The European Accessibility Act explained

What the EAA is

The European Accessibility Act is Directive (EU) 2019/882 of 17 April 2019 on the accessibility requirements for products and services. It sets common EU-wide requirements for what matters most to people with disabilities.

Because it is a directive, it does not apply directly. Member States had to transpose it by 28 June 2022, and the national laws apply the harmonised requirements from 28 June 2025. Work out your scope, then work in the national law of the country whose rules apply to you.

Who is covered

The EAA covers these products when placed on the EU market:

• consumer general purpose computers and operating systems
• smartphones and similar terminal equipment with interactive computing capability
• self-service terminals such as ATMs, ticketing machines and check-in machines
• e-readers
• TV equipment related to digital television services

And these services when provided to consumers in the EU:

• e-commerce services
• consumer banking services
• electronic communications services, including emergency communications
• transport: elements of air, bus, rail and waterborne passenger transport services
• e-books and dedicated software
• services providing access to audiovisual media services

For most digital teams the effect is this: if you sell to consumers online in the EU, or provide consumer banking, telecom or passenger transport services, your site is in scope.

Scope in practice

The EAA attaches to an economic activity, so a website is in scope because the service behind it is. Four questions settle most cases.

1. Is the activity in the EU? A business outside the EU serving consumers in a Member State can be caught.
2. Is it one of the listed products or services? The categories are set out precisely in national law, and are narrower than "anything sold online".
3. Is it consumer-facing? A staff-only tool or a developer portal is not caught by the consumer-facing duties.
4. Are you the right actor? Products follow the manufacturer, importer and distributor; services follow the service provider.

Apps are treated the same way as sites, so an e-commerce app, a banking app, an e-book app and a transport app follow the same rules as the equivalent website.

The three obligations

The national laws that implement the EAA always come back to the same three layers.

1. Information requirements

The first layer is what a person is told. For products, information about use, labelling, instructions and warnings must be available through more than one sensory channel, understandable and perceivable, in fonts of adequate size with sufficient contrast. For services, the information must include an accessible general description and the explanations needed to understand how the service operates.

2. Accessibility requirements

The second layer is what the product or service does: the technical requirements it must actually meet. They are given substance byEN 301 549, the European harmonised standard for ICT accessibility, which national law uses as a presumption of conformity.

3. The accessibility information duty

The third layer turns into a published document. Before providing a service, a provider must prepare information explaining how the service meets the accessibility requirements, make it available to the public in writing and in oral format, in a way accessible to people with disabilities, and keep it for as long as the service runs.

That third layer is the legal home of the accessibility statement. The law does not use that phrase, but a published statement is the ordinary way to make accessibility information public.

Who has to do what

The EAA splits by actor: products follow one list, services the next.

Products: manufacturer, importer, distributor

A manufacturer must ensure the product placed on the market is designed and manufactured in accordance with the applicable accessibility requirements. Before placing it on the market, the manufacturer draws up the technical documentation, carries out the conformity assessment, draws up the EU declaration of conformity and affixes the CE marking. The product must carry the manufacturer's name or trade mark and a contact address, and the technical documentation and EU declaration must be kept for five years.

An importer or distributor is treated as the manufacturer, and takes on the manufacturer's obligations, when they place a product on the market under their own name or trade mark, or when they modify a product already on the market in a way that may affect its compliance.

Services: the service provider

A service provider must ensure the service is designed and provided in accordance with the applicable accessibility requirements, and must prepare, publish and maintain the accessibility information described above. The provider must keep procedures in place so the service stays in conformity, and take account of changes in the service and the standards relied on. When it is not in conformity, the provider must fix it and tell the competent authorities in each Member State where it is provided.

The microenterprise exemption is service-side only. It does not help a manufacturer, importer or distributor with a product.

Key dates

Exemptions and exceptions

The EAA is not absolute. Four points matter in practice.

• Microenterprises providing services (fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million) are exempt from the service requirements: the service accessibility requirements and the accessibility information duty both fall away for such a service. This exemption does not apply to products.
• Disproportionate burden: a provider can be excused from a requirement if meeting it would impose a disproportionate burden, after assessing costs and benefits for people with disabilities. The assessment must be documented, and national law sets the criteria.
• Fundamental alteration: a requirement does not apply if it would fundamentally change the nature of the product or service.
• Excluded content: national laws implementing the EAA also carve out pre-recorded media published before 28 June 2025, office file formats published before that date, online maps where essential information is provided accessibly, third-party content the operator neither funded nor developed, and archived content no longer updated.

Two further carve-outs are often mentioned in summaries of the EAA: services provided in a purely private or non-commercial capacity, and products that are themselves assistive technology. National transpositions handle these in their own terms, so check the wording in your own country first.

These exceptions are narrow, must be assessed, and do not remove the duty to provide accessible alternatives.

Enforcement and penalties

The directive does not set a single EU fine. Each Member State must lay downpenalties that are effective, proportionate and dissuasive, and must designate market surveillance or compliance authorities to check compliance and handle complaints. That is why penalties differ by country, from administrative orders to require fixes, to fines reaching tens or hundreds of thousands of euros for serious or repeated breaches.

Enforcement usually starts with a complaint or an inspection, and providers are typically given a chance to fix the problem first. An accurate statement and a working feedback channel are the simplest way to show good faith and resolve complaints early.

