The European Accessibility Act (EAA), formally Directive (EU) 2019/882, requires businesses selling many consumer products and services in the European Union (EU) to meet specific accessibility requirements. The EAA became enforceable across all 27 EU Member States on June 28, 2025, and the first EAA-related lawsuits were filed in France in November 2025. The directive applies to both EU and non-EU companies operating in the EU market, helping ensure access for an estimated 87 million Europeans with disabilities.
The European Accessibility Act (EAA) is the EU's landmark directive for digital accessibility in the private sector. The Act harmonizes accessibility requirements across the EU, replacing the patchwork of disparate national laws previously in place. By providing a consistent accessibility framework across the region, the EAA aims to streamline trade while ensuring equal access to products and services for all EU citizens.
Key insights
- EAA enforcement started June 28, 2025, and all 27 EU Member States have passed the directive into law.
- The first EAA lawsuits in France were filed in November 2025. The Netherlands plans audits in spring 2026.
- Fines vary by country, from €60,000 in Ireland to ~€900,000 in Sweden. Some countries allow criminal penalties.
- Any company selling covered products or services in the EU must comply, even if based outside Europe.
- EN 301 549 v3.2.1 (which incorporates WCAG 2.1 AA) is the current standard. A WCAG 2.2 update is expected in 2026.
- The EU AI Act, which takes full effect August 2, 2026, requires high-risk AI systems to comply with applicable EU laws including the EAA.
What is the goal of the EAA?
The EAA accessibility directive addresses disparities in accessibility requirements among EU Member States. Before the EAA, divergent rules across national laws created trade barriers and inconsistent access for the 87 million persons with disabilities in the EU. The directive’s purpose is twofold: streamlining commerce across the EU market, and ensuring that all people with disabilities in the EU have equitable access to products and services.
By harmonizing accessibility requirements, the EAA simplifies legal frameworks and reduces costs for economic operators. Industries benefit from adhering to a single set of rules across the unified market rather than managing separate compliance requirements in each EU country.
The EAA also benefits individual citizens. Specifically, the law aims to help better integrate persons with disabilities and the elderly into society, improve their participation in education and employment, and reduce poverty risk.
The directive builds on pre-existing accessibility requirements for the public sector, which were established by the EU Web Accessibility Directive (2016/2102). While these requirements remain in force for public organizations, the EAA extends similar rules to private businesses that provide covered products and services to EU consumers.
The history of EAA: Key milestones
2019: The European Accessibility Act (Directive (EU) 2019/882) was adopted, establishing EU-wide accessibility requirements for products and services.
2022: EU Member States had until June 28, 2022, to transpose the EAA into national laws. All 27 Member States have now completed transposition.
2025: Enforcement began on June 28, 2025. France issued formal legal notices to major retailers shortly after. Sweden launched market surveillance in October 2025. The first lawsuits in France related to the EAA were filed in November 2025.
2026: Dutch ACM is actively enforcing EAA accessibility rules for e-commerce and electronic communications services, WCAG 2.2 is set to become the new accessibility baseline, and key EU AI Act obligations for high-risk AI systems start in the summer.
2027: Some EAA obligations for specific product categories apply from June 28, 2027.
2030: Transitional period ends June 28, 2030, for products and services lawfully in use before June 2025. The European Commission will publish its first EAA review by this date.
What are the EAA requirements?
The specific requirements for EAA compliance are listed in Annex I of the law. These include functional requirements for products and services, which align with the “POUR” principles in the Web Content Accessibility Guidelines (WCAG): all information and functionality must be perceivable, operable, understandable, and robust for users with disabilities.
The best way to meet the functional requirements of the EAA is through conformance with EN 301 549, the harmonized EU digital accessibility standard. EN 301 549 is the presumptive standard for compliance with the EAA, which means that organizations that conform to EN 301 549 are presumed to be in compliance with the law. This may involve ensuring compatibility with assistive technologies, providing keyboard navigation support, and other accessibility considerations. Providers of mobile applications must ensure accessibility across both iOS and Android platforms.
However, the EAA’s requirements extend beyond functional accessibility. Manufacturers of covered products must prepare technical documentation, conduct conformity assessments, affix CE marking, and maintain records for five years. Service providers must publish an accessibility statement, offer accessible support services including at least one accessible customer channel, and maintain ongoing compliance processes.
The following table offers examples of products and services covered by the EAA, and some of the requirements for these products and services.
| Category | Examples | Requirements include: |
|---|---|---|
| Computers and operating systems | Desktops, laptops, tablets, smartphones | CE marking, assistive technology compatibility |
| Self-service terminals | ATMs, payment terminals, ticketing machines, check in machines, interactive kiosks | CE marking, keyboard navigation, physical accessibility |
| Electronic communications equipment | Routers, modems, VoIP phones | CE marking, assistive technology compatibility |
| TV and audiovisual media devices | Smart TVs, streaming devices, set-top boxes | CE marking, audio description support |
E-readers Dedicated e-book reading devices CE marking, text-to-speech compatibility Electronic communication services Phone and internet services, mobile apps, mobile applications Accessibility statement, accessible support channel Banking services Consumer banking, credit, payment, investment, e-money services Accessibility statement, accessible customer channel E-commerce B2C online services via websites or mobile apps, full customer journey Accessibility statement, ongoing compliance Transportation information services Websites, mobile apps, electronic tickets, real-time travel information Accessibility statement, accessible formats Audiovisual media services access Audio descriptions, sign language interpretation, subtitles for television broadcast, streaming, and on-demand audiovisual media services Accessibility statement, multiple accessible formats E-books Digital books and dedicated software Accessibility statement, text-to-speech support Emergency communications Calls to the European emergency number 112 Full accessibility across communication channels
The EAA requirements cascade through economic operators in the supply chain:
- Manufacturers bear responsibility for design, conformity assessment, CE marking, and technical documentation.
