Understanding the European Accessibility Act (EAA)
Updated 10/24/2024
Origins of the European Accessibility Act (EAA)
Nothing important just springs into being — there is always something from the past that led to its present creation. The European Union (EU)’s Charter of Fundamental Rights from 2000 and the EU’s ratification of the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) in 2011 helped lead to the passage of the European Accessibility Act (EAA).
What is the European Accessibility Act?
The EAA is a law designed to help businesses create equal access for Europeans with disabilities by requiring a mix of consumer products and services to be accessible. Before the EAA, the European Union was a patchwork of different accessibility rules. The EAA’s goal is to sweep that away and replaces it with standardized accessibility requirements, “so the EU’s internal market operates smoothly by eliminating and preventing any free-movement barriers that may exist because of divergent national legislation.”
What Products and Services Does the EAA Apply To?
The EAA applies to specific consumer-oriented products and services provided by private and public sector organizations:
Products:
- Computers and operating systems.
- Payment terminals.
- Certain self-service kiosks such as ATMs, ticketing and check-in machines, and interactive self-service information kiosks.
- Smartphones and other equipment for accessing telecommunication services.
- TV equipment involving digital television services
- E-readers
Services:
- E-commerce
- Consumer banking
- Video streaming and television
- Telephone and online communications
- Passenger transportation via air, bus, rail, and water
- E-books
- Services that receive emergency calls to the single European number ‘112’
Note that what the EAA refers to as “products” specifically means hardware devices. “Services” could mean what are often referred to as digital products like web or mobile applications, which may run on devices also covered by EAA.
Important EAA Deadlines
The EAA required that all 27 countries (“member states”) of the EU pass their own “laws, regulations and administrative provisions necessary to comply with this Directive” by 28 June 2022 (a process sometimes referred to as “transposition”), so each country has already set their own legislation (or should have).
Each country’s implementation of the EAA into their own law must come into force on June 28, 2025. This means that unless otherwise specified, products and services covered by the EAA must meet the Act’s accessibility requirements by that date.
The EAA provides a transitional period, ending on June 28, 2030, for service providers to continue to provide services using a product that was lawfully used before the EAA deadline.
In addition, self-service terminals that are already in use by service providers can continue to be used until the end of their useful life, but no longer than 20 years after they were introduced.
Risks of Not Complying with the European Accessibility Act
The EAA includes requirements for each EU country to enforce the Act by setting up a national organization responsible for monitoring products and services on the market in that country and to act over noncompliant products and services.
Monitoring organizations will require product and services providers to address accessibility issues and, if insufficient action is taken, levy penalties and potentially require withdrawal of non-compliant products or services from the market.
Penalties will be decided by each individual country of the EU. The EAA does offer parameters for penalties, noting that the penalty should be adjusted based on “the extent of the non-compliance, including its seriousness, and the number of units of non-complying products or services concerned, as well as the number of persons affected.”
How Will Meeting the EAA Help Your Business?
- Market capture: There are over 100 million people with a disability in the EU. Meeting EAA requirements ensures your product or service can be used by a greater proportion of your target audience.
- Improve user experience: The strong correlation between accessibility and usability means that efforts to meet the EAA’s accessibility requirements will help you design a product or service that is easier to use successfully by more people.
- Reduce risk: Meeting EAA requirements when building products and services reduces risk that enforcement agencies require you to invest in expensive remediation efforts, remove your product or service from the market, or issue you with a penalty for non-compliance.
- Customer retention: With the EU’s aging population, the number of people with accessibility needs in the EU will continue to increase. This is because the aging process can lead to changes in vision, mobility, hearing, and cognition; changes that can affect the ability to successfully interact with digital resources. It costs more to get a new customer than to retain an existing one, so make sure your customers can continue to use your products over time.
Accessibility Requirements
The accessibility requirements of the EAA focus on functional requirements for people with disabilities. It mandates that products and services “be designed and produced to maximize their use by people with disabilities,” provided these “do not alter their basic nature or impose a disproportionate burden on operators.”
As such, the EAA doesn’t provide or reference detailed technical accessibility requirements, although it does mention the four principles of the Web Content Accessibility Guidelines (WCAG) — perceivable, operable, understandable, and robust.
However, given the close relationship of the EAA to existing European standards, proving that a product or service has been designed to meet the standard EN 301549 will go a long way to ensuring EAA compliance.
