European Accessibility Act (EAA) Guide: 2025 Compliance Requirements

The European Accessibility Act (EAA) establishes mandatory accessibility requirements for products and services sold in the European Union, with enforcement beginning June 28, 2025. Unlike previous EU directives targeting only public sector websites, the EAA applies to private sector businesses—including e-commerce, banking, telecommunications, and transportation services. Organizations selling to EU customers must ensure their digital products and services meet accessibility standards or face market access restrictions and penalties.

This guide covers EAA requirements, affected sectors, technical standards, and compliance strategies for businesses operating in European markets.

Q: When does the European Accessibility Act take effect?

A: The EAA takes effect June 28, 2025. Member states were required to transpose the directive into national law by June 28, 2022. Products and services placed on the market or provided after June 28, 2025 must comply. Some existing products have transition periods until June 28, 2030.

EAA Overview

What Is the European Accessibility Act?

The European Accessibility Act (Directive 2019/882) is EU legislation requiring accessibility for specific products and services. It aims to:

• Improve functioning of the internal market for accessible products
• Remove barriers for persons with disabilities
• Harmonize accessibility requirements across member states
• Enable businesses to compete on equal footing across EU

Scope of the EAA

Products covered:

• Computers and operating systems
• Self-service terminals (ATMs, ticketing machines, check-in kiosks)
• Consumer terminal equipment (smartphones, tablets, TVs)
• E-readers

Services covered:

• E-commerce services
• Banking services (consumer-focused)
• Electronic communications services
• Audiovisual media services
• E-books and e-book software
• Transportation services (air, bus, rail, waterborne)

Who Must Comply

Manufacturers: Products sold in EU must meet accessibility requirements

Service providers: Services offered to EU consumers must be accessible

Importers and distributors: Must verify products meet requirements

Microenterprises exemption: Companies with fewer than 10 employees AND annual turnover/balance sheet under €2 million may be exempt from service requirements (not product requirements)

Technical Requirements

EN 301 549: The Technical Standard

The EAA references EN 301 549 as the harmonized European standard for ICT accessibility. EN 301 549 incorporates:

• WCAG 2.1 Level AA for web content
• Additional requirements for software, hardware, and documentation
• Functional performance statements

Web Content Requirements

For e-commerce and web-based services, EN 301 549 requires WCAG 2.1 Level AA conformance:

Perceivable:

• Text alternatives for non-text content
• Captions and audio descriptions for multimedia
• Adaptable content structure
• Distinguishable presentation (contrast, text spacing)

Operable:

• Keyboard accessible functionality
• Sufficient time to interact with content
• No seizure-triggering content
• Navigable structure

Understandable:

• Readable content
• Predictable operation
• Input assistance and error handling

Robust:

• Compatible with current and future assistive technologies

Mobile Application Requirements

Mobile apps providing covered services must:

• Support platform accessibility features
• Work with screen readers
• Provide sufficient touch targets
• Support text scaling and display preferences

Self-Service Terminal Requirements

Kiosks, ATMs, and check-in machines must:

• Be operable without vision, hearing, or speech
• Provide tactile and audio output
• Have accessible physical design (reach, height)
• Support assistive technology connection

E-Commerce Under the EAA

What E-Commerce Must Provide

The EAA specifically requires e-commerce services to be accessible, including:

Website accessibility:

• Full WCAG 2.1 AA conformance
• Accessible checkout process
• Accessible product information
• Accessible customer service channels

Mobile apps:

• Equivalent accessibility to websites
• Platform accessibility feature support

Electronic documents:

• Accessible invoices, receipts, contracts
• Accessible terms and conditions

E-Commerce Accessibility Requirements

Product information:

<!-- Accessible product display -->
<article>
  <h2>Product Name</h2>
  <img src="product.jpg" alt="Detailed product description">
  <p class="price" aria-label="Price: 49.99 euros">€49.99</p>
  <button>Add to Cart</button>
</article>

