The European Accessibility Act: who must comply, and by when?

Since 28 June 2025, digital accessibility has been a legal obligation for many businesses across the EU. Here is who the EAA applies to, which exemptions exist and what to do now.

What is the European Accessibility Act?

The European Accessibility Act (EAA) is Directive (EU) 2019/882. It requires all EU member states to introduce uniform accessibility requirements for a defined set of products and services. The goal is twofold: people with disabilities should be able to use digital products and services throughout the single market without assistance, and businesses should not have to navigate 27 different national rulebooks.

As a directive, the EAA is transposed into national law by each member state. In Germany, the implementation is the Barrierefreiheitsstärkungsgesetz (BFSG, Accessibility Strengthening Act), complemented by a regulation covering the technical details. Other member states have passed their own implementing acts, all based on the same directive. Unlike earlier rules that mainly targeted the public sector, the EAA puts broad obligations on private businesses for the first time.

Who must comply?

The EAA distinguishes between products and services. Covered products include computers, smartphones, self-service terminals (such as ATMs and ticket machines), e-readers and routers. On the services side, the focus is on digital offerings for consumers:

• E-commerce services – in practice, virtually every online shop and every website where consumers can conclude contracts or book appointments
• Consumer banking services, including online banking
• E-books and the software needed to read them
• Electronic communications services and messengers
• Elements of passenger transport services, such as websites, apps and electronic ticketing
• Access to audiovisual media services, for example streaming platforms

Importantly, what matters is not where your company is based but whether your offering targets consumers in the EU. Businesses outside the EU that sell to EU consumers are in scope too. Pure B2B offerings are not covered – but as soon as consumers can order, book or conclude contracts online, you are generally within scope.

The microenterprise exemption

Microenterprises that provide services are exempt. You count as a microenterprise if you employ fewer than 10 people and your annual turnover or annual balance sheet total does not exceed 2 million euros. Both conditions must be met.

Two caveats are worth knowing:

• The exemption only applies to services. Microenterprises that manufacture, import or distribute covered products must still meet the requirements.
• The exemption does not protect you from the market: barriers cost you customers, reach and visibility – regardless of whether the law applies.

Deadlines at a glance

The transition period until 2030 only covers existing contracts that continue unchanged. As soon as you relaunch your website, substantially change your shop or conclude new contracts with consumers, the requirements apply immediately. For most websites and online shops there is effectively no grace period left.

What are the actual requirements?

The EAA states its requirements functionally: information must be perceivable through more than one sensory channel, understandable and usable with assistive technologies. The technical benchmark is the European standard EN 301 549, which for web content refers to the Web Content Accessibility Guidelines (WCAG) at conformance level AA – currently based on WCAG 2.1.

For your website or shop this means, among other things:

• Sufficient colour contrast and resizable text
• Full keyboard operability
• Alternative text for images and captions for videos
• Understandable forms with clear labels and error messages
• Clean semantic structure that screen readers can interpret

If you are building or rebuilding today, it makes sense to aim for WCAG 2.2 AA straight away – the newer version includes almost all 2.1 criteria and is the future-proof choice.

Market surveillance, fines and legal risk

Compliance is monitored by national market surveillance authorities. They can request evidence, demand corrective measures and, as a last resort, order a service to be discontinued or a product withdrawn from the market. Penalties are set by each member state; in Germany, fines can reach 100,000 euros per violation, and other countries have comparable regimes.

There is a civil-law dimension as well: consumers and recognised organisations can report violations to the authorities and trigger proceedings, and in some member states competitors can take legal action against non-compliant rivals. The financial risk is real – the reputational damage is often greater still.

The accessibility statement

Service providers within scope must inform the public about the accessibility of their service – in their general terms and conditions or in another clearly findable way. This statement describes how the requirements are met and must itself be accessible. It is more than a formality: it shows authorities and users that you take the topic seriously, and it documents where you stand.

Practical first steps

1. Clarify whether you are in scope: Check whether your offerings fall under the EAA and whether the microenterprise exemption applies to you.
2. Take stock: Test your website for accessibility – with automated tools, a keyboard test and a screen reader.
3. Prioritise: Fix the barriers that lock users out completely first, such as missing keyboard support or unlabelled forms in the checkout.
4. Embed processes: Make sure editors and developers consider accessibility from the start – from alt text to component choices.
5. Document: Publish your accessibility statement and record what you have already implemented and what is still planned.

The most important advice: start now instead of waiting for perfection. Authorities tend to take into account whether a business is visibly and systematically working on accessibility. A website that removes its biggest barriers today and has a clear roadmap is in a far better position than one that sits the topic out.