What changes in June 2025
From 28 June 2025, the European Accessibility Act (EAA) starts to apply across the EU for a defined set of products and services placed on the market or provided to consumers. The EAA is set out in Directive (EU) 2019/882. It aims to improve the accessibility of key everyday services and digital channels, while reducing fragmentation between national rules.
In practice, this means organisations covered by the rules will need to ensure that relevant consumer-facing products, websites, apps, e-commerce journeys, support services and related digital content meet accessibility requirements. The exact national enforcement approach depends on how each Member State has transposed the Directive into domestic law, but the overall compliance obligation is now part of the operating environment for many businesses and public-facing service providers.
Although the EAA is often discussed alongside public sector accessibility rules, it is a separate legal instrument with a different scope. Public sector bodies have already been subject to web and mobile accessibility obligations under the Web Accessibility Directive. The EAA extends accessibility obligations further into the private market for certain products and services, especially where consumers rely on digital interfaces to access essential or common services.
The EU regulatory context
The EAA sits within a broader EU accessibility framework. The key legal and policy context includes:
- Directive (EU) 2019/882, the European Accessibility Act, which sets accessibility requirements for certain products and services.
- Directive (EU) 2016/2102, the Web Accessibility Directive, which covers websites and mobile applications of public sector bodies.
- EN 301 549, the European standard commonly used to demonstrate accessibility requirements for ICT products and services, including websites, apps, software and documents.
- WCAG (Web Content Accessibility Guidelines), which remain the practical benchmark for web accessibility and are widely referenced through standards and procurement requirements.
- The UN Convention on the Rights of Persons with Disabilities, which underpins much of the EU’s accessibility approach.
The purpose of the EAA is not only social inclusion. It is also a single market measure. Before the Directive, different national accessibility requirements created legal and operational complexity. The EAA is intended to harmonise the baseline requirements for covered products and services so that providers can work to a more consistent framework across the EU.
That said, harmonisation is not the same as complete uniformity. Member States still determine enforcement structures, procedural details, penalties and market surveillance arrangements. So while the legal basis is EU-wide, organisations still need to check the national legislation in every country where they operate.
Who is affected by the EAA
The EAA does not apply to every organisation or every digital service. It applies to specific categories of products and services listed in the Directive.
Products in scope
The Directive covers a range of products placed on the market, including:
- Consumer general-purpose computer hardware systems and their operating systems
- Self-service terminals, such as payment terminals, certain ticketing machines, check-in machines and ATMs
- Consumer terminal equipment with interactive computing capability used for electronic communications services
- Consumer terminal equipment with interactive computing capability used for accessing audiovisual media services
- E-readers
For manufacturers, importers and distributors, the obligations can include design, documentation, conformity assessment, CE marking processes where relevant, and ensuring accessibility information is available.
Services in scope
For many organisations, the most immediate impact is on services. These include:
- Electronic communications services, with some exceptions
- Services providing access to audiovisual media services
- Passenger transport services for air, bus, rail and waterborne transport, including certain websites, apps, e-tickets and real-time travel information
- Consumer banking services
- E-books and dedicated software
- E-commerce services
The phrase e-commerce services is particularly important. It covers services provided at a distance, through websites or mobile-based means, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract. This means many online shops, booking flows, subscription sign-up journeys and transactional portals may be in scope.
Which organisations need to pay attention
In practical terms, the EAA affects:
- Retailers selling to consumers online in the EU
- Banks and financial service providers offering consumer-facing digital services
- Transport operators and ticketing providers
- Telecoms providers
- Media platforms and services providing access to audiovisual content
- Manufacturers of covered consumer devices and self-service terminals
- Software providers whose products form part of covered services
It also affects organisations indirectly. A public institution, regulated utility or large enterprise may not itself be the legal operator of an in-scope consumer service, but it may procure digital systems from suppliers who now need to meet EAA requirements. Accessibility therefore becomes a supply chain and procurement issue, not just a compliance issue for the final service provider.
Are there exemptions?
Yes, but they are limited and should not be treated as a simple opt-out.
Microenterprises
For services, microenterprises are given some relief under the Directive. A microenterprise is generally defined as a business with fewer than 10 employees and annual turnover or annual balance sheet total not exceeding EUR 2 million. However, this exemption does not remove all practical pressure. Contractual requirements, procurement conditions, platform rules and customer expectations may still require accessibility.
For products, the position is more complex and should be checked carefully against the Directive and national implementation rules.
Fundamental alteration and disproportionate burden
There are also limited defences where compliance would:
- Fundamentally alter the basic nature of the product or service, or
- Impose a disproportionate burden on the economic operator
These are not broad exceptions. They require assessment, evidence and documentation. Organisations relying on them need to be able to justify their position to regulators or market surveillance authorities. In most cases, they should be seen as narrow and fact-specific arguments, not a substitute for a proper accessibility programme.
What the requirements mean in practice
The EAA sets out accessibility requirements at a legal level rather than prescribing every technical detail. In practice, compliance often means ensuring that digital interfaces and support channels are perceivable, operable, understandable and robust for people with disabilities.
For websites, apps and digital services, this commonly includes:
- Keyboard accessibility for core tasks
- Compatibility with screen readers and assistive technologies
- Clear structure, headings, labels and form instructions
- Sufficient colour contrast and scalable text
- Alternatives for non-text content
- Accessible authentication, identification and payment journeys
- Consistent navigation and understandable error handling
- Accessible documents and customer communications where they form part of the service
Support services are also relevant. If a service includes helpdesks, information points, onboarding materials or contractual information, these may need to be provided in accessible formats and through accessible channels.