Checkout accessibility:

• All form fields properly labeled
• Error messages clear and associated
• Payment options keyboard accessible
• Order confirmation accessible

Customer communications:

• Accessible email templates
• Accessible PDF documents
• Alternative formats available upon request

TestParty for EAA Compliance

TestParty helps e-commerce businesses achieve EAA compliance:

Automated scanning: Identifies WCAG 2.1 AA violations across your site

Source code remediation: Generates actual fixes, not just reports

Continuous monitoring: Catches new issues as content changes

Shopify integration: Platform-specific fixes for Shopify merchants

Banking Services Requirements

Consumer Banking Accessibility

Banking services under EAA include:

• Online banking platforms
• Mobile banking apps
• ATMs and self-service terminals
• Electronic contracts and statements

Specific Banking Requirements

Online platforms:

• WCAG 2.1 AA compliance
• Accessible account management
• Accessible transaction processes
• Accessible statements and documents

Authentication:

• Accessible login processes
• Alternatives to CAPTCHA
• Support for password managers
• Accessible multi-factor authentication

Documents:

• Accessible PDF statements
• Electronic contracts in accessible formats
• Alternative formats upon request

Transportation Services Requirements

Covered Transportation

EAA covers passenger transportation services:

• Air transport
• Bus transport
• Rail transport
• Waterborne transport

Transportation Accessibility Requirements

Websites and booking:

• Accessible booking platforms
• Accessible ticketing
• Accessible journey planning
• Accessible check-in processes

Self-service terminals:

• Accessible ticket machines
• Accessible check-in kiosks
• Tactile and audio output options

Real-time information:

• Accessible departure/arrival information
• Accessible delay notifications
• Multiple communication channels

Compliance Timeline

Key Dates

June 28, 2022: Member states transposition deadline

June 28, 2025: EAA enforcement begins

• New products/services must comply
• Market surveillance begins
• Non-compliant products cannot be placed on market

June 28, 2027: Self-service terminals

• Existing terminals may continue until this date
• New terminals must comply from 2025

June 28, 2030: Final transition

• All pre-existing service contracts must comply
• No further transition periods

Transitional Provisions

Existing products: Products legally on market before June 28, 2025 may continue for 5 years

Service contracts: Existing contracts may continue until June 28, 2030

Self-service terminals: Up to 20-year lifespan for terminals in service before 2025

Enforcement and Penalties

National Enforcement

Each member state designates market surveillance authorities responsible for:

• Monitoring compliance
• Investigating complaints
• Taking enforcement action
• Imposing penalties

Potential Penalties

Penalties vary by member state but may include:

• Fines (potentially significant, comparable to GDPR)
• Product withdrawal from market
• Service suspension
• Public notification of non-compliance

Complaint Mechanisms

Member states must provide:

• Accessible complaint procedures
• Response within reasonable timeframe
• Right to appeal decisions

Compliance Strategy

Assessment Phase

1. Determine applicability: Identify which products/services are covered
2. Gap analysis: Assess current accessibility status
3. Risk assessment: Prioritize based on enforcement risk and user impact

Remediation Phase

1. Technical fixes: Address WCAG violations
2. Process updates: Integrate accessibility into development
3. Documentation: Create accessibility statements and conformance reports

Monitoring Phase

1. Continuous testing: Ongoing accessibility monitoring
2. User feedback: Implement accessibility feedback mechanisms
3. Regular audits: Periodic comprehensive assessments

Documentation Requirements

Accessibility statement:

## Accessibility Statement

[Company Name] is committed to ensuring accessibility of [product/service]
for people with disabilities.

