European Accessibility Act (EAA) 2025: What EU Businesses Must Do

What Is the European Accessibility Act?

The EAA (Directive 2019/882) is an EU-wide law that establishes common accessibility requirements for key products and services. Unlike the EU Web Accessibility Directive (which targets public sector websites), the EAA applies to private sector businesses that provide covered products and services in the EU market.

The EAA was adopted in 2019, and member states had until June 28, 2022, to transpose it into national law. Enforcement began on June 28, 2025, meaning businesses must now be compliant.

Products and Services Covered by the EAA

The EAA covers a broad range of products and services:

• E-commerce websites and mobile apps — any online store selling products or services to EU consumers.
• Banking and financial services — online banking, payment terminals, and ATMs.
• Telecommunications — phone services, smartphones, and related equipment.
• Transport services — ticketing, check-in systems, and real-time travel information for air, bus, rail, and waterborne travel.
• E-books and e-readers — digital reading platforms and devices.
• Audiovisual media services — streaming platforms and electronic program guides.
• Computers and operating systems — consumer hardware and software.

The Technical Standard: EN 301 549

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 and adds additional requirements for software, hardware, documentation, and support services.

For website and web application compliance, meeting WCAG 2.1 AA is the practical baseline. If your site already meets WCAG 2.1 AA for ADA compliance, you are largely covered for the web content portion of the EAA as well. However, the EAA's scope extends beyond web content to include support services, documentation, and the usability of the overall service offering.

Start by scanning your website against WCAG 2.1 AA to establish your current compliance baseline.

Who Must Comply?

The EAA applies to businesses of all sizes that place covered products on the EU market or provide covered services to EU consumers. This includes:

• Manufacturers of covered products sold in the EU
• Importers and distributors of covered products
• Service providers offering covered services to EU consumers
• Non-EU businesses that sell to or serve EU customers online

Microenterprises (fewer than 10 employees and annual turnover or balance sheet under 2 million euros) providing services are exempt from the EAA. However, they are still subject to the EU Web Accessibility Directive if they operate in the public sector, and national laws may impose additional requirements.

Penalties and Enforcement

Each EU member state sets its own penalties for EAA non-compliance, which must be “effective, proportionate, and dissuasive.” Enforcement mechanisms include:

• Market surveillance authorities in each member state monitor compliance and can order corrective actions.
• Fines and penalties vary by country but can be significant. Germany, France, and the Netherlands have established penalty frameworks.
• Product withdrawal from the EU market may be ordered for non-compliant products.
• Consumer complaints can trigger investigations by national enforcement bodies.

EAA vs. ADA: Key Differences

• Scope: The ADA focuses on places of public accommodation and government entities. The EAA targets specific product and service categories across the private sector.
• Standard: Both effectively reference WCAG 2.1 AA for web content, but the EAA uses EN 301 549 which adds non-web requirements.
• Enforcement: The ADA relies heavily on private litigation. The EAA uses regulatory enforcement through national market surveillance authorities.
• Exemptions: The EAA exempts microenterprises providing services. The ADA has no similar blanket exemption.

How to Prepare for EAA Compliance

1. Determine if you are in scope. Review the list of covered products and services. If you sell to or serve EU consumers in any covered category, the EAA applies.
2. Audit your web presence. Use ADA Scanner to test against WCAG 2.1 AA. This covers the web content requirements of EN 301 549.
3. Review non-web touchpoints. Customer support channels, documentation, mobile apps, and physical products must also meet accessibility requirements.
4. Document your compliance. The EAA requires businesses to maintain technical documentation demonstrating conformity.
5. Set up monitoring. Continuous monitoring ensures your website remains compliant as content and features change.