What is the European Accessibility Act? EAA Compliance Timeline

The European Accessibility Act represents the most significant accessibility legislation to emerge in years—and if you do business in Europe or with European customers, it affects you. Unlike regulations focused solely on government entities, the EAA extends accessibility requirements to private sector products and services, creating obligations for businesses that have never faced formal accessibility mandates before.

With the compliance deadline approaching in June 2025, understanding what the EAA requires has become urgent for any organization with European market exposure.

What the European Accessibility Act Is

The European Accessibility Act (EAA), formally Directive (EU) 2019/882, is an EU directive requiring accessibility for certain products and services. Adopted in 2019, it harmonizes accessibility requirements across EU member states, creating consistent standards rather than a patchwork of national rules.

The EAA aims to improve access for persons with disabilities while creating a unified internal market for accessible products and services. By standardizing requirements, the directive reduces compliance complexity for businesses operating across multiple EU countries and ensures that accessibility improvements benefit all Europeans equally.

Unlike some accessibility regulations that focus narrowly on digital experiences, the EAA covers both physical products and digital services, recognizing that accessibility barriers exist across all types of consumer interactions.

When Compliance Is Required

The EAA timeline creates urgency for organizations that haven't yet addressed accessibility:

June 28, 2025: The primary compliance deadline. From this date, products and services covered by the EAA must be accessible when placed on the EU market or provided to EU consumers.

June 28, 2027: Extended transition for certain service contracts entered before June 2025.

June 28, 2030: Deadline for self-service terminals already in use before June 2025.

For most digital services, June 2025 is the operative date. Organizations should already be well into their compliance efforts—June 2025 provides less than two years from when this article is written.

What's Covered

The EAA covers specific categories of products and services. Not everything falls under its scope, but the coverage is broader than many organizations expect.

Products

Computers and operating systems: Personal computers, tablets, and their operating systems must be accessible.

ATMs and ticketing machines: Self-service terminals for banking, ticketing, check-in, and payment.

Smartphones and tablets: Mobile devices and their operating systems.

TV equipment: Television devices with computing capabilities.

E-readers: Digital reading devices.

Services

E-commerce: Online retail and services, including websites and mobile applications.

Banking services: Consumer banking, including online banking and mobile banking apps.

Electronic communications: Phone services, messaging services, and related consumer services.

Transport services: Ticketing and check-in for air, bus, rail, and waterborne transport.

E-books and dedicated software: Digital publications and the software used to access them.

What's Not Covered

The EAA doesn't cover everything. Notable exclusions include:

• Recorded time-based media (videos published before June 2025)
• Third-party content not under the provider's control
• Content of extranet/intranet applications (certain internal tools)
• Archived content not updated after June 2025

Microenterprises (fewer than 10 employees and under €2 million annual turnover) providing services are also exempt, though this doesn't apply to products.

Technical Requirements

EN 301 549

The EAA references EN 301 549, the European standard for ICT accessibility. Compliance with EN 301 549 creates a presumption of conformity with EAA requirements—essentially, if you meet the standard, you're presumed to meet the law.

EN 301 549 incorporates WCAG 2.1 Level AA for web content and adds additional requirements for:

• Non-web documents
• Software applications
• Hardware
• Documentation and support services

For organizations already pursuing WCAG compliance, the web content requirements will be familiar. The additional EN 301 549 requirements extend similar principles to non-web contexts.

Functional Performance Criteria

Beyond technical standards, the EAA requires that products and services be usable by persons with disabilities. This functional requirement means compliance isn't just about meeting technical checkboxes but ensuring actual accessibility in practice.

Products and services must work for people who are:

• Without vision
• With limited vision
• Without perception of color
• Without hearing
• With limited hearing
• Without speech
• With limited manipulation or strength
• With limited reach
• With limited cognition

Demonstrating Compliance

CE Marking

Products covered by the EAA must bear CE marking indicating conformity. Manufacturers must prepare technical documentation demonstrating compliance and issue an EU declaration of conformity.

Service Provider Obligations

Service providers must:

• Provide information about accessibility features
• Ensure services meet accessibility requirements
• Provide accessible information about the services themselves
• Establish procedures for addressing accessibility complaints

Market Surveillance

EU member states conduct market surveillance to verify compliance. Non-compliant products may be restricted or removed from the market. Service providers may face enforcement actions under national implementing laws.

Implications for Non-EU Businesses

The EAA affects businesses outside the EU if they:

Sell products in the EU: Products placed on the EU market must comply, regardless of where they're manufactured.

Provide services to EU consumers: Online services accessible to EU customers fall under the directive. An American e-commerce site selling to European customers must comply.

Import products into the EU: Importers have compliance obligations even if manufacturers are outside the EU.

The practical effect is that any business with meaningful European market exposure must consider EAA compliance. This includes US, UK (post-Brexit), and other non-EU businesses serving European customers.

Relationship to Other Regulations

Web Accessibility Directive

The EU Web Accessibility Directive (2016) already required accessibility for public sector websites and apps. The EAA extends similar requirements to the private sector, creating comprehensive coverage across public and private digital services.

GDPR

While GDPR focuses on privacy and the EAA focuses on accessibility, both regulations affect digital services and require attention to user needs. Organizations already managing GDPR compliance have experience with EU regulatory frameworks that transfers to EAA preparation.

National Laws

Each EU member state implements the EAA through national law. While the directive harmonizes core requirements, implementation details may vary. Organizations operating across multiple EU countries should monitor national implementing legislation.

Preparing for Compliance

Organizations should be taking concrete steps now:

Assess current accessibility: Audit websites, applications, and products against EN 301 549 requirements. Understand where you stand relative to requirements.

Prioritize remediation: Focus on high-impact issues affecting core functionality. Not everything can be fixed simultaneously—prioritize by user impact and business criticality.

Integrate accessibility into development: New products and features should be built accessibly from the start. Retrofitting is more expensive than building correctly initially.

Prepare documentation: Develop accessibility statements, conformity documentation, and procedures for handling complaints.

Train teams: Ensure developers, designers, content creators, and customer service staff understand accessibility requirements and their roles in maintaining compliance.

Taking Action

June 2025 approaches quickly. Organizations that haven't begun accessibility efforts should start immediately—meaningful compliance takes time, and waiting creates unnecessary risk and rushing.

The EAA represents a fundamental shift in European accessibility requirements. Rather than viewing it as a burden, forward-thinking organizations see it as clarifying what's expected and creating market opportunity through differentiated accessible products and services.

TestParty helps organizations achieve EN 301 549 compliance through continuous monitoring and actionable remediation guidance.

Schedule a TestParty demo and get a 14-day compliance implementation plan.

Related Resources

• EN 301 549 Compliance
• Global Accessibility Regulations
• WCAG 2.2 Level AA Checklist
• Accessibility Statement Template