**Conformance status:** [Product/Service] conforms to EN 301 549 and
WCAG 2.1 Level AA.

**Feedback:** Contact accessibility@example.com for accessibility
questions or to report barriers.

Technical documentation:

• Conformance reports
• Testing methodology
• Known limitations and remediation plans

Relationship to Other Requirements

EAA vs Web Accessibility Directive

| Aspect             | Web Accessibility Directive | European Accessibility Act |
|--------------------|-----------------------------|----------------------------|
| Scope              | Public sector               | Private sector             |
| Effective          | 2016/2019                   | 2025                       |
| Technical standard | EN 301 549                  | EN 301 549                 |
| Products covered   | Websites, apps              | Products and services      |

EAA vs GDPR

Both regulations may apply simultaneously:

• GDPR: Data protection for personal data
• EAA: Accessibility of services processing that data

Accessibility features must not compromise privacy, and privacy features must be accessible.

EAA vs ADA

| Aspect             | ADA (US)                  | EAA (EU)                   |
|--------------------|---------------------------|----------------------------|
| Legal basis        | Civil rights law          | Single market directive    |
| Technical standard | WCAG (court precedent)    | EN 301 549 (explicit)      |
| Enforcement        | Litigation-driven         | Market surveillance        |
| Scope              | All public accommodations | Specific products/services |

Organizations operating in both markets should target WCAG 2.1 AA to satisfy both frameworks.

FAQ Section

Q: Does the EAA apply to non-EU companies?

A: Yes. Any company selling covered products or providing covered services to EU consumers must comply, regardless of where the company is headquartered. This includes US companies with EU customers.

Q: What is the microenterprise exemption?

A: Companies with fewer than 10 employees AND less than €2 million annual turnover may be exempt from service accessibility requirements. However, this exemption doesn't apply to product requirements, and member states may implement stricter rules.

Q: Is WCAG 2.1 AA sufficient for EAA compliance?

A: For web content, WCAG 2.1 AA conformance satisfies EAA requirements as incorporated through EN 301 549. However, the EAA has additional requirements for mobile apps, documents, and overall service accessibility beyond web content alone.

Q: How does the EAA affect Shopify stores selling to EU?

A: Shopify stores providing e-commerce services to EU consumers must ensure their stores are WCAG 2.1 AA compliant. TestParty provides Shopify-specific accessibility fixes to help merchants achieve compliance.

Q: What penalties can EU countries impose for EAA violations?

A: Penalties are determined by member states and may include fines, product withdrawal, service suspension, and public notification. Some countries are implementing GDPR-style penalty frameworks with potentially significant fines.

Key Takeaways

• EAA enforcement begins June 28, 2025. Products and services in EU market must comply.

• Private sector e-commerce is covered. Unlike previous directives, EAA applies to private businesses selling to consumers.

• WCAG 2.1 AA is the web standard through EN 301 549 harmonized standard.

• Non-EU companies must comply if selling to EU consumers.

• Microenterprise exemption is limited. Only applies to services for smallest businesses.

• Continuous compliance required. Ongoing monitoring, not just initial conformance.

Conclusion

The European Accessibility Act represents a significant expansion of accessibility requirements to the private sector. E-commerce businesses, banks, telecommunications providers, and transportation services must ensure their digital products meet EN 301 549/WCAG 2.1 AA standards by June 28, 2025.

For e-commerce specifically, this means accessible websites, mobile apps, checkout processes, and customer communications. Organizations operating in EU markets should begin compliance efforts now—the deadline is imminent.

TestParty helps businesses achieve EAA compliance through automated WCAG scanning and source code remediation. For e-commerce sites targeting EU customers, TestParty provides the fixes needed to meet EN 301 549 requirements before the enforcement deadline.

Ready for EAA compliance? Schedule a TestParty demo to see how automated remediation achieves EU accessibility standards.

Related Articles:

• WCAG 2.1 AA Requirements: Complete Implementation Guide
• ADA Website Compliance 2025: US Legal Requirements
• E-Commerce Accessibility: Complete WCAG Compliance Guide

Just so you know, this article was written with AI assistance. Our accessibility specialists at TestParty reviewed it, but web accessibility rules differ by region and use case. Please check with qualified professionals before making compliance decisions based on what you read here.