European Accessibility Act

The EAA applies now.
Know if your product is in it.

Since 28 June 2025, consumer-facing digital services in the EU must meet accessibility requirements. Whether you are directly covered or a supplier to someone who is, this guide explains the scope, the dates and what to check. Not legal advice: national laws differ in detail.

Directive (EU) 2019/88228 June 2025EN 301 549WCAG 2.2Microenterprise exemption

Last updated Published by TryTrustableNot legal advice

Short answer

The European Accessibility Act (EAA), Directive (EU) 2019/882, requires certain products and services sold to consumers in the EU to be accessible to people with disabilities. It has applied since 28 June 2025 through each member state's national law. Covered services include e-commerce, consumer banking, e-books, electronic communications, access to audiovisual media and passenger transport websites, apps and ticketing. Microenterprises providing services (fewer than 10 staff and no more than EUR 2 million turnover or balance sheet) are exempt. In practice, conformance is shown against EN 301 549, which builds on WCAG.

01

What is the European Accessibility Act?

The European Accessibility Act is Directive (EU) 2019/882 on the accessibility requirements for products and services. It sets common accessibility requirements across the EU for a list of products and services that people with disabilities depend on, so that companies face one set of rules instead of 27. As a directive, it works through national law: each member state transposed it and enforces it.

It is separate from the Web Accessibility Directive (EU) 2016/2102, which covers public sector websites and apps. The EAA mainly covers private companies serving consumers.

02

When does the European Accessibility Act apply?

The requirements have applied since 28 June 2025. There are transition periods for existing products and contracts.

DateWhat happens
17 April 2019Directive (EU) 2019/882 adopted
28 June 2022Deadline for member states to put it into national law
28 June 2025Requirements apply to products placed on the market and services provided to consumers
Until 28 June 2030Service providers may keep using products they lawfully used before 28 June 2025; service contracts agreed before that date may run unchanged until they end, but no longer than five years
28 June 2027 (latest)Member states may delay until this date the rules on answering emergency 112 communications (Article 4(8))
Up to 20 yearsSelf-service terminals in use before 28 June 2025 may stay until the end of their economic life, capped at 20 years

Articles 31 and 32. The 20-year terminal rule is an option member states may adopt; check national law.

03

Which products and services are covered?

CoveredExamplesNote for software companies
E-commerce servicesOnline shops, marketplaces, booking and checkout flows sold to consumersThe widest category for SaaS: covers the consumer's journey to a contract, on web and mobile
Consumer banking servicesOnline banking, payment and credit services for consumersIncludes the websites and apps
E-books and dedicated softwareE-books and the software used to read them
Electronic communicationsPhone, messaging and similar services
Access to audiovisual media servicesWebsites, apps and electronic programme guides used to reach TV and streaming
Passenger transport (air, bus, rail, waterborne)Websites, mobile apps, e-tickets, real-time travel informationSome elements only for certain transport types
ProductsConsumer computers and operating systems, smartphones, e-readers, payment terminals, ATMs, ticketing and check-in machinesHardware and the OS, not general business software

From Article 2 of Directive (EU) 2019/882. Check the national transposing law in each country you sell in.

The e-commerce definition is broad: services provided at a distance through websites and mobile services, by electronic means, at the individual request of a consumer, with a view to concluding a consumer contract. Any consumer-facing SaaS that sells or takes bookings online should check it carefully.

04

Does the EAA apply to B2B SaaS?

The obligations fall on the economic operators who place covered products on the market or provide covered services to consumers. A pure business-to-business tool with no consumer journey is generally not directly covered. But if your software is the checkout, booking flow, banking interface or support widget that a covered business shows to consumers, that business must make the whole service accessible, and it will pass the requirement to you through contracts, security and procurement reviews. In practice, many SaaS vendors selling into the EU are being asked to show WCAG 2.2 AA and EN 301 549 conformance whether or not the Act names them.

05

The microenterprise exemption

Article 4(5) exempts microenterprises that provide services from the accessibility requirements. A microenterprise employs fewer than 10 people and has an annual turnover, or an annual balance sheet total, of no more than EUR 2 million. The exemption covers services only: microenterprises that make covered products are not exempt, though member states must give them guidance.

Separately, Article 14 lets any business rely on a disproportionate burden or a fundamental alteration of the product or service, but only after a documented assessment using the criteria in Annex VI, and the business must still meet the requirements as far as it can.

