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European Accessibility Act compliance: who is in scope, the deadlines, and what the law asks for
Directive (EU) 2019/882 has applied since 28 June 2025. Here is what it covers, who is exempt, and what to do.
In one paragraph. The European Accessibility Act is Directive (EU) 2019/882. It has applied since 28 June 2025 to a defined list of products and services sold to consumers in the EU, including e-commerce, banking, e-books, transport ticketing and telecoms, whether or not the seller is established in Europe. The technical yardstick for websites and apps is EN 301 549, which for web content means WCAG 2.1 Level AA. Microenterprises are exempt for services, existing service contracts get until 28 June 2030, and each member state sets its own penalties, from tens of thousands of euros to, in Ireland, criminal liability.
What the EAA is, and what it is not
The Act is a directive, so it does not apply directly; member states were required to transpose it into national law (Germany's Barrierefreiheitsstärkungsgesetz, for example) by 28 June 2022 (several missed the deadline and faced infringement proceedings), and the national laws apply from 28 June 2025. It is a product safety style law: a service or product that does not meet the requirements can be withdrawn from the market, and market surveillance authorities, not just courts, enforce it.
It is a different law from the Web Accessibility Directive (2016/2102), which has covered public sector websites and apps since 2018. The EAA is the private sector counterpart. If you sell to consumers, the EAA is the one that concerns you; if you are a public body, your obligations come from the Web Accessibility Directive and its model accessibility statement.
Who is in scope
Article 2 lists the products and the services. For most readers of this page the relevant line is e-commerce services, which the directive defines as services provided at a distance, through websites and mobile device based services, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract. If a consumer in the EU can buy something on your site, you are providing an e-commerce service. The other services in scope:
- Electronic communications services (telephony, messaging, internet access), except machine to machine.
- Services giving access to audiovisual media services (the apps and sites through which people watch broadcast and on demand video).
- Elements of air, bus, rail and waterborne passenger transport: websites, apps, e-tickets and ticketing, real time travel information, and interactive self service terminals (with exceptions for urban, suburban and regional transport).
- Consumer banking services.
- E-books and their dedicated software.
- Answering emergency communications to the single European emergency number 112.
Products in scope include consumer computer hardware and operating systems, self service terminals (payment terminals, ATMs, ticketing and check in machines), consumer terminal equipment for electronic communications and for audiovisual media, and e-readers.
Two things follow. First, geography is about the consumer, not the company: a US or UK store shipping to French or German consumers is providing an e-commerce service in the Union. Second, business to business services are out of scope; the directive protects consumers.
Who is exempt, and on what terms
| Exemption | Applies to | Conditions |
|---|---|---|
| Microenterprise (Article 4(5)) | Services only | Fewer than 10 persons employed AND annual turnover or annual balance sheet total not exceeding EUR 2 million. A microenterprise providing e-commerce is fully exempt from the service requirements. Products from microenterprises are not exempt, though the paperwork is lighter. |
| Disproportionate burden (Article 14) | Products and services | You may limit compliance to what would not impose a disproportionate burden, but you must carry out and document an assessment using the criteria in Annex VI (cost of compliance versus cost and benefits, size and resources, and so on), keep it for five years, renew it when the service changes or at least every five years, and provide it to the authority on request. Lack of priority, time or knowledge is explicitly not a reason. |
| Fundamental alteration (Article 14) | Products and services | Only where a requirement would change the basic nature of the product or service. |
| Content exclusions (Article 2(4)) | Websites and apps | Pre-recorded time based media and office file formats published before 28 June 2025; online maps, provided essential navigational information is available accessibly; third party content neither funded nor developed by nor under the control of the operator; and content that qualifies as an archive (not updated or edited after 28 June 2025). |
The deadlines
| Date | What happens |
|---|---|
| 28 June 2022 | Member states had to adopt and publish their national transposing laws. |
| 28 June 2025 | National laws apply. Products placed on the market and services provided to consumers after this date must comply (Article 31). |
| 28 June 2030 | End of the transition. Until then, service providers may keep using products they lawfully used to provide the same service before 28 June 2025, and service contracts agreed before that date may run unchanged until they expire, but no longer than five years (Article 32). |
| Up to 20 years, at the latest 2045 | Self service terminals lawfully in use before 28 June 2025 may stay in service until the end of their economically useful life, capped at 20 years. |
The transition is narrower than it sounds. It protects existing products and existing contracts. A website is neither; a site that was live before June 2025 does not get five extra years.
