Accessibility guide

Who Does the European Accessibility Act Apply To?

The European Accessibility Act (EAA) is an EU law that sets common accessibility requirements for a defined list of products and services sold in the EU. It is easy to assume it covers every website, but its scope is specific. This guide explains which products and services are caught, who is exempt, and the deadlines that apply.

Reviewed by the EAA Navigator team

TL;DR

  • The EAA is Directive (EU) 2019/882. Its accessibility requirements have applied since 28 June 2025.
  • It covers a defined list of products (such as computers, smartphones, ATMs, ticketing machines, e-readers and payment terminals) and services (such as e-commerce, consumer banking, e-books, electronic communications and passenger transport).
  • Micro-enterprises providing services are exempt; the exemption does not extend to micro-enterprises that make products.
  • Existing service contracts may continue until 28 June 2030; self-service terminals already in use may run to the end of their useful life, up to a maximum of 20 years.
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In this guide

What this covers

  • The list of products in scope: computers and operating systems, smartphones and other communication devices, TV equipment for digital television, ATMs, ticketing and check-in machines, e-readers and payment terminals.
  • The list of services in scope: e-commerce, consumer banking, e-books and dedicated software, electronic communications, access to audiovisual media services, and air, bus, rail and waterborne passenger transport services.
  • The micro-enterprise exemption and exactly how far it reaches.
  • The application date and the transition periods for existing contracts and terminals.

What matters

Key points

  • Scope is defined by product and service categories, not by "any website". An e-commerce service is squarely in scope; a brochure-only site that sells nothing may not be — though other laws can still apply.
  • The micro-enterprise exemption is narrow: it applies to micro-enterprises providing services (fewer than 10 staff and turnover or balance sheet of €2 million or less). Micro-enterprises that place products on the market are not exempt.
  • Conformance is demonstrated through the harmonised standard EN 301 549, which incorporates WCAG 2.1 Level AA for web and mobile content.
  • Penalties are set by each member state and must be effective, proportionate and dissuasive. There is no single EU-wide figure.

Across web accessibility, Level AA of WCAG 2.2 is the working target, and for the EU it is incorporated into the harmonised standard EN 301 549.

What to do

What to do next

  1. List your products and services and match each against the EAA categories above.
  2. Check whether any micro-enterprise exemption genuinely applies to you, remembering it only covers services.
  3. If you provide an in-scope service such as e-commerce, treat WCAG 2.1 AA (via EN 301 549) as your working target.
  4. Map the transition periods to your situation: most requirements apply from 28 June 2025, with limited continuation for existing contracts and terminals.
  5. Prepare the accessibility information the EAA expects you to make available, and plan an audit if you have not tested your site.

For the standard itself, see the WCAG explainer; to put it into practice, work through the WCAG 2.2 AA checklist.

FAQ

Common questions

Does the EAA apply to every website?
No. The EAA applies to a defined list of products and services. Many websites are caught because they provide an in-scope service such as e-commerce, consumer banking or electronic communications, but a site that does not provide a listed service may fall outside the EAA, even if other accessibility laws still apply.
Are small businesses exempt from the EAA?
Only micro-enterprises providing services are exempt: those with fewer than 10 employees and an annual turnover or balance sheet total of €2 million or less. Micro-enterprises that manufacture or place products on the market do not get this exemption, and small businesses above the micro thresholds are not exempt.
When did the EAA start to apply?
The directive was adopted on 17 April 2019. Member states had to transpose it by 28 June 2022, and its requirements have applied since 28 June 2025.
Is e-commerce covered by the EAA?
Yes. E-commerce is explicitly listed as a service in scope, so online shops selling to EU consumers generally need to meet the accessibility requirements unless a specific exemption applies.
What standard do I have to meet?
Conformance is shown through the harmonised standard EN 301 549, which for web and mobile incorporates WCAG 2.1 Level AA. Meeting WCAG 2.1 AA gives a presumption of conformity for the digital parts of an in-scope service.

Make your site accessible

Start with the WCAG 2.2 AA checklist, then work through the guides to fix what you find.

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This is guidance, not legal advice

This guide is here to help you understand web accessibility and how WCAG, the EAA and the ADA apply in practice. It is not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]Web Content Accessibility Guidelines (WCAG) 2.2 (W3C Recommendation)retrieved 9 Jun 2026
  2. [2]WCAG overview (W3C Web Accessibility Initiative)retrieved 9 Jun 2026
  3. [3]Directive (EU) 2019/882 — European Accessibility Act (EUR-Lex)retrieved 9 Jun 2026
  4. [4]EN 301 549 v3.2.1 — harmonised ICT accessibility standard (ETSI)retrieved 9 Jun 2026
  5. [5]US DOJ ADA Title II web accessibility rule fact sheetretrieved 9 Jun 2026
  6. [6]WebAIM Million 2025 — accessibility of the top 1,000,000 home pagesretrieved 9 Jun 2026
  7. [7]Overlay Fact Sheet — why overlays do not deliver complianceretrieved 9 Jun 2026

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Who Does the EAA Apply To? Scope, Products & Services | EAA Navigator · EAA Navigator