The European Accessibility Act, in plain terms.

The European Accessibility Act (EAA) is EU Directive 2019/882, adopted in April 2019. Each member state was required to transpose it into national law by June 2022 and apply it from June 28, 2025. The Act creates harmonized accessibility requirements across the EU single market for a defined list of products and services.

The EAA targets the private sector specifically. EU public-sector accessibility was already governed by the Web Accessibility Directive (2016/2102), enforceable since 2020 against public-body websites and mobile apps.

The EAA covers products and services placed on the EU market or provided to consumers in the EU — regardless of where the company is headquartered. Non-EU companies selling to EU consumers are in scope.

Products covered:

• Consumer general-purpose computer hardware and operating systems.
• Self-service terminals (ATMs, ticketing machines, check-in kiosks).
• Consumer terminal equipment for telecoms (smartphones, modems).
• Consumer terminal equipment for audiovisual media (smart TVs, set-top boxes).
• E-readers.

Services covered:

• E-commerce services — any online retailer selling to EU consumers.
• Banking services for consumers (online banking, mobile banking apps).
• Electronic communications services (messaging, calls).
• Audiovisual media services access (streaming platforms, TV apps).
• Passenger transport (booking, ticketing, real-time info — air, rail, water, bus).
• E-books and dedicated software.
• Access to emergency services through 112 number.

Microenterprises (fewer than 10 employees and annual turnover/balance ≤ €2 million) providing services are exempt. Microenterprises selling products are not exempt but get simplified procedures.

The EAA does not specify technical requirements directly. Instead, it references "harmonized standards" — and the harmonized standard for web and software accessibility is EN 301 549, currently at version 3.2.1 (published March 2021).

EN 301 549 incorporates WCAG 2.1 Level A and AA in full as the technical requirements for web content, with additional clauses for software, hardware, documents, and ICT-specific accessibility.

Practical implication: conforming to WCAG 2.1 Level AA gets you most of the way to EN 301 549 conformance for web-based services. Conforming to WCAG 2.2 AA (a superset) future-proofs you for the next EN 301 549 revision.

AccessProof scans against WCAG 2.2 and explicitly cross-references EN 301 549 clauses in every report.

E-commerce is the largest category newly in scope. Online retailers selling to EU consumers must:

• Make their website conform to EN 301 549 (effectively WCAG 2.1 AA) — every step of the consumer-facing flow.
• Make their mobile app (if any) conform to EN 301 549 mobile clauses.
• Provide accessibility information about products they sell where applicable (product description must include accessibility features).
• Publish an accessibility statement describing conformance level, known issues, contact mechanism for feedback, and remediation timeline.
• Maintain conformance over time, not just at launch — material updates trigger re-evaluation.

The EAA explicitly applies to the entire purchase journey: browsing, search, product page, cart, checkout, payment, confirmation, customer support. A storefront that audits cleanly but has an inaccessible checkout flow is non-conformant.

Each EU member state sets its own penalty regime under their transposition law. Common patterns:

• Administrative fines — typically €5,000 to €500,000 per violation, depending on member state and severity. Germany, France, Spain, and Italy have published higher tiers for repeat violations.
• Market withdrawal — non-conformant products can be ordered off the EU market by national surveillance authorities.
• Service prohibition — services that cannot demonstrate conformance can be ordered to stop trading in the affected member state.
• Consumer remedies — some member states allow consumers to bring complaints; collective redress mechanisms vary.

Enforcement is per-member-state. A non-conformant retailer selling to France, Germany, and Spain faces parallel enforcement actions, each with its own fine.

The EAA also affects market access: non-conformant products may be denied CE marking equivalence, blocking distribution.

1. Confirm scope — are you selling products or services to EU consumers? Microenterprise exemption applies?
2. Inventory the surface — list every website, mobile app, and digital service that touches EU consumers.
3. Run baseline EN 301 549 audits — AccessProof scans every URL and cross-maps each finding to EN 301 549 clauses + WCAG criteria.
4. Triage by severity — critical and serious WCAG violations first; map remediation timeline.
5. Publish an accessibility statement — required by the EAA. Must describe conformance level, known limitations, contact for feedback, remediation timeline. A model template is available in EN 301 549 Annex A.
6. Establish ongoing audit cadence — material updates trigger re-evaluation. Automated audits per deploy + manual review per quarter is the typical pattern.
7. Train internal teams — designers, developers, content authors. EAA conformance fails most often at the content-author layer (alt text, headings, link text).
8. Document for surveillance authorities — keep dated audit records. National authorities can request evidence of ongoing conformance activity.

The EAA provides limited transition relief:

• Service providers can continue using existing service contracts concluded before June 28, 2025, for up to five years (until June 28, 2030) — but only for those specific contracts.
• Self-service terminals lawfully used before June 28, 2025, can continue to be used until end of their economic useful life, with a cap of 20 years.
• New contracts, new products, and new services launched on or after June 28, 2025, must conform from day one.

Practical interpretation: there is no general grace period for new e-commerce sites or new SaaS services launched after June 2025. The "five-year" relief applies only to specific pre-existing service contracts, not to general operations.