What "compliant" means for a website or app
The directive's Annex I sets functional requirements: information must be perceivable, operable, understandable and robust, provided through more than one sensory channel, with sufficient contrast, adjustable text, and so on. Those are the four WCAG principles restated as law. Compliance is presumed when you meet a harmonised standard, and the harmonised standard for ICT is EN 301 549. Its clause 9 (web) reproduces the WCAG 2.1 Level AA success criteria, clause 10 applies them to documents, and clause 11 to software including mobile apps.
In practice:
- WCAG 2.1 AA is the baseline a French, German or Dutch regulator will measure your site against. WCAG 2.2 AA, which adds nine criteria and drops one, is the safe target for anything you build now, and everything you fix for the EAA also reduces US ADA lawsuit exposure, which points at the same standard.
- Article 13(2) requires service providers to prepare information, per Annex V, explaining how the service meets the requirements, in accessible written form, in the general terms and conditions or an equivalent place, and to keep it as long as the service is provided. Most companies satisfy this with a public accessibility statement; the statement generator includes an EAA variant.
- You must handle complaints. Article 29 gives consumers and disability organisations the right to take action before courts or authorities, so a visible contact and a response process are part of compliance, not optional.
Penalties and what enforcement looked like in year one
Article 30 leaves penalties to the member states, requiring only that they be effective, proportionate and dissuasive. Published maxima vary widely: Germany's BFSG allows fines up to EUR 100,000; Ireland's transposition provides for fines up to EUR 60,000 and, uniquely, up to 18 months imprisonment; France's law provides EUR 50,000 for web accessibility violations; Italy allows up to 5 percent of annual turnover for companies already covered by the older Stanca law and EUR 40,000 for others.
Enforcement in the first year was investigative rather than punitive. Allyant's country by country review found no verified fine issued under a national EAA law by June 2026. What did happen: in November 2025 France's consumer authority, the DGCCRF, issued formal notices to Auchan, Carrefour, E.Leclerc and Picard after inspections found inaccessible checkout flows, inaccessible product browsing and missing accessibility statements, and emergency injunctions were filed at the Paris commercial court on 12 November 2025. In Germany, enforcement is running through competitor warning letters (Abmahnungen) under unfair competition rules. The Dutch ACM sent information requests to companies selling to Dutch consumers and scheduled audits for spring 2026, and Sweden's PTS opened e-commerce cases after more than 120 public complaints. The pattern is clear: large retailers first, checkout and product pages first, and a missing statement is the easiest finding of all.
A practical compliance plan
- Confirm scope. Do you sell to EU consumers? Are you a microenterprise (fewer than 10 staff and EUR 2 million or less)? If exempt, decide whether to comply anyway; EU customers, procurement and US risk all push the same way.
- Inventory the customer journey. Home, category, product, cart, checkout, account, order confirmation, the emails, and any PDF invoices or manuals published after June 2025.
- Run an automated scan on each. The free scan reports the machine-detectable failures with the exact elements. Automated tools find roughly two fifths of barriers, so this is the start, not the audit.
- Fix the high frequency items first. Contrast (test any pair with the contrast checker), alt text (the alt text checker lists every image), form labels, focus visibility, and keyboard operation of menus, carousels and the checkout.
- Test manually. Keyboard only, then a screen reader (NVDA on Windows, VoiceOver on macOS and iOS), on the checkout above all, since that is where the French notices landed.
- Document. Publish the Annex V information as an accessibility statement with known limitations and a contact; if you rely on disproportionate burden, write and date the Annex VI assessment.
- Fix the supply chain. Payment providers, booking engines, chat, reviews and cookie banners are third party content under your control when you chose them; require accessibility conformance reports from vendors.
- Monitor. Schedule re-scans so that a theme update in March does not undo the work you did in January.
EAA versus ADA at a glance
| Aspect | European Accessibility Act | ADA Title III (US) |
|---|---|---|
| Who | Businesses selling listed products and services to EU consumers, wherever established | Businesses operating places of public accommodation; courts differ on online only businesses |
| Standard | EN 301 549, i.e. WCAG 2.1 AA for web | No statutory standard; courts and DOJ use WCAG 2.1 AA |
| Enforced by | National market surveillance authorities, plus consumer and NGO complaints | Private lawsuits (5,000+ in 2025), DOJ in rare cases |
| Consequence | Fines set nationally (EUR 40,000 to 100,000 typical maxima), withdrawal orders, Ireland criminal liability | Injunction plus attorney's fees; state law damages (Unruh: $4,000 minimum per violation) |
| Small business relief | Microenterprises exempt for services | None specific to websites |
Check your site against the EAA baseline
Free 30 second WCAG scan of any page: score, the failing elements and their code. Covers the same criteria EN 301 549 points at.
