorporates WCAG 2.1 AA by reference in clauses 9 (web) and 11 (software).
Accessible mobile apps
Native apps must meet EN 301 549 clause 11 — screen-reader, keyboard navigation, contrast, target size, orientation support.
Accessible PDFs (PDF/UA-1)
Any PDF supplied through a covered service must meet EN 301 549 clause 10 / PDF/UA-1 / ISO 14289-1. Tagged structure, reading order, alt text, language.
Accessibility statement (public)
Services must publish a machine-readable accessibility statement: standards applied, limitations, known issues, feedback mechanism, enforcement contact.
Information about accessibility
At the point of sale or signup you must explain how the product or service meets accessibility needs — in formats accessible to disabled consumers.
Support interoperability with AT
Compatibility with assistive technologies (screen readers, magnifiers, alternative input devices, braille displays, switch controls).
EU Declaration of Conformity
Manufacturers of products in scope must issue an EU Declaration of Conformity and (for certain products) affix CE marking after accessibility assessment.
Documented accessibility assessment
Maintain technical documentation demonstrating how conformance is achieved. National authorities can request it on inspection. Retain for 5 years.
Complaint handling
Services must provide a mechanism for consumers to report accessibility problems, with a national enforcement body to escalate to if unresolved.
Training and awareness
Staff handling access and support queries must be trained in accessibility. Not directly enforceable but weighted in disproportionate-burden assessments.
Penalties by country
What non-compliance costs across the EU
The EAA requires every member state to set “effective, proportionate and dissuasive” penalties. National transposition laws diverge significantly — these are the largest markets.
€100k
Up to €100,000 per violation under the BFSG (Barrierefreiheitsstärkungsgesetz). Enforcement by Marktbewachungsbehörden (market-surveillance bodies).
€60k
Up to €60,000 per summary conviction, unlimited on indictment. Enforcement by the Competition and Consumer Protection Commission (CCPC).
5% turnover
Up to 5 % of prior-year turnover. Enforcement by AgID (Agenzia per l’Italia Digitale).
€50k
Up to €50,000 per product/service per breach, renewable every 6 months. Enforcement by DGCCRF (consumer-protection authority).
€1M
Up to €1,000,000 for very serious breaches under Law 11/2023. Tiered system based on severity, scale and recidivism.
€900k
Up to €900,000 (category 6 of the Dutch Criminal Code) per violation. Enforcement by the Authority for Consumers and Markets (ACM).
Product-withdrawal powers. Beyond fines, national authorities can order products to be withdrawn or recalled from the market — a material commercial risk for hardware and e-book sellers.
Class-action exposure. In several member states (France, Italy, Portugal, Spain), consumer associations can bring collective actions for accessibility breaches. Combined with GDPR-style enforcement culture, this is where real financial risk lives.
Deadlines
Key EAA deadlines
The EAA is already in force. Derogation windows exist for certain pre-existing services and products — but they’re closing fast.
17 April 2019
Directive 2019/882 adopted
European Parliament and Council adopt the EAA. Member states given 3 years to transpose into national law and 6 years to apply.
28 June 2022
National transposition deadline
Member states’ deadline to publish national laws implementing the EAA. Most met it; some (IT, IE, ES) published later.
28 June 2025
EAA applies across the EU
All new products placed on the EU market and services supplied to consumers must meet accessibility requirements. Enforcement begins across all 27 member states.
28 June 2030
End of service-contract derogation
Existing service contracts concluded before 28 June 2025 may continue unchanged until this date — after which they must meet EAA requirements.
28 June 2045
End of self-service-terminal derogation
Self-service terminals lawfully placed on the market before 28 June 2025 may continue in use up to this date. New terminals must comply immediately.
How to comply
Your EAA compliance checklist
Compliance is about evidence, not just conformance. You need to demonstrate a process, a technical standard target, and a response mechanism.
Confirm you’re in scope for one of the nine product/service categories
If yes — and you’re not a microenterprise providing services only — you are subject to the EAA from 28 June 2025.
Audit website and app against EN 301 549 / WCAG 2.1 AA
Automated scan + manual testing. Include screen-reader, keyboard, zoom, contrast, captions, form error handling.
Audit PDFs against PDF/UA-1 / ISO 14289-1
Every consumer-facing PDF must be tagged, reading-order correct, alt text on images, table headers, language set, title metadata.
Publish an accessibility statement on every public digital service
Standards applied, date of last assessment, known limitations, feedback contact, enforcement-authority contact. Machine-readable format recommended.
Maintain technical documentation for 5 years
Conformance assessment reports, test evidence, remediation logs. National surveillance authorities can demand this without warning.
For products: issue EU Declaration of Conformity
Manufacturers of hardware (self-service terminals, e-readers, consumer computing) must issue a formal DoC and, where required, affix CE marking.
Appoint an EU authorised representative (if non-EU)
Non-EU manufacturers and importers need a named EU-based authorised representative with documented responsibility for EAA compliance.
Operate a complaints + feedback mechanism
Accessible channel for consumers to report issues, with an escalation path to the national enforcement body cited in the statement.
Next step
Audit your site + PDFs against EN 301 549
Our checkers test against WCAG 2.1/2.2 AA (web), PDF/UA-1 (PDFs) and the full Matterhorn Protocol. Every failure maps to the specific EAA clause and the specific EN 301 549 requirement.