EU accessibility legislation
European Accessibility Act (EAA)
Directive 2019/882 on the accessibility requirements for products and services. Applicable to private sector organizations from 28 June 2025, it mandates EN 301 549 conformance for e-commerce, banking, transport, telecom, audiovisual services, and e-books across the EU single market.
What is European Accessibility Act (EAA)?
The European Accessibility Act (EAA), formally Directive 2019/882, entered into force on 28 June 2019 and became applicable from 28 June 2025. It establishes common EU-wide accessibility requirements for a wide range of consumer-facing products and services. Unlike the earlier Web Accessibility Directive (2016/2102) which targeted public sector websites only, the EAA explicitly covers private sector organizations operating in the EU single market. The directive uses the principle of 'functional accessibility requirements' — services must be accessible in practice, not just technically compliant — with EN 301 549 as the referenced technical standard for digital services.
The EAA applies to: (1) e-commerce services (online shops selling goods/services to EU consumers); (2) banking and financial services (online banking, payment services, consumer credit); (3) transport services (booking, ticketing, real-time information for air, rail, bus, waterborne); (4) electronic communications (telephony, messaging services, IPTV); (5) audiovisual media services (on-demand video platforms subject to AVMS Directive); (6) e-books and dedicated reading software; (7) relevant computer operating systems and hardware. There are exemptions for micro-enterprises (fewer than 10 employees and annual turnover/balance sheet below €2 million), and a 'disproportionate burden' escape clause.
Member states transposed the EAA into national law by June 2022 and enforcement mechanisms apply from June 2025. Market surveillance authorities in each EU member state enforce compliance and can impose sanctions. Penalties vary by country — some member states have set fines up to €100,000 per infraction. Products placed on the market before June 2025 have a transition period until June 2030 ('service provider transition'). The EAA references EN 301 549 as the harmonized standard for digital services; EN 301 549 v4.1.1 (October 2026) will be the first version harmonized to EAA requirements.
Key criteria
The 10 requirements most frequently flagged in automated audits by scan-access.com.
- Art. 4
Accessibility requirements — General
Products and services must meet the functional accessibility requirements listed in Annex I, using EN 301 549 as the primary technical reference for digital content.
- Annex I §1
General requirements for web-based services
Web-based services must provide perceivable, operable, understandable, and robust content (POUR principles). WCAG 2.1 AA criteria apply via EN 301 549.
- Art. 14
Disproportionate burden exemption
Organizations can invoke 'disproportionate burden' when compliance costs are excessive relative to their size, resources, and the estimated benefit to disabled users. Documented assessment required.
- Art. 13
Conformity assessment by service providers
Service providers must assess their services against EAA requirements and document the results. Self-assessment is acceptable; third-party audit recommended for high-risk sectors.
- Art. 20
Market surveillance and enforcement
Member states designate market surveillance authorities. They can inspect services, demand documentation, and impose sanctions. Consumers must have access to complaint and enforcement procedures.
- Art. 5
Micro-enterprise exemption
Micro-enterprises providing services (fewer than 10 employees and annual revenue below €2 million) are exempt from EAA requirements but encouraged to comply voluntarily.
- Annex I §2
Requirements for mobile services
Mobile apps providing EAA-covered services must meet EN 301 549 Chapter 11 (non-web software) requirements in addition to web requirements.
- Art. 7
Free movement clause
Member states cannot restrict placing accessible products/services on the market solely on accessibility grounds, provided they meet EAA requirements — supports single market harmonization.
- Art. 31
Transition period for existing contracts
Service contracts concluded before 28 June 2025 must be updated to meet EAA requirements by 28 June 2030 at the latest.
- EN 301 549 v4.1.1
Harmonized technical standard (October 2026)
EN 301 549 v4.1.1, expected in October 2026, will be the first version harmonized to EAA requirements. It will reference WCAG 2.2 AA and update real-time text requirements.
How scan-access.com covers European Accessibility Act (EAA)
scan-access.com coverage
Demonstrate EAA compliance with automated accessibility scanning
EAA compliance for digital services requires conformance with EN 301 549, which references WCAG 2.1 AA for web content. scan-access.com automates the detection of ~35% of WCAG/EN 301 549 web violations, covering the highest-risk categories: contrast failures, missing alt text, form errors, ARIA misuse, and structural issues. For EAA sectors with high legal exposure (e-commerce checkout, online banking flows), the legal-defense PDF provides timestamped, hash-signed audit evidence. This is the documentation that market surveillance authorities and legal counsel expect to see. Pair automated scanning with a manual audit to reach full EN 301 549 Chapter 9 coverage.
Free scan against European Accessibility Act (EAA). No account required.
Frequently asked questions
When did the EAA take effect?
The EAA Directive 2019/882 was published in June 2019. Member states had until June 2022 to transpose it into national law. Enforcement obligations for private sector organizations apply from 28 June 2025. Products and services already on the market before that date have a transition period until 28 June 2030.
Who must comply with the EAA?
Private sector organizations providing the following in the EU must comply: e-commerce services, banking and financial services, transport services (ticketing, real-time info), electronic communications (telephony, messaging), audiovisual media (on-demand video), and e-books. Micro-enterprises (< 10 employees, < €2M revenue) are exempt. The 'disproportionate burden' clause can apply if full compliance costs are grossly disproportionate to the benefit.
What are the EAA fines and penalties?
Penalties vary by member state, as each country sets its own sanction regime. Fines can reach €50,000 to €100,000 or more per infraction in some member states, with additional daily fines for continued non-compliance. Market surveillance authorities can also require product/service withdrawal from the market. Legal counsel in the relevant country should be consulted for specific national enforcement rules.
Is the EAA the same as EN 301 549?
No. The EAA is a legal directive setting accessibility obligations for private sector products and services. EN 301 549 is the technical standard specifying how to meet those obligations. EN 301 549 v3.2.1 is the current reference standard. EN 301 549 v4.1.1 (October 2026) will be the first version harmonized to EAA requirements in the Official Journal.
Does the EAA apply to non-EU companies?
The EAA applies to services made available to EU consumers, regardless of where the service provider is headquartered. A US or UK e-commerce company selling to French or German consumers must comply with EAA requirements for those services. The relevant enforcement authority is in the member state where the consumer is located.