EAA deadlines by country: what applies where

The EU baseline

Directive (EU) 2019/882 was adopted on 17 April 2019. Member States had to incorporate it into national law by June 2022, and the Commission monitors whether that transposition is complete and correct. The requirements apply to covered products and services from28 June 2025.

The directive covers consumer computers and operating systems, smartphones and similar terminal equipment, self-service terminals such as ATMs and ticketing machines, e-readers and digital television equipment, plus e-commerce, consumer banking, electronic communications, passenger transport, e-books and audiovisual access services. If you sell to consumers in the EU in one of those lanes, the date applies to you regardless of where you are established.

The EAA guide covers scope, the microenterprise exemption and the information duty in more detail.

Three dates people confuse

A launch plan usually needs one date, and the directive supplies three candidates:

1. The transposition deadline (June 2022). That is a duty on Member States, not on your business. A country that transposed late did not give providers a later compliance date in principle, though its national enforcement may have started later in practice.
2. The application date (28 June 2025). This is the date that matters for a new or updated service. Products placed on the market and services provided from that date must comply.
3. A national transitional end date. Some Member States let existing arrangements continue for a period. Germany’s rule is the clearest example, and it runs to 27 June 2030 for certain pre-existing products and contracts.

If a supplier or a blog gives you a single “EAA deadline” without saying which of the three it means, the number is not usable in a plan.

Germany: BFSG

Germany implemented the directive through the Barrierefreiheitsstärkungsgesetz (BFSG), the Act on the Strengthening of Accessibility. The Federal Ministry of Justice publishes the consolidated text on gesetze-im-internet.de, including the sections on service provider duties, market surveillance and transitional provisions.

The transitional provision in § 38 is the part worth reading before a German launch:

• Service providers may continue to deliver services using products they already lawfully used for those or similar services before 28 June 2025, until 27 June 2030.
• Service contracts concluded before 28 June 2025 may continue unchanged until 27 June 2030, but not beyond the term they were agreed for.
• Self-service terminals already in use before 28 June 2025 may continue until the end of their economic life, capped at fifteen years after they were put into service.

That is a transition for legacy products and contracts, not a general delay. A new service launched in Germany after 28 June 2025 does not inherit it.

Ireland: S.I. No. 636 of 2023

Ireland transposed the directive through the European Union (Accessibility Requirements of Products and Services) Regulations 2023, S.I. No. 636 of 2023. The regulations state that they come into operation on 28 June 2025, and they apply to products placed on the market, and services provided to consumers, on or after that date.

Three details are more explicit in the Irish text than in most summaries:

• Content exclusions are listed. Pre-recorded time-based media and office file formats published before 28 June 2025, online maps where essential information is provided accessibly, third-party content not funded or controlled by the operator, and archived content not updated on or after 28 June 2025.
• The microenterprise exemption is service-side. The service requirements and the service provider duties do not apply to a service provided by a microenterprise, defined as fewer than 10 employees and turnover or balance sheet total not exceeding €2 million. It does not exempt products.
• Enforcement is split by sector. The Competition and Consumer Protection Commission is the market surveillance authority for products. For services, ComReg covers electronic communications, Coimisiún na Meán audiovisual services, the Irish Aviation Authority air transport, the National Transport Authority bus, rail and waterborne transport, and the Central Bank of Ireland banking. E-commerce and e-books sit with the CCPC.

United Kingdom: outside the EAA

The EAA is EU law and the UK is not an EU Member State, so it does not apply to UK-only services. Two UK regimes do the work instead:

• Equality Act 2010, which requires service providers to make reasonable adjustments for disabled people. It applies beyond the public sector.
• Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, which require public sector websites and apps to meet WCAG 2.2 AA and publish an accessibility statement. GOV.UK publishes the requirements and the statement guidance.

A UK business selling into Ireland, Germany or France is caught by those countries’ national law for those customers, which is why one statement per regime is usually cleaner than a single page hedging across jurisdictions.

France, the Netherlands and elsewhere

France and the Netherlands are EU Member States, so the directive applies there from the same application date, through their own national implementing texts. This page has not verified the current consolidated instrument, the national regulator or any transitional period for either country, so it does not state one. Read the national text directly: Legifrance for France, wetten.overheid.nl for the Netherlands, and the regulator named in that text.

The same caution applies to every other Member State. The directive harmonises the requirements, not the administration. Penalties, complaint routes, market surveillance powers and transitional rules are national, and a compliance plan that assumes otherwise will be wrong somewhere.

What to do with this

1. List the countries where you actually serve consumers, not the countries where your company is registered.
2. For each, identify the national implementing act and the regulator. If you cannot find them, that is the first task, not a footnote.
3. Check for a transitional rule that applies to your specific product or contract. A legacy terminal is a different case from a new web service.
4. Set the technical target at WCAG 2.2 AA, which satisfies the EN 301 549 baseline and prepares for the newer version of the standard.
5. Publish a statement per regime, naming the law that applies and the route a visitor can escalate to. Thegenerator handles the EAA, BFSG, UK and US references.
6. Re-check the date before launch. This page is a snapshot, not a subscription.

Frequently asked questions

More general questions are answered on the AccessProof FAQ.

Sources and last checked

Links opened on 24 October 2026. Where a country’s national instrument was not verified, this page says so rather than filling the gap.

• European Commission, European Accessibility Act overview:commission.europa.eu - checked 24 October 2026.
• Germany, Barrierefreiheitsstärkungsgesetz (BFSG), consolidated text:gesetze-im-internet.de - checked 24 October 2026.
• Germany, BFSG § 38 transitional provisions:gesetze-im-internet.de - checked 24 October 2026.
• Ireland, S.I. No. 636/2023, European Union (Accessibility Requirements of Products and Services) Regulations 2023:irishstatutebook.ie - checked 24 October 2026.
• GOV.UK, accessibility requirements for public sector websites and apps:gov.uk - checked 24 October 2026.
• GOV.UK, digital accessibility topic:gov.uk - checked 24 October 2026.