Introduction
The European Accessibility Act (EAA) sets common accessibility requirements for products and services sold or provided in the EU. Since 28 June 2025, covered products placed on the market and services provided to consumers must meet those requirements — including many websites, apps, e-commerce, banking, telecom and self-service terminals.
This European Accessibility Act guide covers who must comply, which products and services are in scope, which technical standard to use (EN 301 549 / WCAG), how an EAA audit works, and a practical 2026 checklist. Non-EU companies that sell to EU consumers are in scope too.
European Accessibility Act At A Glance
- 28 Jun 2025: Date the EAA started applying to covered products placed on the market and services provided to consumers (Source: Directive (EU) 2019/882, EUR-Lex)
- Annex I: The accessibility requirements economic operators must meet for products and services in scope (Source: EAA Directive text)
- EN 301 549: The ICT accessibility standard used as the practical technical benchmark (V4.1.1 maps to EAA; OJ citation for presumption of conformity is still pending) (Source: ETSI EN 301 549)
- Microenterprises: Service providers that are microenterprises are exempt from the service accessibility obligations in the Directive (Source: EAA Article 4 / definitions)
Choose Your Next Step
New to the EAA or still checking scope? Start free. Already know you are in scope? Jump to a manual EU audit. Already have findings or EN 301 549 questions for your developer? Book the technical hour.
Scan One Page First (Free tool)
Best for: a quick first look before you scope a full EAA audit
Run a free one-page check on AccessibilityScore.in (powered by axe-core). It is a starting point that complements a manual EN 301 549 audit; automated tools miss many keyboard and screen reader barriers.
Run a free accessibility scan (opens in a new tab)
EU Accessibility Compliance Audit
Best for: teams that know the EAA applies and need Annex V evidence
Manual testing of your key consumer journeys against EN 301 549 and WCAG 2.2 AA, with a fix-ready report you can use for remediation and your accessibility information.
Free 30-Minute Call
Best for: first conversations, scoping and quotes
Talk through whether the EAA applies to your product or service, what to audit first and what it will cost. No technical prep needed.
Book a free 30-minute call (opens in a new tab)
One-Hour Technical Consultation ($100)
Best for: teams that need technical answers now
Walk through audit findings, talk with a developer about EN 301 549 gaps, or review a live journey on screen.
What’s Inside This European Accessibility Act Guide
- What the EAA is, when it took effect, and who must comply
- The products and services it covers
- EN 301 549 and WCAG 2.1 AA, and where version 4.1.1 fits
- Common issues, a four-step compliance process, and a checklist
- How an EAA audit works, and what the Annex V accessibility information (often called an EAA accessibility statement) must contain
- The EAA requirements in Annex I, and what non-EU companies have to do
- How European Accessibility Act testing works, what compliance software can and cannot do, and how to choose an EAA compliance company
If you already know you are in scope and need a step-by-step action plan, our EAA compliance playbook goes deeper on enforcement, accessibility statements and deadlines.
What Is the European Accessibility Act?
The European Accessibility Act (Directive (EU) 2019/882) was created to harmonize accessibility requirements across all EU member states. Prior to the EAA, accessibility regulations varied significantly between countries, creating challenges for businesses operating across Europe. The European Commission’s EAA overview summarises what the directive covers.
The primary objectives of the EAA are to:
- Improve access to products and services for people with disabilities.
- Create consistent accessibility requirements throughout the EU.
- Remove barriers to trade caused by differing national regulations.
- Encourage inclusive design and innovation.
When Did the EAA Take Effect?
The EAA became enforceable on 28 June 2025. From this date forward, covered products and services placed on the EU market must comply with accessibility requirements.
Strictly, the Directive applies to products placed on the market and services provided to consumers after 28 June 2025. Article 32 adds narrow transitional rules: service contracts agreed before that date can continue unchanged until they expire, but for no longer than five years (to 28 June 2030); products a service provider was already lawfully using can keep being used for similar services until 28 June 2030; and Member States may let self-service terminals already in use stay in service until the end of their economically useful life, up to 20 years. None of these rules delays the requirements for a website or app you are building or changing today.
