With the first European Accessibility Act (EAA) deadline approaching on June 28, 2025, many organizations are seeking clarity on how to meet the requirements. During two recent webinars, TPGi teamed up with various experts to discuss the law and how it impacts businesses that offer digital services and devices, like self-service kiosks, in the European Union.
To start, our Chief Accessibility Officer David Sloan joined with an attorney from the international law firm Bird & Bird for the first webinar, “6 months to the European Accessibility Act Deadline – What Do You Need to Do?”
Then, he joined Roxana Fischer, Vispero’s Product Manager, and Matthijs Verhagen, European Sales Manager at Storm Interface, for the webinar “Countdown to Compliance: The European Accessibility Act and Self-Service Kiosks 101.”
Both webinars resulted in great conversations, but businesses are still trying to make sense of many questions. Here’s a summary of those questions and our answers to help you better understand and prepare.
This article provides information about accessibility laws and regulations but is not legal advice. You should consult a lawyer for advice on specific legal issues or problems.
Important EAA Deadlines
When does a website need to meet the EAA requirements? Is the deadline June 28, 2025, or June 28, 2030?
Answer: Websites providing consumer services covered by the EAA must meet requirements by June 28, 2025. The 2030 deadline applies to certain products (devices), not websites.
What’s Covered Under the EAA
How can I determine if my website is affected by the EAA?
Answer: The EAA applies to websites providing the following services to consumers in the European Union:
- E-commerce services
- Consumer banking
- Audiovisual media services
- Public transportation information
- Access to e-books
- Electronic communication services
Most website content and functionality is covered by EAA’s requirements. Exceptions include certain online map content, archived content, third-party content that wasn’t funded by or under the control of the service provider, and digital documents and media that was published before June 28, 2025.
Review EAA technical requirements in each Member States where you operate. If unsure, seek legal advice.
Does the EAA apply only to government organizations, or does it include businesses providing products for computers or mobile devices?
Answer: The EAA applies to any organization providing products or services to consumers in the EU. This includes government entities, whose websites are already subject to the requirements of the EU’s Public Sector Web Accessibility Directive.
If we’re already compliant with the UK’s Equality Act or the U.S. ADA, does that mean we’re compliant with the EAA?
Answer: Not necessarily. While the Equality Act and ADA are both civil rights laws that have protections for people with disabilities in the UK and the US respectively, the EAA has specific requirements for product manufacturers and service providers. Compliance with UK or U.S. disability rights laws does not guarantee compliance with the EAA.
If we provide B2B banking services, does the EAA apply to us?
Answer: The EAA applies to consumer-facing services. Business-to business (B2B) services are not directly in scope. However, if customers use your technology to provide covered consumer banking services, ensuring your solution meets EAA requirements may help support their obligations.
If a website primarily sells nondigital products like ladders, tools, or furniture, does the EAA apply?
Answer: Yes, an eCommerce website that sells products or services to consumers in the EU must meet EAA’s accessibility requirements regardless of what kind of products or services it sells. In addition, the EAA requires ecommerce websites to provide accessibility information for each product or service sold, where this information is known.
What does the EAA’s ‘disproportionate burden’ clause mean?
Answer: The “disproportionate burden” clause provides an exception to meeting EAA requirements, where doing so would cause an organization excess financial or administrative burden.
The exemption is narrowly defined and requires evidence, so shouldn’t be considered an easy way to opt out of meeting requirements. The EAA specifies criteria for assessing disproportionate burden in Annex VI. Organizations must carefully assess and document the rationale for claiming this exemption, as incorrect determinations could lead to legal consequences.
For services provided through products that do not need to meet requirements by the June 28, 2025, deadline, do you need to offer an alternative, accessible way for customers with disabilities to access that service?
Answer: The EAA has been introduced to supplement existing disability rights laws across the European Union by providing more details on what’s required to provide accessible products and technology-aided services.
This means that organizations will still need to ensure they meet all existing applicable laws that protect disabled people from discrimination based on disability. So, for as long as the kiosk or other product used to provide the service does not meet EAA’s requirements, you need to support people with disabilities in another way.
You should seek legal advice to ensure that the approach you take provides an equivalent alternative for disabled people affected by the accessibility barriers present in the product.
What You Need to Do to Comply
What does my organization need to do to prepare for the EAA deadline on June 28, 2025?
Answer: To prepare for the deadline, we recommend organizations:</p?
- Inventory digital services and products to identify which are covered by the EAA’s requirements.
- In a prioritized manner, review each covered service and product for level of compliance with EAA’s requirements to identify the nature and extent of areas of non-compliance. This can be done through a review of technical accessibility standards; you can also find out issues through gathering feedback directly from people with disabilities.
- In a prioritized manner, take action to address the barriers identified, considering factors such as effort to fix and severity in terms of impact on users’ ability to use the product or service for its intended purpose.
- Document progress in addressing issues so that you have a record of how well each resource meets EAA requirements.
In parallel, it’s important to implement a strategy for embedding accessibility in processes and practices, including staff training, gathering feedback from people with disabilities, investing in using tools to support accessibility efforts, and starting a conversation with your technology suppliers about their accessibility efforts.
What role does WCAG (Web Content Accessibility Guidelines) play in the EN 301 549 standard?
Answer: First, it’s important to clarify how the EN 301 549 standard relates to EAA. EN 301 549 is a voluntary accessibility standard for websites, software, hardware, and documents, and was developed to support implementation of the EU’s public sector Web Accessibility Directive.