The current version of EN 301549 (Europe’s extension to WCAG) has requirements for websites, software applications, hardware and digital documents, and for most situations requires conformance with WCAG version 2.1 Level AA.
At the time of writing, EN 301549 is currently undergoing revision, due for publication in early 2026, and we expect the updated version will reference WCAG 2.2 Level AA conformance.
The EAA Is More Than Meeting Technical Accessibility Requirements
The EAA goes beyond specifying accessibility requirements of the product or service itself. Organizations also need to:
- Document how a product or service meets accessibility requirements and provide this information to the public in an accessible format;
- Have and follow processes to ensure a product or service continues to meet accessibility requirements over time, including when requirements change;
- Provide communication channels that gather feedback on accessibility issues and processes for addressing this feedback in an effective way;
- Fix a product or service when they are found not to meet accessibility requirements, and inform relevant national monitoring agencies when this happens;
- Maintain details of the current level of product or service accessibility and any corrective action taken to meet requirements and provide this information to appropriate authorities whenever requested to do so.
This means that meeting EAA requirements involves establishing processes that ensure products and services meet international technical accessibility standards and are usable by people with disabilities, and that efforts to achieve accessibility are documented in a proper way and made available to consumers and relevant authorities.
How TPGi Can Help Meet Your EAA Compliance Obligations
While the June 2025 deadline approaching, it’s better to be proactive and assess your product or service’s accessibility so that you can create a plan based on your needs and goals.
TPGi’s accessibility experts are ready to collaborate with you and help develop a strategy so you can achieve conformance with the European Accessibility Act. No matter what you end up doing, we recommend familiarizing yourself with relevant digital accessibility standards — WCAG and EN 301549. You can also download our guide to the European Accessibility Act (checklist included) to help you get started.
TPGi is a world leader in digital accessibility and is a consulting partner that provides expertise, accessibility testing tools, and services to support you on your conformance journey. Contact TPGi today to learn more about how we can help your organization’s digital products conform to the European Accessibility Act.
Frequently Asked Questions
The Web Accessibility Directive applies only to public sector organizations. The EAA applies to any organization that provides the products and services covered in the Act, including public and private sector organizations.
The Web Accessibility Directive applies only to websites and apps. The EAA also covers specified hardware products and software applications.
The EAA does not reference a specific technical standard for conformance, though as noted above, meeting EN 301549 should help to show conformance with EAA. The Web Accessibility Directive calls out WCAG 2.1 Level AA.
The EAA applies to all 27 countries in the European Union. International organizations that do business in the EU must also comply with the regulations.
Organizations that employ less than ten people and have an annual turnover of less than two million euros are exempt from the EAA.
Specific products and services could also receive an exemption if an organization can provide evidence that meeting EAA requirements creates an “undue burden” or changes their nature too dramatically (“fundamental alteration”).
Additionally, the EAA includes exemptions for specific types of content such as:
- Pre-recorded time-based media published before June 2025.
- Office file formats published before June 2025.
- Online maps, if essential information is otherwise provided in an accessible way.
- Third party content that is not funded, developed, or under the control of the organization that must be compliant.
- Archive content that won’t be updated after June 2025.
The European Commission (the executive branch of the EU) will set up “a working group of representatives of authorities for market surveillance and services’ compliance and of stakeholders including disability organizations.”
This group is designed for communication and information sharing between different groups. As is the case with many far-reaching laws, the European Commission will create a report every five years on how the law has been implemented and its effect on product and service accessibility.
Installing an accessibility overlay on your website is unlikely to help you meet the requirements under the EAA.
Learn more about accessibility overlays and why they fall short in this.
Yes, the European Accessibility Act covers payment terminals and most interactive self-service terminals, including automated teller machines (ATMs), kiosks that issue tickets, check-in machines, and interactive information screens.
The EAA includes requirements for the accessibility of kiosk hardware and software user interfaces. Covered kiosks and self-service terminals installed in EU member states after the deadline of June 28, 2025, must meet the EAA requirements. However, kiosks already in use that do not meet requirements may continue in service for a maximum of 20 years after this deadline.
Payment terminals have specific deadlines for compliance with the EAA. Like TVs and phones, older models of payment terminals can continue to be distributed after June 28, 2025. However, all newer models released after this date must meet EAA accessibility requirements.
Additionally, certain sectors such as transportation and consumer banking are required to replace any inaccessible payment terminals by June 28, 2030.