06

EN 301 549 and WCAG: how conformance is shown

Article 15 gives a presumption of conformity to products and services that meet harmonised standards published in the Official Journal. The standard for ICT is EN 301 549. ETSI published EN 301 549 V4.1.1 in September 2026; it is aligned with WCAG 2.2 and includes an annex mapping its clauses to the EAA. The presumption of conformity applies once its reference is cited in the Official Journal under the Act, so check the current citation status. Until then, WCAG 2.2 Level AA for web content and apps is the practical baseline. Our WCAG 2.2 checklist covers what to test.

07

What must a covered service provider publish?

Article 13 and Annex V require service providers to make information available, in their general terms and conditions or an equivalent document, explaining how the service meets the accessibility requirements. Many businesses publish this as an accessibility statement. Keep it accurate and dated, and update it when the service changes.

08

Who enforces the EAA, and what are the penalties?

Enforcement is national. Each member state designates authorities to check that services comply, act on complaints and require corrective action (Article 23), and market surveillance authorities handle products. Member states set the penalties (Article 30); they must be effective, proportionate and dissuasive, come with remedial action, and take account of how serious the failure is and how many people are affected, so amounts and procedures differ by country. Check the law and authority in each country where you have consumers.

09

What a SaaS startup selling into the EU should check

QuestionIf yes
Do consumers in the EU use your product to buy something, bank, read e-books, travel or communicate?You may be a covered service provider. Get legal advice for each market.
Do you supply software that covered businesses use to serve consumers (checkout, booking, banking UI, help widgets)?You are probably not directly regulated, but your customers need you to conform. Expect contract clauses and a request for an ACR.
Are you a microenterprise providing a service?The service requirements do not apply to you, but your larger customers still will ask.
Do you sell to EU public bodies?They follow the Web Accessibility Directive and procure against EN 301 549. Prepare an EU or INT edition VPAT.
Is your product purely B2B with no consumer journey?The EAA probably does not reach it directly; buyers may still ask for WCAG 2.2 AA.

Our reading of the Directive for planning purposes, not legal advice.

  1. Map which of your products touch EU consumers and which EAA category they could fall into.
  2. Audit against WCAG 2.2 AA, including keyboard and screen reader testing.
  3. Write an ACR on the EU or INT edition of the VPAT so customers can assess you.
  4. If you are covered, publish the Annex V accessibility information and keep it current.
  5. Plan fixes for known gaps; do not rely on the disproportionate burden route without a written assessment.
10

Where TryTrustable fits

TryTrustable scans your public pages against the WCAG 2.2 Level A and AA rules with axe-core, the open-source accessibility engine, and maps each failure to its success criterion with the element and how to fix it. It then gives your team a worksheet of all 55 A and AA criteria to set the conformance level and remarks for each, and issues a sealed Accessibility Conformance Report based on the VPAT® 2.5 WCAG edition. Automated rules find only some failures, so the product never marks a criterion "Supports" by itself: that needs manual testing with a keyboard, a screen reader and zoom, by your team or a specialist. It does not yet scan pages behind a login or produce the 508, EU or INT editions. It does not write EAA accessibility statements. For EU buyers we help with the privacy and security side of the same review: GDPR consent and rights requests, SOC 2 and ISO 27001 evidence, and a trust center. See the enterprise readiness guide for the full list.

Questions

The things people ask us

When did the European Accessibility Act come into force?

The Directive was adopted in 2019, member states had to transpose it by 28 June 2022, and its requirements have applied since 28 June 2025.

Does the European Accessibility Act apply to companies outside the EU?

Yes, if they place covered products on the EU market or provide covered services to consumers in the EU. Where the company is established does not decide it.

Are small businesses exempt from the EAA?

Microenterprises providing services are exempt: fewer than 10 employees and annual turnover or balance sheet total of no more than EUR 2 million. Microenterprises making covered products are not exempt.

What standard should we follow for the EAA?

EN 301 549, whose V4.1.1 (September 2026) aligns with WCAG 2.2. Check whether it has been cited in the Official Journal, which gives the presumption of conformity. WCAG 2.2 AA is the practical baseline for web and apps.

What are the penalties under the European Accessibility Act?

Each member state sets its own penalties, which must be effective, proportionate and dissuasive. Authorities can also require a non-compliant service to be brought into line.

Does TryTrustable make us EAA compliant?

No tool makes you compliant on its own. TryTrustable runs automated WCAG 2.2 scans and produces a conformance report your team completes after manual testing; EN 301 549 has requirements beyond WCAG that it does not check.

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