For many digital teams, EN 301 549 and WCAG 2.1 AA or later versions remain the most useful operational reference points, even where the legal obligation is framed through the Directive and national law.
Sanctions and enforcement
The EAA requires Member States to establish rules on penalties for non-compliance and to ensure those penalties are effective, proportionate and dissuasive. This means there is no single EU-wide fine schedule. Sanctions depend on national law.
However, organisations should not assume enforcement will be light. Depending on the Member State and the nature of the breach, consequences may include:
- Administrative fines
- Orders to bring products or services into compliance
- Requirements to withdraw or suspend non-compliant products or services
- Corrective action imposed by market surveillance or supervisory authorities
- Consumer complaints and legal claims under national frameworks
- Reputational damage and procurement risk
For products, market surveillance authorities may investigate whether products placed on the market meet the applicable requirements. For services, supervisory or competent authorities may review whether the service provider has met its obligations under national implementing law.
There is also a practical enforcement route through customers and counterparties. If a banking journey, ticketing flow or e-commerce checkout is inaccessible, the issue may surface first as a complaint, ombudsman case, procurement challenge or contractual dispute before it becomes a formal regulatory matter.
Transitional points to note
The Directive includes some transitional provisions, and these can be important for legacy systems and long-life infrastructure. For example, certain service contracts or self-service terminals may benefit from limited transition periods under the legal framework. But these provisions are technical and should be reviewed carefully against the national law in each relevant country.
The safe assumption is that organisations should not rely on transition rules unless they have clear legal advice and documented evidence that the provision applies.
How to prepare for compliance
For most organisations, preparation is not a one-off accessibility audit. It is a combination of legal scoping, technical remediation, governance and supplier management.
1. Confirm whether your products or services are in scope
Start with a legal and operational mapping exercise. Identify:
- Which products and services you provide to consumers in the EU
- Which websites, mobile apps, portals, kiosks and support channels are part of those services
- Which countries you operate in and the national laws that apply
- Which entities in your group are the manufacturer, importer, distributor or service provider
This step matters because the EAA applies by category, not by general brand presence.
2. Carry out an accessibility gap assessment
Review the current state of your digital estate against recognised standards, typically EN 301 549 and WCAG. This should include:
- Automated testing for common issues
- Manual expert review
- Assistive technology testing
- Testing of critical user journeys such as registration, login, checkout, payment, account management and support
- Review of PDFs, emails, statements and other service documents
A gap assessment should produce a prioritised remediation plan, not just a defect list.
3. Prioritise high-risk journeys
Not everything can always be fixed at once. Focus first on the parts of the service that are essential for access and completion:
- Account creation and authentication
- Search and navigation
- Product selection or booking
- Forms and payment
- Customer support and complaints channels
- Access to contractual information, statements or tickets
If users cannot complete the core transaction independently, the compliance risk is usually much higher.
4. Build accessibility into design and development
Accessibility work fails when it is treated as a late-stage QA task. Teams should update:
- Design systems and component libraries
- Content design patterns
- Front-end development standards
- Definition of done and release criteria
- Testing processes in CI/CD pipelines
This reduces the cost of future compliance and prevents recurring defects.
5. Review suppliers and procurement
Many accessibility failures come from third-party tools: payment providers, booking engines, identity checks, chat widgets, document generators and embedded media players. Review supplier contracts and procurement processes to ensure accessibility is specified, evidenced and tested.
For public institutions and regulated organisations, this is especially important. Accessibility should be part of tender requirements, acceptance criteria and ongoing vendor management.
6. Put governance in place
Compliance needs ownership. Good practice usually includes:
- A named senior owner
- Clear internal policy and standards
- Training for design, content, development, QA and procurement teams
- Documented decisions where disproportionate burden or transitional arguments are considered
- Regular monitoring and re-testing
Without governance, accessibility improvements tend to degrade over time.
7. Prepare documentation and evidence
If challenged by a regulator, customer or contracting authority, you will need to show what you have done. Keep records of:
- Scope assessments
- Audit results
- Remediation plans
- Testing evidence
- Supplier assurances
- Internal approvals and exception decisions
Evidence of a structured compliance effort can be important, especially where issues are being actively remediated.
Why this matters beyond legal compliance
The EAA is a legal requirement, but it also reflects a basic service standard. If a consumer cannot buy a ticket, access a bank account, read a statement or complete an online purchase because the interface is inaccessible, the problem is operational as much as legal.
For organisations serving the public, accessibility affects service quality, inclusion, conversion, support costs and trust. For public sector institutions and their suppliers, it also affects procurement readiness and long-term digital resilience.
Final point
June 2025 is not the start of a theoretical policy discussion. It is the point at which the EAA becomes operational for in-scope products and services across the EU. Organisations that have not yet scoped their exposure, tested their digital journeys and addressed supplier risk should treat this as an immediate priority.
The details of enforcement will vary by Member State, but the direction is clear: accessibility is now a compliance requirement for a significant part of the consumer digital economy. The most effective response is practical and structured: understand your scope, fix the barriers that matter most, and make accessibility part of how you design and run digital services.