Who Must Comply?
The EAA applies to organizations that provide covered products or services to consumers within the European Union.
Importantly, the law is not limited to European companies.
Examples of Organizations That May Need to Comply
- E-commerce businesses selling to EU customers
- Banks, payment and e-money providers serving consumers
- Telecom and messaging providers (electronic communications services)
- E-book publishers
- Airlines, rail, bus and ferry operators (websites, apps, e-tickets and travel information)
- Streaming and TV platforms that give access to audiovisual media services
- Manufacturers, importers and distributors of covered products, such as computers, smartphones, e-readers and payment terminals
- Any website or app used to deliver one of these services, whoever built it
A company based in India, the United States, Canada, or Australia may still fall under EAA requirements if its products or services are available to EU consumers: the Directive defines a service provider as anyone who provides a service on the EU market or offers it to consumers in the Union.
Two limits matter. First, the EAA covers specific consumer products and services, not every website. A B2B SaaS company is usually not directly in scope, but it is often pulled in because banks, shops and travel companies that are in scope write EAA requirements into their supplier contracts. Second, microenterprises providing services (fewer than 10 people and annual turnover or balance sheet total of no more than €2 million) are exempt from the service requirements under Article 4(5). The exemption does not cover businesses that make or sell covered products.
EAA Compliance for Non-EU Companies (US, UK, India and Australia)
Being based outside the EU does not take you out of scope. If EU consumers can buy from your online store, open an account with your bank or fintech app, book travel through your site or stream your content, the EAA treats you as a service provider for those services. What changes is who checks, not whether the rules apply: the authorities in each Member State where you serve consumers can ask how your service meets the accessibility requirements, and the national law of that country sets the penalties.
If you sell covered products, the chain of responsibility matters too. Article 9 makes the EU importer check that the manufacturer has carried out the conformity assessment in Annex IV, drawn up the technical documentation and applied the CE marking before the product goes on sale, and Article 8 lets a non-EU manufacturer appoint an authorised representative in writing to hold the EU declaration of conformity and deal with market surveillance authorities.
In practice, a non-EU company should do four things:
- List the EU countries you sell to and the services each one receives, then check the national law that transposes the EAA there (our EAA compliance playbook compares country fines and enforcement).
- Test the journeys EU customers use against EN 301 549 and WCAG 2.1 AA, including localised versions of the site and app.
- Publish your Annex V accessibility information in the languages you sell in, and make sure support staff can answer accessibility questions.
- Line the work up with the rules you already face at home, so one audit covers both: the ADA in the United States (see our ADA and Section 508 audit), the Equality Act 2010 in the UK (see our UK accessibility audit) and the RPwD Act in India (see our India accessibility audit).
UK businesses often ask whether Brexit changes this. The EAA was adopted in 2019 but its transposition deadline came after the UK left the EU, so it was never made part of UK law and does not govern sales within Great Britain. A UK retailer, bank or app that serves consumers in the EU still has to meet it for those customers.
Products and Services Covered by the EAA
The EAA applies to the products and services listed in Article 2 of Directive (EU) 2019/882.
Products
- Computers and operating systems
- Smartphones and tablets
- Payment terminals
- ATMs
- Ticketing and check-in machines
- Self-service kiosks
- Interactive information terminals
- Smart TVs and other consumer equipment used to access audiovisual media services
- E-readers
Services
- E-commerce services (selling to consumers at a distance through websites and apps)
- Consumer banking services (payments, payment accounts, consumer credit, e-money and some investment services)
- Electronic communications services
- Websites and mobile apps used to provide any of these services
- Air, bus, rail and waterborne passenger transport (websites, apps, electronic tickets and real-time travel information)
- E-book services
- Services that give access to audiovisual media, such as streaming apps and electronic programme guides
- Answering emergency calls to the single European emergency number 112
For digital businesses, websites and mobile applications are among the most common areas requiring remediation and ongoing compliance efforts.
