European Accessibility Act — Accessibility Requirements for

Which of our digital products and services must be accessible by 28 June 2025 — and what happens if they are not?

Any company placing consumer hardware, self-service terminals, e-commerce, banking or electronic communications services on the EU market must comply with harmonised accessibility requirements since 28 June 2025; non-compliance triggers Member State penalties that must be effective, proportionate and dissuasive, and market surveillance authorities can order product withdrawal [Art. 30, Art. 20].

Short Answer

Directive (EU) 2019/882 establishes binding accessibility requirements for a defined list of products (computers, self-service terminals, e-readers, consumer terminal equipment) and services (e-commerce, consumer banking, electronic communications, audiovisual media access, passenger transport ticketing, e-books) [Art. 2]. Economic operators — manufacturers, importers, distributors and service providers — each carry specific compliance obligations including conformity assessment, CE marking, EU declaration of conformity and ongoing monitoring [Art. 7, Art. 9, Art. 10, Art. 13]. Microenterprises providing services are exempt from the service accessibility requirements, but microenterprises manufacturing or distributing products are not [Art. 4(5)]. An economic operator may invoke a disproportionate burden defence only after a documented assessment under Annex VI criteria — and must renew that assessment at least every five years [Art. 14].

Who is affected

Manufacturers, importers and distributors of consumer hardware systems, self-service terminals (payment terminals, ATMs, ticketing machines, check-in machines, information kiosks), e-readers and consumer terminal equipment for electronic communications or audiovisual media services [Art. 2(1)]. Service providers offering electronic communications, audiovisual media access, e-commerce, consumer banking, e-book platforms or passenger transport digital services (websites, mobile apps, e-ticketing) [Art. 2(2)]. Microenterprises providing services (fewer than 10 employees and annual turnover or balance sheet total not exceeding EUR 2 million) are exempt from service accessibility requirements [Art. 4(5), Art. 3(23)].

Deadline

The Directive has been applicable since 28 June 2025 — all products placed on the market and services provided after that date must comply. Next milestone: Member States may defer the obligation for accessible emergency communications to the single European emergency number 112 until 28 June 2027 at the latest [Art. 31(3)]. Transitional period: service providers may continue using pre-existing products until 28 June 2030; self-service terminals lawfully in use before 28 June 2025 may continue until end of economic useful life, but no longer than 20 years after entry into use [Art. 32].

Risk

Penalties are set by each Member State and must be effective, proportionate and dissuasive [Art. 30(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)]. Market surveillance authorities can require corrective action, restrict or prohibit the making available of non-compliant products, and order product withdrawal from the market [Art. 20]. For services, designated national authorities can require cessation of non-compliant service provision [Art. 23]. In Germany, the implementing law (BFSG) provides for fines of up to EUR 100,000.

Proof

Legal status

• In force
• as of 2026-04-17
• 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

•Verify which products and services in your portfolio fall within the Directive's scope by checking the exhaustive lists in Art. 2(1) for products (consumer hardware, self-service terminals, e-readers, terminal equipment) and Art. 2(2) for services (e-commerce, banking, electronic communications, audiovisual media, transport ticketing, e-books) [Art. 2].
•Document any reliance on the disproportionate burden or fundamental alteration exemption with a written assessment meeting the Annex VI criteria; retain the assessment for five years and renew it at least every five years or upon service alteration [Art. 14(2), Art. 14(3), Art. 14(5)].
•Review service contracts agreed before 28 June 2025 — they may continue unamended only until expiry and no longer than five years from that date (i.e. 28 June 2030); plan contract renewals to include accessibility clauses [Art. 32(1)].

Compliance

•Establish an internal conformity assessment process under Annex IV (Module A — Internal Production Control) for every product in scope, ensuring CE marking is affixed and the EU declaration of conformity is drawn up before placing on the market [Art. 7(2), Art. 18].
•Build a monitoring procedure so that any change to product design, harmonised standards or technical specifications triggers a re-assessment of series production conformity [Art. 7(4)].
•For services, prepare and publicly disclose the information required by Annex V explaining how each service meets the applicable accessibility requirements, and keep that information current for the lifetime of the service [Art. 13(2)].

IT / Security

•Audit all customer-facing digital products (websites, mobile applications, e-commerce checkout flows, self-service terminal interfaces) against the accessibility requirements in Section I and Section II of Annex I — especially perceivability, operability and understandability via multiple sensory channels [Art. 4(2), Annex I].
•Ensure consumer terminal equipment with interactive computing capability provides information through more than one sensory channel, is operable via assistive technologies and offers adjustable presentation options including font size, contrast and spacing [Annex I, Section I].
•Implement automated accessibility testing in the CI/CD pipeline to detect regressions against EN 301 549 requirements before each release, ensuring continued conformity as required by Art. 7(4) and Art. 13(3) [Art. 7(4), Art. 13(3)].

