European Accessibility Act (EAA) — Directive (EU) 2019/882…

Do our consumer products and digital services meet the new EU accessibility requirements that became enforceable on 28 June 2025 — and what happens if they do not?

Every manufacturer, importer and service provider placing consumer hardware, self-service terminals, e-commerce platforms or banking services on the EU market must comply with Annex I accessibility requirements since 28 June 2025, with Member States required to impose effective, proportionate and dissuasive penalties for non-compliance [Art. 30].

Short Answer

The European Accessibility Act (Directive (EU) 2019/882) harmonises accessibility requirements across the internal market for a defined set of consumer products and services [Art. 1]. Products covered include general purpose computer hardware and operating systems, self-service terminals (payment terminals, ATMs, ticketing and check-in machines), consumer terminal equipment for electronic communications and audiovisual media, and e-readers [Art. 2(1)]. Services covered include electronic communications, audiovisual media access services, elements of air, bus, rail and waterborne passenger transport, consumer banking services, e-books and e-commerce [Art. 2(2)]. Non-compliant products may be withdrawn from the market by surveillance authorities [Art. 20], and service providers face enforcement action including court proceedings initiated by consumers or representative organisations [Art. 29].

Who is affected

Manufacturers, authorised representatives, importers and distributors of the listed consumer products, as well as providers of the listed services, operating in the EU internal market [Art. 2]. Microenterprises (fewer than 10 employees and annual turnover or balance sheet not exceeding EUR 2 million) providing services are fully exempt [Art. 4(5)]. Microenterprises dealing with products have lighter documentation obligations but are not fully exempt [Art. 14(4)]. SMEs (fewer than 250 employees, turnover not exceeding EUR 50 million or balance sheet not exceeding EUR 43 million) must comply but may invoke the disproportionate burden exception under Art. 14.

Deadline

28 June 2025 — all covered products placed on the market and services provided to consumers after this date must comply [Art. 31(2)]. Transitional period: service providers may continue using products lawfully in use before 28 June 2025 until 28 June 2030 [Art. 32(1)]. Self-service terminals lawfully in use before 28 June 2025 may be used until the end of their economically useful life, but no longer than 20 years after entry into use [Art. 32(2)]. Member States may defer obligations under Art. 4(8) until 28 June 2027 at the latest [Art. 31(3)].

Risk

The Directive does not prescribe a specific EU-wide fine ceiling; instead, Member States must lay down penalties that are effective, proportionate and dissuasive [Art. 30(1)-(2)]. Penalties must take into account the extent of non-compliance, its seriousness, the number of non-complying units and the number of persons affected [Art. 30(4)]. Beyond fines, market surveillance authorities can require corrective action, restrict market availability or order product withdrawal [Art. 20]. Consumers and representative organisations have standing to bring enforcement actions before courts or administrative bodies [Art. 29(2)].

Proof

Legal status

• In force
• as of 2026-05-05
• Original version as published in OJ L 151, 7.6.2019

Primary sources

• EUR-Lex — Full text of the legal act
• European Commission — Accessibility — EU accessibility policy

What to do now

Legal / DPO

•Map all products and services your organisation offers against the scope catalogue in Art. 2(1) and Art. 2(2) to determine which fall under the EAA, and document the analysis for market surveillance purposes [Art. 12].
•Assess whether the disproportionate burden or fundamental alteration exception under Art. 14 applies to any product or service, document the assessment with reference to the criteria in Annex VI, and retain records for at least five years [Art. 14(2)-(3)].
•Ensure that service contracts agreed before 28 June 2025 are flagged for the transitional expiry under Art. 32(1) — they may continue unaltered only until they expire or until 28 June 2030, whichever comes first.

Compliance

•Establish a conformity assessment process for products per Annex IV and prepare the EU declaration of conformity per Art. 16, ensuring the CE marking is correctly affixed before placing products on the market [Art. 18].
•Set up internal monitoring procedures to verify that services remain in continuous conformity with applicable Annex I requirements, including after any changes to the service or to harmonised standards [Art. 13(3)].
•Implement a complaints and non-compliance tracking process as required by the Member State authorities responsible for checking compliance of services [Art. 23(1)(b)].

IT / Security

•Audit all consumer-facing digital services — websites, mobile applications and e-commerce platforms — against the accessibility requirements in Section III and Section IV of Annex I, focusing on perceivable, operable and understandable design [Art. 4(3)].
•Verify that self-service terminals (payment terminals, ATMs, ticketing machines, check-in machines, interactive kiosks) meet the hardware and software accessibility requirements of Section I and Section II of Annex I [Art. 4(2)].
•Integrate accessibility testing into the product release pipeline so that updates to consumer terminal equipment and operating systems do not regress compliance with Annex I requirements [Art. 7(2)].

