# EAA Reference - Verified Fact Set

Regulation: **European Accessibility Act (EAA)** - Directive (EU) 2019/882.
Last verified: June 2026. Status: in force and applying. No amendment or delay to the core 28 June 2025 application date as of mid-2026.

## Core dates

| Date | What happens |
|------|--------------|
| 7 June 2019 | Directive (EU) 2019/882 adopted. |
| 28 June 2022 | Deadline for Member States to transpose into national law (most have; transposition quality and penalties vary by country). |
| **28 June 2025** | **Application date.** Accessibility requirements apply to products placed on the market and services provided to consumers from this date. |
| 28 June 2030 | End of the general transition window. Service providers may keep using products lawfully used before 28 June 2025 until this date. Service contracts agreed before 28 June 2025 may run unchanged until this date (max). |
| Up to 28 June 2045 | Self-service terminals (ATMs, ticketing/check-in machines, payment terminals) lawfully in use before 28 June 2025 may keep being used until the end of their economic life, capped at 20 years from entry into use. |

Enforcement note: national market surveillance and service-compliance authorities are active; enforcement is intensifying across Member States through 2026.

## Who is covered (economic operator roles)

The EAA assigns obligations by role. A company can hold more than one role.
- **Manufacturer** - makes a covered product, or has one designed/made and markets it under its own name/trademark. Heaviest obligations (technical documentation, conformity assessment, EU Declaration of Conformity, CE marking).
- **Importer** - places a covered product from a non-EU country on the EU market. Must verify the manufacturer did the conformity work; cannot place non-conforming products.
- **Distributor** - any other operator in the supply chain that makes a product available. Must act with due care, check CE marking and documentation.
- **Service provider** - provides a covered service to consumers in the EU. Must meet accessibility requirements and publish an accessibility statement / information.

## Covered PRODUCTS (Article 2)

- Consumer general-purpose computer hardware systems and their operating systems.
- Self-service terminals: payment terminals; ATMs; ticketing machines; check-in machines; interactive information terminals (except those installed as integrated parts of vehicles, aircraft, ships, rolling stock).
- Consumer terminal equipment with interactive computing capability used for electronic communications services (e.g. smartphones).
- Consumer terminal equipment with interactive computing capability used for accessing audiovisual media services (e.g. smart TVs, set-top boxes).
- E-readers.

## Covered SERVICES (Article 2)

- Electronic communications services (telecoms).
- Services providing access to audiovisual media services (AVMS).
- Elements of air, bus, rail and waterborne passenger transport services: websites, mobile apps, electronic tickets and e-ticketing, delivery of transport service information, interactive self-service terminals (with exceptions for urban/suburban/regional transport, which only owe the self-service-terminal parts).
- Consumer banking services.
- E-books and dedicated software.
- E-commerce services (selling products/services to consumers via website or mobile app).

E-commerce note: applies to any provider offering e-commerce to consumers in the EU, EU-based or not, regardless of whether the goods sold are themselves in scope.

## Micro-enterprise exemption

- **Micro-enterprise** = fewer than 10 persons AND annual turnover or balance-sheet total not exceeding EUR 2 million.
- A micro-enterprise providing **services** is exempt from the accessibility requirements and the related documentation duties (but must notify the relevant authority on request that it relies on this).
- The exemption does **NOT** apply to micro-enterprises that **manufacture, import or distribute products** - product obligations still apply to them.

## Other exemptions / limits

- **Disproportionate burden** (Article 14): an operator need not meet a requirement to the extent doing so imposes a disproportionate burden, assessed against listed criteria (costs vs benefits, resources, estimated benefit to persons with disabilities). Must be self-assessed, documented, and re-assessed (at least every 5 years, or when the service changes, or on authority request). Not available to operators that received external funding for accessibility.
- **Fundamental alteration** (Article 14): a requirement may be skipped only to the extent it would require a fundamental change in the basic nature of the product or service.
- These are partial and documented exemptions, not blanket opt-outs. The operator must still comply as far as is not disproportionate / not a fundamental alteration.

## The standard: EN 301 549 / WCAG 2.1 AA

- The EAA sets functional accessibility requirements in **Annex I**. It does not name a standard in the text.
- **EN 301 549** is the European harmonised standard for ICT accessibility. The widely used version is **V3.2.1 (March 2021)**; it incorporates **WCAG 2.1 Level AA** for web content and extends to apps, software and hardware. Conformance with a harmonised standard published in the Official Journal gives a **presumption of conformity**.
- Practical target for websites and apps: meet **WCAG 2.1 Level AA** (perceivable, operable, understandable, robust). // VERIFY whether an updated EN 301 549 version (e.g. referencing WCAG 2.2) has been cited in the Official Journal for EAA presumption-of-conformity as of latest check.

## Obligations by output

**Products (manufacturers):**
- Design and make the product to meet Annex I accessibility requirements.
- Prepare technical documentation (Annex IV) and carry out the conformity assessment (internal production control, Annex IV).
- Draw up the **EU Declaration of Conformity**; keep it and the technical documentation for **5 years** after the product is placed on the market.
- Affix the **CE marking** (visible, legible, indelible).
- Provide instructions/safety information in an accessible way; mark product with type/batch/serial and contact address.
- Importers and distributors: verify the above is done before placing/making available; keep records; act on non-conformity.

**Services (service providers):**
- Design and provide the service to meet Annex I requirements (and, for e-commerce/transport/banking/e-books, the service-specific requirements in Annex I sections).
- Prepare the information explaining how the service meets the requirements (Annex V) and **publish an accessibility statement** (general terms/conditions or equivalent) covering: how the service meets accessibility requirements, and, where claimed, any disproportionate-burden assessment.
- Keep this information for as long as the service is offered.
- Note: CE marking and EU Declaration of Conformity do **not** apply to services (or to websites/apps as such) - those are product mechanisms.

**Both:**
- Non-conformity duties: corrective action, informing authorities, cooperating with market surveillance.
- Operators must, on request, identify any operator who supplied/was supplied a product (traceability, 5 years).

## Penalties / enforcement

- Set by each Member State; must be "effective, proportionate and dissuasive."
- Typical range across countries: administrative fines roughly EUR 5,000 to EUR 100,000+ (varies widely; some allow market withdrawal; at least one allows criminal penalties). Exact figures are national. // VERIFY exact national fine ceilings per target country.
- Consumers and disability bodies can bring complaints; products/services can be ordered withdrawn or restricted.

## Sources (official + authoritative)

- Directive (EU) 2019/882 full text, EUR-Lex: https://eur-lex.europa.eu/eli/dir/2019/882/oj/eng
- EUR-Lex summary "Accessibility of products and services": https://eur-lex.europa.eu/EN/legal-content/summary/accessibility-of-products-and-services.html
- European Commission, European Accessibility Act page: https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/disability/european-accessibility-act-eaa_en
- AccessibleEU Centre (Commission), guidance: https://accessible-eu-centre.ec.europa.eu/
- EN 301 549 (ETSI standard): https://www.etsi.org/standards (search EN 301 549)
- WCAG 2.1 (W3C): https://www.w3.org/TR/WCAG21/
- European Disability Forum overview: https://www.edf-feph.org/accessibility-act-enters-into-force-products-and-services-must-be-accessible/