Three sectors feel this most. Banks have to make online banking, card payments and customer communications accessible (see banking and finance accessibility). Online shops have to make product pages, filters and checkout usable with a keyboard and screen reader (see ecommerce accessibility). And software companies that power those services often find EAA requirements written into their customers’ contracts (see SaaS accessibility).
EAA Requirements: What Annex I Asks of Websites, Apps and Services
The legal requirements sit in Annex I of Directive (EU) 2019/882. They are written as functional outcomes rather than code rules, which is why EN 301 549 and WCAG are used to test them. For every covered service, Section III of Annex I requires you to:
- Make any products you use to deliver the service accessible, such as a payment terminal or ticket machine.
- Give information about how the service works, and about the accessibility features of any products it relies on, through more than one sensory channel, in an understandable way, in text formats that assistive technology can convert, with adequate font size, contrast and adjustable spacing, and with alternatives for non-text content.
- Make websites, related online applications and mobile apps accessible “in a consistent and adequate way by making them perceivable, operable, understandable and robust”, the same four principles WCAG is built on.
- Where you offer help desks, call centres, technical support or training, make sure they can explain the accessibility of the service and its compatibility with assistive technologies, in accessible ways of communicating.
Extra EAA Requirements for Specific Services
Section IV adds sector rules on top of the general ones:
- E-commerce: show the accessibility information about the products you sell when the responsible economic operator provides it, and make identification, security and payment functions perceivable, operable, understandable and robust (see ecommerce accessibility services).
- Consumer banking: make identification methods, electronic signatures, security and payment services accessible, and keep information understandable without going above level B2 (upper intermediate) of the Council of Europe’s Common European Framework of Reference for Languages, which makes plain language a legal requirement for banks (see banking and finance accessibility).
- Passenger transport (air, bus, rail, waterborne): give accessible information about vehicles, stations and assistance, smart ticketing, real-time travel information and service disruptions.
- E-books: synchronise text and audio, do not block assistive technology, provide accessibility metadata, and make sure digital rights management does not block accessibility features.
- Audiovisual media services: make electronic programme guides accessible and pass subtitles, audio description, spoken subtitles and sign language through in sync and at adequate quality.
- Electronic communications: provide real time text alongside voice, and total conversation (voice, text and video) where video is offered, including for emergency calls.
Product Requirements and Functional Performance Criteria
Products such as computers, smartphones, e-readers, ATMs and self-service terminals must meet Sections I and II: information and instructions through more than one sensory channel, alternatives to vision, hearing, speech, colour and fine motor control, no seizure triggers, an alternative to biometric identification, and interfaces that work with assistive technology. Section VII adds functional performance criteria (use without vision, with limited vision, without hearing, with limited reach or strength, with limited cognition and so on) that apply when no specific requirement covers a function. Manufacturers prove conformity with technical documentation, an EU declaration of conformity and the CE marking.
Not sure which of these requirements apply to your business? A free accessibility needs assessment maps your services against Annex I, and our EU accessibility compliance audit tests them.
The Technical Standard Behind EAA Compliance
One of the most common questions organizations ask is:
“What accessibility standard should we follow?”
The answer is EN 301 549.
EN 301 549 is the European accessibility standard for Information and Communication Technology (ICT). It provides the technical requirements organizations use to demonstrate accessibility compliance under the EAA.
For websites and mobile applications, EN 301 549 incorporates WCAG 2.1 Level AA requirements.
A note on versions. As of October 2026, no harmonised standard has yet been cited in the Official Journal under the EAA itself, so no standard gives a formal presumption of conformity with the Act yet. In practice, EN 301 549 v3.2.1 (the version cited under the EU Web Accessibility Directive, built on WCAG 2.1 Level AA) is the reference most organisations and regulators use. Version 4.1.1 was published in September 2026. It moves the web requirements to WCAG 2.2 and adds an annex mapping its clauses to the EAA. Once the European Commission cites it in the Official Journal, meeting it will give a presumption of conformity with both the EAA and the Web Accessibility Directive. Ireland’s National Disability Authority currently expects that citation on 16 December 2026, but the date is not confirmed. Because v4.1.1 is coming, WCAG 2.2 AA is a sensible target for new work today. Our EN 301 549 v4.1.1 guide lists the six new criteria to fix first, and W3C’s WCAG overview explains how the versions relate.