The latest version of EN 301 549 is v 3.2.1, and it’s currently in the process of being updated to align with EAA’s requirements. Once the new version is published, expected to be early 2026, it will be considered an official supporting standard of EAA (in EU terms, a “harmonized standard”).
While meeting the updated EN 301 549 standard is still voluntary, evidence of doing so will indicate that a product or service conforms to EAA’s accessibility requirements.
The current version of EN 301 549 incorporates WCAG 2.1 “by reference” into its requirements:
- Web content must satisfy WCAG 2.1 Level A and AA success criteria.
- EN 301 549’s requirements for non-web documents and software applications also directly reference applicable WCAG 2.1 Level A and Level AA success criteria and additional guidance. Meeting these criteria helps ensure software and documents meet EN 301 549’s requirements.
We expect the next version of EN 301 549 will be updated to reference WCAG 2.2 instead of WCAG 2.1.
Is there an end goal for accessibility and if so, how long does it take to achieve?
Answer: Accessibility, like security, is an ongoing effort. The EAA requires organizations to meet and maintain accessibility over time, especially as products or services are updated with new functionality and as requirements change. Don’t assume that accessibility is a project with an end date.
While the purpose of EAA is to harmonize accessibility requirements across the EU, there may be national differences on how the EAA is implemented. Organizations should implement a strategy to:
- Understand EAA requirements in each relevant Member State and monitor requirements for any changes over time.
- Embed accessibility into product review and lifecycle processes.
- Manage supply chain relationships to ensure that accessibility responsibility is clearly communicated.
- Document conformance over time, including situations where a product or service is found not to conform with requirements, and what action is taken to address the issues identified.
This approach ensures long-term conformance rather than treating accessibility as a one-off project. Visit our EAA Resource Center to learn about the relevant EU Member State requirements.
Kiosk and Self-Service Terminal EAA Questions
Does the EAA cover kiosks with large interactive screens to buy food?
Answer: Yes. The EAA includes payment terminals in the list of covered products. The visual and physical demands of large and complex touchscreen interfaces, especially when vertically mounted, can make them challenging to navigate and operate for many disabled people.
Providing an alternative input device that is easy to operate physically and supports logical speech-based navigation can help improve accessibility. For example, Vispero has worked with McDonalds in the U.S. to make their large interactive screens accessible to people who are blind or have low vision.
The YouTube video “Accessible Kiosk Walkthrough” shows ways in which a kiosk experience can be made more accessible.
One requirement for self-service terminals is accessibility for visually impaired people. What about self-service terminals in parking lots, for example? Do they also have to be accessible to blind people when the customer of these terminals is a car driver?
Answer: Yes! While a blind person may not be the driver, they should still be able to pay for parking independently, whether as a passenger or when assisting someone else. Don’t assume that someone won’t use a particular product or service just because they have a disability. Accessibility ensures everyone has equal access to self-service terminals, regardless of their role in the journey.
The EAA requirement “avoid modes of operation requiring extensive reach and great strength” feels somewhat vague. How is this measured? Are there guidelines on the height or position of kiosks?
Answer: The current version of EN 301 549 (v 3.2.1) provides detailed requirements for stationary ICT (which would include kiosks and self-service terminals) in Section 8.3. These include specifications for forward and side reach, approach, and operation of mechanical parts (which includes force of operation as well as means of operation). Meeting these requirements should help to demonstrate compliance with EAA.
What must you do to communicate that self-service terminals are accessible and that they can plug in headphones to activate the accessibility features?
Answer: The great thing about the EAA is that it promotes accessibility without setting rigid thresholds, allowing us to aim for universal access across all units. For blind users, consistency is key.
Just as many ATMs already include a headphone jack and accessible kiosks often integrate Storm’s accessible keypads, users will come to expect the same on other self-service terminals.
For effective communication, provide clear tactile markers for controls, input and output devices, support use of personal headphones, and provide instructions in more than one way (such as tactile, onscreen text, and audio) on how to use accessibility features.
Over time, implementing these measures will establish an expectation that self-service terminals are accessible by default rather than viewing accessibility as an exception.
How does one test for physical accessibility requirements, like force needed to operate a button? Is there a device that measures that?
Answer: Instruments like measuring devices and force meters can be used to measure whether the device meets physical accessibility requirements relating to reach and height dimensions, and force of operating physical controls. If you’re working with a third-party kiosk supplier, ask them for evidence that their product meets the EN 301 549 standard.
Testing and Feedback for Long-Term EAA Compliance
Usability testing can be expensive and time-consuming. What advice do you have?
Answer: Usability testing with people with disabilities is essential to verify that products and services are usable in a comparable way to nondisabled people. Ways to streamline the process include:
- Limiting the number of participants and tasks.
- Using remote testing for convenience.
- Building a pool of participants with disabilities to reduce recruitment efforts.
- Working with organizations like TPGi for expert-led usability studies.
It’s also important to actively and consistently look for feedback from people with disabilities through other channels, including customer service and helpdesk, product and service reviews.
Get Ready for the June 28, 2025, EAA Deadline
The European Accessibility Act presents a significant opportunity for organizations to improve accessibility and reach a broader audience. Start planning now to ensure your services and products meet the requirements in time.
Does TPGi offer tools for automated website testing?
Answer: Yes. TPGi’s ARC Platform runs automated scans against WCAG 2.1 and 2.2, providing structured reports with specific WCAG criteria.
TPGi offers tools, resources, and expertise to help you navigate your EAA journey if you need support. Contact TPGi to get a free EAA planning consultation.
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