Product / Engineering

•Map every self-service terminal in the estate (payment terminals, ATMs, ticketing machines, check-in machines, information kiosks) — terminals placed on the market after 28 June 2025 must comply; those already in use may continue until end of economic useful life but no longer than 20 years [Art. 2(1)(b), Art. 32(2)].
•Integrate Annex I Section I accessibility requirements into the product design specification: information must be available via visual, auditory and tactile channels; user interface and functionality design must include accessible modes of operation [Annex I, Section I].
•For e-commerce services, ensure the identification, description and images of products, the checkout and payment process and the delivery information are provided in accessible formats meeting Section III of Annex I [Art. 2(2)(f), Annex I, Section III].

Key Terms

European Accessibility Act (EAA): Directive (EU) 2019/882 establishing harmonised accessibility requirements for specified products and services across the EU internal market, adopted under Article 114 TFEU.
Accessibility requirements: Mandatory design and performance criteria set out in Annex I that products and services must fulfil to be usable by persons with disabilities, including perceivability, operability and understandability requirements.
Economic operator: The manufacturer, authorised representative, importer, distributor or service provider — each bearing distinct obligations under the Directive [Art. 3].
Microenterprise: An enterprise employing fewer than 10 persons with annual turnover or balance sheet total not exceeding EUR 2 million; exempt from service accessibility requirements but not from product obligations [Art. 3(23), Art. 4(5)].
Disproportionate burden: A defence available to economic operators where compliance would impose costs disproportionate to the benefit, assessed against Annex VI criteria (cost-to-turnover ratio, overall expenditure); must be documented and reassessed at least every five years [Art. 14].
Fundamental alteration: A change to the basic nature of a product or service so significant that the accessibility requirements need not be applied; must be assessed on a case-by-case basis and documented [Art. 14(1)(a)].
CE marking: A conformity marking affixed to products indicating that the manufacturer has verified compliance with applicable EU harmonisation legislation, including the accessibility requirements of this Directive [Art. 17, Art. 18].
EU declaration of conformity: A document drawn up by the manufacturer stating that the product meets applicable accessibility requirements; structured per Annex III of Decision 768/2008/EC and continuously updated [Art. 16].
Self-service terminal: An interactive device providing services to the general public — including payment terminals, ATMs, ticketing machines, check-in machines and information kiosks — that must be accessible to persons with disabilities [Art. 2(1)(b)].
Harmonised standard: A European standard adopted by a recognised European standardisation organisation on the basis of a Commission request; products or services conforming to it benefit from a presumption of conformity with the Directive [Art. 15(1)].

Frequently Asked Questions

Does the European Accessibility Act apply to microenterprises?

Microenterprises (fewer than 10 employees, turnover or balance sheet not exceeding EUR 2 million) are fully exempt from service accessibility requirements [Art. 4(5)]. However, microenterprises manufacturing, importing or distributing products in scope are NOT exempt — they must comply with all product obligations including CE marking and conformity assessment. They are only relieved from documenting their disproportionate burden assessment unless requested by market surveillance authorities [Art. 14(4)].

What products are covered by the Directive?

Five product categories: (a) consumer general-purpose computer hardware and their operating systems, (b) self-service terminals — payment terminals, ATMs, ticketing machines, check-in machines, interactive information terminals (excluding those integrated into vehicles, aircraft, ships or rolling stock), (c) consumer terminal equipment for electronic communications, (d) consumer terminal equipment for audiovisual media services, and (e) e-readers [Art. 2(1)].

What services are covered by the Directive?

Six service categories: (a) electronic communications services (excluding machine-to-machine), (b) services providing access to audiovisual media, (c) certain elements of passenger transport services (websites, apps, e-tickets, information delivery, self-service terminals), (d) consumer banking services, (e) e-books and dedicated software, and (f) e-commerce services [Art. 2(2)].

Can an economic operator claim a disproportionate burden exemption?

Yes, but only after conducting and documenting a formal assessment against the criteria in Annex VI — including the ratio of compliance costs to overall costs and turnover. The assessment must be retained for five years and renewed at least every five years or when the service changes. If the operator received public or private funding specifically for accessibility, the exemption cannot be invoked [Art. 14].

How long can existing self-service terminals remain in use?

Self-service terminals lawfully used before 28 June 2025 may continue in service until the end of their economically useful life, but no longer than 20 years after their entry into use [Art. 32(2)]. New terminals placed on the market after 28 June 2025 must comply immediately.

What conformity assessment procedure applies?

The Directive prescribes Module A (Internal Production Control) from Decision No 768/2008/EC. Manufacturers draw up technical documentation, carry out the assessment, issue an EU declaration of conformity and affix the CE marking [Art. 7(2), Annex IV]. No third-party certification body is required.

Does the Directive apply to the built environment?

Not mandatorily at EU level. However, Member States may decide that the built environment used by clients of covered services must comply with the accessibility requirements set out in Annex III [Art. 4(4)]. Check your national transposition law for this extension.

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