In practice:
| Requirement | Standard |
|---|---|
| Website Accessibility | WCAG 2.1 AA (WCAG 2.2 AA in EN 301 549 v4.1.1) |
| Mobile App Accessibility | WCAG 2.1 AA (WCAG 2.2 AA in EN 301 549 v4.1.1) |
| Documents (PDFs, Office Files) | EN 301 549 |
| Software Applications | EN 301 549 |
| Hardware & Terminals | EN 301 549 |
Understanding WCAG 2.1 AA
WCAG (Web Content Accessibility Guidelines) is built around four core principles known as POUR:
1. Perceivable
Users must be able to perceive information regardless of disability.
Examples:
- Alternative text for images
- Captions for videos
- Transcripts for audio
- Adequate color contrast
- Content that remains usable when zoomed to 200%
2. Operable
Users must be able to interact with all functionality.
Examples:
- Full keyboard accessibility
- Visible focus indicators
- Skip navigation links
- No keyboard traps
- Accessible menus and controls
3. Understandable
Users should easily understand content and interactions.
Examples:
- Clear error messages
- Consistent navigation
- Predictable interfaces
- Plain language content where appropriate
4. Robust
Content must work with assistive technologies.
Examples:
- Semantic HTML
- Proper ARIA implementation
- Screen reader compatibility
- Accessible forms and controls
Common Accessibility Issues That Cause Non-Compliance
Organizations frequently encounter the following issues during accessibility audits:
Content Issues
- Missing image alt text
- Poor heading structure
- Inaccessible PDFs
- Missing video captions
Design Issues
- Low color contrast
- Text that cannot be resized
- Reliance on color alone for meaning
Development Issues
- Missing form labels
- Incorrect ARIA usage
- Keyboard navigation failures
- Screen reader incompatibility
- Focus management problems
E-Commerce Issues
- Inaccessible checkout flows
- Unlabeled payment forms
- Dynamic content not announced to assistive technologies
- Product filters inaccessible via keyboard
These issues are commonly identified during automated and manual WCAG audits.
EAA Audit: How to Check Your Website for EAA Compliance
An EAA audit tests your website or app against the accessibility requirements in Annex I of the Directive, using EN 301 549 and WCAG 2.1 AA as the test baseline (and WCAG 2.2 AA if you want to be ready for v4.1.1). Automated scanners only catch part of the problem, so a credible European Accessibility Act audit always includes manual testing. A typical EAA compliance audit covers:
- Scope check. Confirm which of your services or products are covered by Article 2, which EU markets you serve, and whether the microenterprise exemption applies.
- Journey selection. Pick the templates and flows a consumer must complete: sign-up, login, search, product pages, checkout or payment, booking, account settings and support.
- Automated scan. Run tools across the site to find repeatable code issues quickly (see automated accessibility testing).
- Manual testing. Test every journey with a keyboard and with screen readers such as NVDA, JAWS and VoiceOver, plus zoom, reflow and colour contrast checks (see screen reader accessibility testing).
- Documents and media. Check the PDFs, forms, videos and e-tickets the service relies on.
- Report and roadmap. Map each issue to WCAG and EN 301 549, rank it by severity, and turn it into a remediation plan with owners and dates.
- Re-test and document. Re-test the fixes and use the results to write your Annex V accessibility information.
Want to see what you get? Look at our sample accessibility audit report. A $500 Quick Accessibility Audit covers up to 5 templates with a prioritised top-10 issues report, which suits smaller sites and first checks. Our EU accessibility compliance audit is the full EAA audit, and the $2,000 Complete Audit on our pricing page covers up to 25 templates or flows with a full manual audit, a re-test of fixed issues and an accessibility statement draft.