Scan my site free →Frequently asked questions
When did the European Accessibility Act come into force?
Directive (EU) 2019/882 was adopted in April 2019, member states had to transpose it by 28 June 2022, and the national laws apply from 28 June 2025. A transition period for existing service contracts and for products already in use ends on 28 June 2030; self service terminals already in use may stay in service for up to 20 years.
Does the EAA apply to companies outside the EU?
Yes, if they provide a service in scope to consumers in the EU. The directive is about where the consumer is, not where the company is registered. A US or UK online store selling to shoppers in Germany or France is providing an e-commerce service in the Union and must meet the requirements or fall under an exemption.
Who is exempt from the European Accessibility Act?
Microenterprises providing services are exempt: fewer than 10 persons employed and annual turnover or balance sheet total of EUR 2 million or less. Microenterprises that sell products are not exempt. Any operator may limit compliance where it would be a disproportionate burden or a fundamental alteration, but must document an assessment under Annex VI and keep it for five years. Some content is excluded, such as PDFs and videos published before 28 June 2025 and archives.
What standard does the EAA use for websites?
EN 301 549, the European harmonised standard for ICT accessibility. Its web clause incorporates the WCAG 2.1 Level AA success criteria, so meeting WCAG 2.1 AA gives a presumption of conformity for web content. WCAG 2.2 AA is a superset and a sensible target for new work.
What are the penalties for not complying with the EAA?
Each member state sets its own. Published maxima include EUR 100,000 in Germany, EUR 60,000 and/or up to 18 months imprisonment in Ireland, EUR 50,000 in France and up to 5 percent of turnover in Italy for companies already under the Stanca law. Authorities can also order a non compliant service to be withdrawn. As of mid 2026 enforcement had consisted of formal notices, information requests and competitor warning letters rather than published fines.
Does the EAA require an accessibility statement?
Article 13(2) requires service providers to prepare and publish information, following Annex V, explaining how the service meets the accessibility requirements, in the general terms and conditions or an equivalent document, in an accessible format. A public accessibility statement with known limitations and a contact is the usual way to meet it, and the missing statement was one of the findings in the French notices of November 2025.
Sources
- Directive (EU) 2019/882 on the accessibility requirements for products and services (European Accessibility Act), EUR-Lex: https://eur-lex.europa.eu/eli/dir/2019/882/oj
- W3C WAI, Web Accessibility Laws and Policies: European Union (EN 301 549 and WCAG): https://www.w3.org/WAI/policies/european-union/
- ETSI EN 301 549 V3.2.1 (2021-03), Accessibility requirements for ICT products and services: https://www.etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf
- Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies: https://eur-lex.europa.eu/eli/dir/2016/2102/oj
- Level Access, EAA Penalties: Fines for Non-Compliance (Germany, France, Italy): https://www.levelaccess.com/blog/penalties-for-eaa-non-compliance/
- WebYes, EAA Fines, Penalties and Sanctions for Each EU Country (Ireland up to EUR 60,000 and/or 18 months): https://www.webyes.com/blogs/eaa-fines/
- Allyant, EAA Enforcement News: A Country-by-Country Look, Year One: https://allyant.com/blog/eaa-enforcement-news/
- W3C, Web Content Accessibility Guidelines (WCAG) 2.2: https://www.w3.org/TR/WCAG22/
- GOV.UK accessibility blog, What we found when we tested tools on the world's least-accessible webpage (best tool found 41 percent of 143 barriers): https://accessibility.blog.gov.uk/2017/02/24/what-we-found-when-we-tested-tools-on-the-worlds-least-accessible-webpage/
- ADA.gov, First Steps Toward Complying with the Title II Web and Mobile Application Accessibility Rule (WCAG 2.1 AA; 26 April 2027 and 2028): https://www.ada.gov/resources/web-rule-first-steps/
- California Civil Code section 52 (Unruh Act statutory damages): https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV§ionNum=52