How an accessibility statement fits

The EAA requires accessible services, not paperwork, but the accessibility information duty means a provider has to publish something. A statement is the standard, human-readable page that:

• states your commitment and the standard you follow (for example WCAG 2.2 AA);
• describes your actual conformance status, honestly, including known limitations;
• gives a clear feedback channel, email, phone or a form, and a response promise;
• explains how accessibility was assessed; and
• names the legal framework and, where relevant, the authority a visitor can escalate to.

That is the structure the AccessProof generator produces, following the W3C accessibility statement guidance. See also theAccessProof FAQ.

WCAG 2.2 AA and EN 301 549

EN 301 549 is the European harmonised standard for accessibility requirements for ICT products and services, and it is how the EAA's requirements are given technical substance. Its current version, EN 301 549 v3.2.1, is based on WCAG 2.1 Level AA and is the version currently referenced for demonstrating conformity with the EAA.

In September 2026 a new version, EN 301 549 v4.1.1, was published. It adopts WCAG 2.2 and adds an annex linking its requirements directly to the EAA. It is not yet the legal reference standard until the European Commission cites it in the Official Journal, but it shows the direction of travel. Aiming for WCAG 2.2 Level AA is the safest target: it meets the baseline used today and prepares for what comes next.

National implementation

Transposition looks different in every country. These are the main frameworks the generator can reference for you:

The EAA and the UK

The EAA is EU law. The UK is not an EU Member State, so it does not apply to UK-only services. Sell into Ireland, Germany or France and you follow each of those countries' national law. Serve only UK consumers and the following apply.

• Equality Act 2010. The duty to make reasonable adjustments for disabled people runs through the Equality Act 2010 (and the Disability Discrimination Act 1995 in Northern Ireland). It applies to every UK service provider, not just the public sector.
• Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. In force since 23 September 2018, these require public sector websites and apps to be perceivable, operable, understandable and robust, and to publish an accessibility statement. GOV.UK points public sector bodies at WCAG 2.2 AA.
• A Digital Accessibility Bill has been talked about but is not law.As of 22 October 2026 there is no Digital Accessibility Bill in the list of Bills before the UK Parliament, so it creates no obligations. Treat the Equality Act and the 2018 Regulations as the operative UK duties, and re-checkGOV.UK Digital accessibility if you are reading this much later.

Two UK points carry over beyond the public sector: a body that declares content exempt still has to explain that in its statement, and "we have not had time" is not a disproportionate burden. More is on theaccessibility audit page and in thesample audit report (opens in a new tab).

How to comply this week

If you have an afternoon, this is the order that produces the most movement. None of it needs a legal opinion, and all of it helps whether or not you are formally in scope.

1. Write down your scope. One paragraph: what you sell, who buys it, which countries you serve, and whether you are a service provider or a product business.
2. Run an automated scan. You will not find everything, but you will get the cheap wins: missing alt text, low contrast, unlabelled fields, broken heading order, empty links. Note the tool version and the date.
3. Fix the top five barriers. Keyboard access first, because it blocks everyone who cannot use a mouse. Then contrast, form labels, alt text, headings.
4. Publish the statement. Use theAccessProof generator, fill in the honest answers, and put it live with a link in every footer. State the standard, what you have not fixed yet, and the enforcement body in your country.
5. Put a feedback channel in place. A named contact and a response promise, on the same page as the statement. Accessibility information has to be available in oral as well as written form where the service allows it.
6. Book the re-test. A recurring reminder for three months, and again before any significant redesign.

Practical checklist

1. Confirm whether you are in scope (sector, consumers, size).
2. Pick a target: WCAG 2.2 Level AA, tested with automated and manual checks.
3. Fix the highest-impact barriers first: keyboard access, contrast, forms, alt text, headings, captions.
4. Publish an accessibility statement and link it from every page footer.
5. Give a feedback channel and respond to reports.
6. Keep procedures in place so the service stays in conformity, and revisit them when things change.
7. Review and update the statement at least once a year, or whenever your site changes significantly.

Frequently asked questions

More general questions are answered on the AccessProof FAQ.

Sources and last checked

Every link below was opened on 22 October 2026, and this guide is based on those pages as they stood that day. Some publishers serve automated requests a challenge, so a link may need a refresh in your browser. Re-check anything load-bearing.

• Directive (EU) 2019/882, full text (EUR-Lex CELEX 32019L0882):publications.europa.eu- checked 22 October 2026.
• European Commission, EAA overview:commission.europa.eu- checked 22 October 2026.
• Irish Statute Book, S.I. No. 636/2023:irishstatutebook.ie- checked 22 October 2026.
• AccessibleEU, EN 301 549 update (7 September 2026):accessible-eu-centre.ec.europa.eu- checked 22 October 2026.
• GOV.UK, public sector accessibility requirements:gov.uk- checked 22 October 2026.
• GOV.UK, make your site accessible and publish a statement:gov.uk- checked 22 October 2026.
• GOV.UK, digital accessibility topic:gov.uk- checked 22 October 2026.
• W3C WAI, developing an accessibility statement:w3.org- checked 22 October 2026.
• W3C WAI, how to meet WCAG 2.2:w3.org- checked 22 October 2026.