European Accessibility Act Testing: What Manual Testing Adds
Good European Accessibility Act testing follows a recognised method rather than a quick scan. W3C’s WCAG-EM evaluation methodology is a useful model: define the scope, explore the site, pick a representative sample of pages and complete processes, test the sample, then report. For the EAA, the sample should include every step of the consumer journeys covered by Article 2, the same journeys in each language version, the mobile app on iOS and Android, and the documents customers download, such as contracts, statements and e-tickets. Each journey is tested with a keyboard only, with NVDA and JAWS on Windows, VoiceOver on macOS and iOS and TalkBack on Android, at 200% zoom and 400% reflow, and with colour contrast and motion checks.
EAA Compliance Software: What It Can and Cannot Do
Automated accessibility software is worth running on every release because it finds repeatable code errors quickly. It cannot make a website EAA compliant on its own. When the UK Government Digital Service tested 10 automated tools on a page with 143 known accessibility barriers, 29% of the barriers were missed by every tool, and the best performer found only 41% even when its manual-check prompts were counted. Tools cannot judge whether alt text is meaningful, whether a checkout error is announced at the right moment, or whether a screen reader user can finish a payment. Overlay widgets that promise instant compliance do not change that: in the US, EcomBack counted 496 of the 2,045 ADA website lawsuits filed in the first half of 2026 against sites that already had one installed (see accessibility overlays and lawsuits). Use software for regression checks and ongoing accessibility monitoring, and pair it with manual testing for the audit itself. For a free first look, our AccessibilityScore.in scanner checks one public page with axe-core and shows each issue with its severity and WCAG mapping. Treat it as a starting point that complements a manual EAA audit, not a replacement for one.
How to Achieve EAA Compliance: A 2026 Roadmap
Step 1: Conduct an Accessibility Audit
Begin with a comprehensive accessibility assessment that includes:
- Automated testing
- Manual keyboard testing
- Screen reader testing
- Mobile accessibility testing
- Document accessibility testing
Automated tools alone cannot identify all accessibility barriers. Manual evaluation remains essential.
Step 2: Prioritize Remediation
Focus first on issues that prevent users from completing critical tasks such as:
- Account creation
- Login
- Purchases
- Form submission
- Customer support access
Addressing high-impact barriers provides immediate improvements for users.
Step 3: Train Internal Teams
Accessibility should not be limited to a one-time project.
Organizations should train:
- Designers
- Developers
- QA teams
- Content authors
- Product managers
Accessibility becomes sustainable only when embedded into daily workflows.
Step 4: Implement Continuous Monitoring
Accessibility is an ongoing process.
Organizations should establish:
- Regular audits
- Accessibility testing during releases
- Accessibility acceptance criteria
- User feedback mechanisms
- Accessibility governance policies
Continuous monitoring helps prevent regressions and supports long-term compliance.
EAA Accessibility Statement: What Annex V Requires
The EAA does not use the term “accessibility statement” the way the Web Accessibility Directive does for public bodies, but it does require something very similar from service providers. Under Article 13(2), you must prepare information in line with Annex V explaining how your service meets the accessibility requirements, make it public in written and oral format in a way that is accessible to persons with disabilities, and keep it for as long as the service is in operation. Annex V says it can go in your general terms and conditions or an equivalent document, and it should include:
- A general description of the service in accessible formats
- The descriptions and explanations needed to understand how the service works
- A description of how the service meets the relevant accessibility requirements in Annex I
Most companies publish this as an accessibility statement page linked from the footer and reference it from their terms. If an audit shows that part of the service does not yet comply, Article 13(4) requires you to take corrective measures and to inform the competent national authorities in the Member States where you provide the service.
