European Accessibility Act (EAA)

What the EAA Is

The European Accessibility Act is Directive (EU) 2019/882, adopted on 17 April 2019 and published in the Official Journal on 7 June 2019^[1]. Member States were required to transpose it into national law by 28 June 2022, and economic operators must comply with its requirements for products placed on the market and services provided to consumers on or after 28 June 2025^[1].

Unlike the earlier Web Accessibility Directive (Directive (EU) 2016/2102), which applies only to public-sector websites and mobile applications^[2], the EAA reaches private-sector economic operators. Where 2016/2102 fixed a gap in public-sector digital accessibility, 2019/882 extends binding requirements into the private market for a specific enumerated list of products and services.

Products in Scope (Article 2(1))

The EAA applies to the following products placed on the EU market on or after 28 June 2025^[1]:

• Consumer general-purpose computer hardware systems and their operating systems.
• Self-service terminals: payment terminals, ATMs, ticketing machines, check-in machines, and interactive information terminals (excluding those installed as integrated parts of vehicles, aircraft, ships, or rolling stock).
• Consumer terminal equipment with interactive computing capability used for electronic communications services (for example, smartphones).
• Consumer terminal equipment with interactive computing capability used for accessing audiovisual media services.
• E-readers.

Services in Scope (Article 2(2))

The EAA applies to the following services provided to consumers on or after 28 June 2025^[1]:

• Electronic communications services (excluding machine-to-machine transmission).
• Services providing access to audiovisual media services -- the websites, mobile apps, electronic programme guides, and access-service delivery (captions, audio description, sign-language interpretation) that surround the media content itself.
• Elements of air, bus, rail, and waterborne passenger transport services: websites, mobile apps, electronic tickets and ticketing services, delivery of transport-service information including real-time travel information, and interactive self-service terminals within the EU.
• Consumer banking services.
• E-books and dedicated reading software.
• E-commerce services.
• Answering of emergency communications to the single European emergency number 112.

Microenterprises providing services are exempt from the substantive requirements of the Directive, though they must inform Member State authorities on request^[1]. The exemption does not extend to microenterprises dealing with products.

Technical Baseline: EN 301 549 and WCAG 2.1 AA

The EAA sets its functional accessibility requirements in Annex I rather than naming a specific technical standard in the directive text. Conformity is established through harmonised standards adopted under Regulation (EU) 1025/2012: where a product or service meets a harmonised standard (or parts of it) whose reference is published in the Official Journal, it benefits from a presumption of conformity with the corresponding Annex I requirements^[1].

For ICT -- including web content and mobile applications -- the harmonised standard is EN 301 549, maintained by ETSI, CEN, and CENELEC under Mandate 376. EN 301 549 incorporates WCAG 2.1 Level A and Level AA by reference for web content (clause 9) and for non-web documents and software that deliver web-like content^[3].

Practical consequence: a website that conforms to WCAG 2.1 AA satisfies the web-content layer of the EAA's Annex I requirements. It does not satisfy the rest of the directive -- accessibility information obligations, the conformity-assessment procedure in Annex IV, accessibility statements, feedback mechanisms, market-surveillance cooperation, and the "disproportionate burden" documentation requirement all sit outside what a WCAG audit covers.

Disproportionate Burden and Fundamental Alteration

Article 14 of the EAA lets economic operators claim that a specific accessibility requirement would impose a disproportionate burden or require a fundamental alteration of the product or service^[1]. The claim is not self-executing: the operator must carry out and document an assessment using the criteria in Annex VI (costs, benefits, organisation size and resources, estimated costs relative to total cost of producing or providing the product or service), retain that assessment for five years, and provide it to market surveillance authorities on request.

A disproportionate-burden claim does not exempt the operator from all accessibility requirements -- only those specific ones where the burden is documented. Public funding received specifically to improve accessibility cannot be counted toward the "burden" side of the calculation.

National Transposition

The EAA is a directive, not a regulation: it takes effect through national transposition laws, each of which designates its own enforcement authority, penalty schedule, and reporting procedures. The three largest Member States illustrate the range:

• France -- RGAA (Référentiel général d'amélioration de l'accessibilité). France extended its existing public-sector RGAA framework to cover EAA obligations, with enforcement by the Autorité de régulation de la communication audiovisuelle et numérique (ARCOM) and the DGCCRF for consumer-protection aspects.
• Germany -- BFSG (Barrierefreiheitsstärkungsgesetz). The BFSG is Germany's private-sector EAA transposition. It sits alongside -- and does not replace -- BITV 2.0, which continues to apply to federal public-sector web content under the earlier Web Accessibility Directive.
• Italy -- Stanca Law extension. Italy extended Legge Stanca (Law 4/2004), originally a public-sector accessibility law, via Legislative Decree 82/2022 to cover private-sector operators under the EAA, with AgID as the supervisory body.

If your organisation sells into multiple Member States, the technical baseline (EN 301 549) is the same, but the enforcement body, complaint mechanism, and accessibility-statement format vary per country.