- Importers must verify conformity before sale and ensure CE marking is present.
- Distributors must verify CE marking and documentation and halt sales of non-compliant products.
Economic operators must notify regulators in every Member State where non-compliant products or services are available.
Are any organizations exempt from the EAA's requirements?
Microenterprises with fewer than 10 employees and an annual turnover or annual balance sheet total of no more than €2 million are exempt from EAA service accessibility requirements. This exemption applies to services only, not products. The exemption disappears immediately if a business grows past these thresholds, with no grace period. It also does not apply if the business has received funding specifically for accessibility improvement.
Disproportionate burden defense
Article 14 of the EAA allows businesses to claim that specific accessibility requirements would impose a disproportionate burden on them, meaning that the burden that meeting these requirements places on the business outweighs potential benefits to persons with disabilities. This is not a blanket exemption or fundamental alteration of the accessibility obligation.
Businesses must document their reasons for making this claim using the criteria in Annex VI of the EAA, provide documentation to enforcement authorities on request, and reassess at least every five years (or sooner if circumstances change).
Does the European Accessibility Act apply to non-EU companies?
The EAA applies to any economic operator that places covered products on the EU market, or provides covered services to EU consumers, regardless of where the company is headquartered. Product manufacturers that are not based in the EU must appoint an EU-based authorized representative to manage compliance-related tasks on their behalf.
What role does EN 301 549 play in relation to the EAA?
EN 301 549 is the harmonized European accessibility standard for information and communication technology (ICT). Meeting this standard provides a "presumption of conformity" with the EAA under Article 15. The standard outlines specific, technical accessibility requirements based on the same four "POUR" principles in WCAG: perceivable, operable, understandable, and robust.
The current version, EN 301 549 v3.2.1, incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. However, EN 301 549 extends beyond WCAG to address accessibility for a broader range of ICT products and services, and outlines additional requirements.
These include requirements related to hardware, mobile apps, documentation, and certain features like video players.
WCAG 2.2 and the EN 301 549 V4.1.1 update
A new version of the European standard, EN 301 549 V4.1.1, is expected to publish in 2026. Compared to WCAG 2.1, WCAG 2.2 introduced nine new success criteria, including criteria covering focus appearance, dragging movements, accessible authentication, and redundant entry.
To keep pace with evolving regulatory expectations, organizations should align with WCAG 2.2 now. It is backwards-compatible with WCAG 2.1, so early adoption creates no compliance conflict while preparing for potential future obligations.
EAA enforcement: lawsuits, audits, and market surveillance
Enforcement of the EAA is now underway across Europe. In the second half of 2025, most authorities have focused on building enforcement capacity and preparing procedures. However, some have already begun auditing companies, handling complaints, and issuing notifications.
France: first EAA lawsuits
On July 7, 2025, French disability organizations sent formal legal notices to Auchan, Carrefour, E.Leclerc, and Picard Surgelés. When responses proved inadequate, emergency injunctions were filed in French Commercial Court on November 12, 2025, marking the first EAA-related lawsuits in Europe.
Sweden: market surveillance
The Swedish Post and Telecom Authority (PTS) began inspecting laptops, smartphones, and tablets in October 2025 using JAWS screen reader technology. PTS opened its first e-commerce regulatory cases. Maximum fines reach SEK 10 million (approximately €900,000) with market ban authority.
Netherlands and other EU Member States
Authorities in the Netherlands and Germany have confirmed that enforcement activities are underway, and they plan to ramp up auditing efforts in 2026. These early actions suggest that enforcement will not be evenly paced across the 27 EU Member States, but will depend on national authority readiness and priorities.
What happens if you fail to comply with the European Accessibility Act?
The EAA requires penalties to be "effective, proportionate, and dissuasive." Each Member State establishes its own enforcement authorities and penalty structures.
| Country | Maximum fine |
|---|---|
| Sweden | ≈€900,000 (SEK 10 million) |
| Spain | €600,000 |
| France | €75,000 per violation or daily penalties of up to €3,000 (capped at €300,000) for injunctions or, for serious breaches, up to 0.1% of worldwide turnover per day (capped at 5% of annual turnover) |
| Netherlands | €90,000 |
| Austria | €80,000 per violation |
| Germany | €100,000 per violation |
| Italy | €40,000 per violation and up to 5% of annual turnover for organizations under the Stanca Law |
| Ireland | €60,000 |
Beyond fines, enforcement authorities can order product withdrawal, prohibit non-compliant products and services on national markets, mandate accessibility audits, and publicly disclose non-compliance. In some jurisdictions, competitors may pursue unfair competition claims related to unmet accessibility requirements.
EAA and the EU AI Act: what changes in 2026?
The EU AI Act (Regulation 2024/1689) becomes fully enforceable on August 2, 2026, integrating accessibility into AI governance. Article 16(1)(l) requires that providers of high-risk AI systems comply with existing, applicable EU laws—and for providers of AI systems used by EU consumers, these applicable laws include the EAA.
Additionally, Article 5(1)(b) prohibits AI systems that exploit disability vulnerabilities. This reinforces the role of accessibility and inclusive design in AI development across the European market.
Jump-start your EAA compliance journey with UserWay
If EAA compliance is a priority for your organization, UserWay can help you get on the right path. Make immediate improvements to web accessibility and user experience with our Accessibility Widget. Then, request an audit from our experts to surface code-level issues you can fix to align with EAA requirements.