Product / Engineering

•Apply universal design principles from the outset for all new consumer products to meet the functional accessibility requirements of Annex I, documenting design decisions in the technical documentation per Annex IV [Art. 7(1)].
•Evaluate existing self-service terminals against the transitional provisions: terminals in use before 28 June 2025 may continue under Art. 32(2) but new deployments must fully comply — plan fleet renewal accordingly.
•Ensure product packaging and instructions include accessibility information in formats perceivable by persons with disabilities, as required by Section VII of Annex I [Art. 7(3)].

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Key Terms

Accessibility requirements: Mandatory functional requirements set out in Annex I of the Directive, covering information provision, user interface design, support services and product packaging, aimed at making products and services perceivable, operable and understandable for persons with disabilities.
Microenterprise: An enterprise employing fewer than 10 persons with annual turnover or annual balance sheet not exceeding EUR 2 million [Art. 3(23)]. Microenterprises providing services are fully exempt from the EAA service requirements.
Disproportionate burden: An exception under Art. 14 allowing economic operators not to comply with accessibility requirements to the extent compliance would impose an excessive organisational or financial burden, assessed against the criteria in Annex VI.
Fundamental alteration: An exception under Art. 14(1)(a) allowing non-compliance where meeting accessibility requirements would require a significant change resulting in a fundamental alteration of the basic nature of the product or service.
CE marking: A marking affixed to products indicating conformity with applicable EU harmonisation legislation, including the accessibility requirements of this Directive. Governed by the general principles of Art. 30 of Regulation (EC) No 765/2008 [Art. 17].
EU declaration of conformity: A formal document drawn up by the manufacturer stating that the product fulfils applicable accessibility requirements, following the model structure of Annex III to Decision No 768/2008/EC [Art. 16].
Harmonised standard: A European standard adopted on the basis of a request by the Commission under Regulation (EU) No 1025/2012. Products and services conforming to relevant harmonised standards benefit from a presumption of conformity with the accessibility requirements [Art. 15(1)].

Frequently Asked Questions

Which products fall under the European Accessibility Act?

Consumer general purpose computer hardware and their operating systems, self-service terminals (payment terminals, ATMs, ticketing machines, check-in machines, interactive information kiosks), consumer terminal equipment for electronic communications and audiovisual media services, and e-readers placed on the market after 28 June 2025 [Art. 2(1)].

Which services fall under the European Accessibility Act?

Electronic communications services (except M2M), services providing access to audiovisual media, elements of air, bus, rail and waterborne passenger transport services, consumer banking services, e-books and their dedicated software, and e-commerce services provided to consumers after 28 June 2025 [Art. 2(2)].

Are microenterprises exempt from the EAA?

Microenterprises providing services (fewer than 10 employees and annual turnover or balance sheet not exceeding EUR 2 million) are fully exempt from the service accessibility requirements [Art. 4(5)]. Microenterprises dealing with products are not fully exempt but have lighter documentation duties — they need not document the disproportionate burden assessment unless requested by authorities [Art. 14(4)].

What is the disproportionate burden exception?

Under Art. 14, economic operators need not comply with accessibility requirements to the extent that compliance would fundamentally alter the product or service or impose a disproportionate burden. The assessment must follow the criteria in Annex VI, be documented and retained for at least five years. Service providers must renew the assessment at least every five years or when the service changes [Art. 14(5)]. Operators receiving external funding for accessibility may not invoke the disproportionate burden exception [Art. 14(6)].

What are the transitional provisions for existing products and services?

Service providers may continue using products lawfully in use before 28 June 2025 to provide similar services until 28 June 2030 [Art. 32(1)]. Service contracts agreed before 28 June 2025 may run without alteration until they expire, but no longer than five years from that date [Art. 32(1)]. Self-service terminals in use before 28 June 2025 may continue until the end of their economically useful life, up to a maximum of 20 years after entry into use [Art. 32(2)].

What penalties apply for non-compliance with the EAA?

The Directive does not set a specific EU-wide fine amount. Member States must establish penalties that are effective, proportionate and dissuasive, accompanied by effective remedial action [Art. 30(2)]. Penalties must account for the seriousness of non-compliance, the number of non-complying units and the number of affected persons [Art. 30(4)]. Additionally, non-compliant products may be withdrawn from the market [Art. 20].

How does the EAA interact with public procurement rules?

The accessibility requirements of Annex I constitute mandatory accessibility requirements for public procurement under Art. 42(1) of Directive 2014/24/EU and Art. 60(1) of Directive 2014/25/EU [Art. 24(1)]. However, the enforcement and penalty provisions of the EAA do not apply to procurement procedures [Art. 29(3), Art. 30(5)].

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