The European Accessibility Act: who it applies to and what it asks for

The European Accessibility Act is Directive (EU) 2019/882. It was adopted in April 2019, member states had to write it into national law by June 2022, and the requirements have applied since 28 June 2025. It is the first European accessibility rule that reaches deep into the private sector. Until then, the binding obligations under EU accessibility law mostly stopped at public sector bodies.

What is covered

The directive works with two lists, one for products and one for services. A thing is in scope only if it appears on a list.

Products include general-purpose computer hardware and its operating systems, payment terminals, self-service terminals such as ATMs, ticketing machines and check-in machines, consumer terminal equipment used for electronic communications and for accessing audiovisual media services, and e-readers.

Services include electronic communications services, services providing access to audiovisual media, defined elements of air, bus, rail and waterborne passenger transport, consumer banking services, e-books together with the software used to read them, and e-commerce.

That last item is the one that catches most organisations by surprise. E-commerce here means selling goods or services to consumers through a website or a mobile application. A shop is in scope because it sells online, not because of what it sells.

Who is exempt

Two exemptions matter in practice.

Microenterprises that provide services are outside the scope: fewer than ten people and an annual turnover or balance sheet total of no more than two million euro. Note the asymmetry. A microenterprise that manufactures a covered product is not exempt in the same way, although it can use a lighter procedure.

The second exemption is the disproportionate burden assessment. A provider may claim that a specific requirement would impose a disproportionate burden, but this is not a box to tick. The assessment has to be documented, it has to be repeated at least every five years, and it has to be handed over to the market surveillance authority on request. An assessment that consists of the sentence “this would be too expensive” is not an assessment.

What a provider actually has to deliver

The directive itself is written as functional requirements rather than as a technical checklist. Information must be perceivable through more than one sensory channel, presented in an understandable way, and made available in text formats that assistive technology can process. Interfaces must support alternative input methods and must not rely on an ability the user may not have.

For anything on a screen, those functional requirements are met in practice by conforming to the harmonised standard, EN 301 549, which in turn points at the WCAG success criteria. Conformity with the harmonised standard creates a presumption of conformity with the directive. That is the whole point of a harmonised standard: it turns a legal argument into a testable one.

The transition periods

Three dates sit behind the headline date and they are frequently mixed up.

The 2030 date applies to the contract, not to the service in general. A new contract signed after June 2025 does not inherit it.

Enforcement

Each member state designates market surveillance authorities for products and enforcement bodies for services, and each must provide a way for consumers to complain. Penalties are set nationally and the directive only requires them to be effective, proportionate and dissuasive, so the real exposure varies considerably between countries. In Germany the transposition is the Barrierefreiheitsstärkungsgesetz; the German-language explanation of that is on our BFSG page.

The practical risk in the first years is less about fines than about being told to fix something on a deadline set by someone else. That is a much more expensive way to do the work than doing it during a redesign you were planning anyway. If you want to know where you stand, our self-check guide walks through what you can test without buying anything.