What to Put in Your EAA Accessibility Statement
Annex V sets the minimum. A statement that regulators and customers can actually use usually covers:
- Which service, website and apps the statement applies to, and the date it was last reviewed
- The standard you test against (EN 301 549 v3.2.1 and WCAG 2.1 AA today, with WCAG 2.2 AA as your target) and how you tested: who tested, which journeys and which assistive technologies
- How the service meets the Annex I requirements, in plain language
- Known gaps, the reason for each, the date you expect to fix it and an accessible alternative in the meantime
- Any disproportionate burden assessment you rely on, and for which requirement
- How customers can report a barrier or ask for information in another format, with a named contact and response time
Our $2,000 Complete Audit includes an accessibility statement draft based on the audit findings; see audit pricing.
Fundamental Alteration and Disproportionate Burden
Article 14 lets an economic operator skip a specific requirement only if meeting it would fundamentally alter the service or product, or impose a disproportionate burden under the criteria in Annex VI. You must document the assessment, keep the results for five years, give a copy to the authorities on request, and tell the relevant authorities you are relying on it (microenterprises are exempt from that notification). Service providers must renew the assessment when the service changes, when the authorities ask, and in any case at least every five years. You cannot claim disproportionate burden if you receive outside funding to improve accessibility.
What Happens If You Ignore the EAA?
Enforcement is managed by individual EU member states, and penalties can vary. Article 30 requires every Member State to set penalties that are “effective, proportionate and dissuasive”, backed by remedial action, and scaled to how serious the non-compliance is and how many people it affects. The actual amounts are set in each country’s national law, so a company that sells across Europe faces several regimes at once; our EAA compliance playbook compares the fines and enforcement approach country by country.
Potential consequences may include:
- Regulatory fines
- Market access restrictions
- Customer complaints
- Legal disputes
- Reputational damage
Beyond legal risk, inaccessible products exclude millions of potential users and customers.
Business Benefits of EAA Compliance
Many organizations view accessibility solely as a compliance requirement. In reality, accessibility often delivers measurable business benefits.
Increased Market Reach
According to the Council of the EU, Eurostat estimates that 24% of people aged 16 and over in the EU, about 90 million people or one in four adults, had some form of disability in 2024. Accessible products reach that whole audience, along with older customers.
Better User Experience
Accessibility improvements often benefit all users, including those using mobile devices, older users, and users with temporary impairments.
Improved SEO
Many accessibility practices align with search engine optimization best practices, including semantic HTML, heading structure, and alternative text.
Reduced Legal Risk
Proactive compliance significantly lowers regulatory and litigation exposure.
Stronger Brand Reputation
Organizations that prioritize inclusion often build greater trust and customer loyalty.
EAA Compliance Checklist (2026)
Before you launch or keep offering a covered website, app or digital service in the EU market, work through this checklist. Treat it as a planning list, not a certificate — only a manual audit against Annex I / EN 301 549 can confirm conformance.
| Check | What to verify |
|---|---|
| Scope | Confirm which of your products or services are in scope, and whether the microenterprise exemption applies |
| Images & media | Meaningful alternative text; captions on video; transcripts for audio-only content |
| Colour & zoom | Contrast meets WCAG; content reflows and stays usable at 200%–400% zoom |
| Keyboard | All functionality works with a keyboard alone; visible focus; no keyboard traps |
| Forms | Visible labels, clear errors and accessible instructions |
| Assistive tech | Screen readers can navigate landmarks, headings, links and controls correctly |
| Documents | PDFs and downloads are tagged and usable (our PDF document remediation service can fix existing files) |
| Mobile | Apps support VoiceOver, TalkBack and system accessibility settings |
| Journeys | Sign-up, login, search, checkout or payment, booking and support tested by hand against EN 301 549 and WCAG 2.1 AA (target WCAG 2.2 AA for new work) |
| Annex V info | Accessibility information published in an accessible format and referenced from your terms |
| Support | Customer support can explain accessibility of the service and assistive-tech compatibility |
| Governance | Accessibility testing is part of release cycles, with ongoing monitoring after launch |
Need help turning this checklist into evidence? Start with a $500 Quick Audit (up to 5 templates) or a full EU accessibility compliance audit. Not sure you are in scope? Book a free 30-minute call first.
