European Accessibility Act (EAA) Scope Checker

Check if the European Accessibility Act (EAA) applies to your product or service. Select your product type, service type, company size, and whether you sell in the EU to find out if you are in scope, whether any exemptions apply, what the compliance deadline is, and the key actions you need to take. The EAA has been in effect since 28 June 2025, with enforcement now underway across the EU. France has issued formal notices to non-compliant businesses, and Germany is actively investigating complaints. The Act affects a wide range of digital and physical products and services sold in the European Union.

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What Is the European Accessibility Act?

The European Accessibility Act (EAA), formally known as Directive (EU) 2019/882, is a European Union directive that establishes common accessibility requirements for certain products and services. The directive was adopted in April 2019 and EU member states were required to transpose it into national law by 28 June 2022, with the requirements in effect since 28 June 2025. Enforcement has begun, with member states actively monitoring compliance and issuing penalties. The EAA is the most comprehensive piece of accessibility legislation to affect the European market, establishing harmonised standards that replace the patchwork of different national accessibility requirements that previously existed across EU member states.

The EAA covers a broad range of products including computers and operating systems, smartphones and tablets, self-service terminals such as ATMs, payment terminals, ticketing and check-in machines, and e-book readers. On the services side, it covers electronic communications services, services providing access to audiovisual media, passenger transport services (for air, bus, rail, and waterborne transport), banking services, e-commerce platforms, and e-books and dedicated software. The accessibility requirements are based on the principle that products and services must be perceivable, operable, understandable, and robust for persons with disabilities.

Who Must Comply with the EAA?

The EAA applies to economic operators who place covered products on the EU market or provide covered services to consumers in the EU. This includes manufacturers, importers, distributors, and service providers. Importantly, the EAA applies regardless of where the company is based. A company headquartered outside the EU must still comply if it sells covered products or services to consumers within the EU. This extraterritorial reach means that the EAA affects a very large number of businesses worldwide, similar to how GDPR affected data processing practices globally.

The directive includes a specific exemption for microenterprises providing services. A microenterprise is defined as a company with fewer than 10 employees and annual turnover or balance sheet total not exceeding 2 million euros. Microenterprises that only provide services (not products) are exempt from the EAA requirements. However, microenterprises that manufacture, import, or distribute covered products must still comply. This exemption recognises the disproportionate burden that full compliance would place on very small service providers, while ensuring that products entering the market meet accessibility standards regardless of the manufacturer's size.

Accessibility Requirements Under the EAA

The EAA establishes functional accessibility requirements rather than prescribing specific technical solutions. Products and services must be designed and produced so that they can be used by persons with disabilities, including those with visual, hearing, motor, and cognitive impairments. For digital products and services, this generally means compliance with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, which is the internationally recognised standard for web and digital accessibility. Products must provide information through more than one sensory channel, offer alternatives to speech and fine motor control, be compatible with assistive technologies, and include accessible documentation and support services.

For physical products like self-service terminals and ATMs, the requirements address aspects such as screen contrast, font sizes, audio output options, physical reach ranges, tactile feedback, and compatibility with hearing aids. The EAA also requires that the built environment where services are provided must be accessible, including physical premises and digital touchpoints. Manufacturers must document how their products meet the accessibility requirements through technical documentation and an EU declaration of conformity, and they must affix the CE marking to products that comply.