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The European Accessibility Act, in plain English

11 min read Reviewed 2026-08-22

The European Accessibility Act is the first EU law that makes digital accessibility a product-safety-style obligation for private companies rather than only for the public sector. If you sell to consumers in the EU and you have a website or an app, it probably applies to you.

What the EAA actually is

The European Accessibility Act is Directive (EU) 2019/882, adopted in April 2019. Being a directive rather than a regulation, it does not apply to you directly — each member state had to write it into national law. Those national laws have applied since 28 June 2025.

This matters practically: the obligation you have to meet is your national implementing statute, not the directive text. The substance is harmonised across the EU, but definitions, supervising authorities and penalty ranges are national. If you operate in several member states you are dealing with several regulators, all pointing at the same technical standard.

People often confuse the EAA with the Web Accessibility Directive, (EU) 2016/2102. That earlier directive covers public sector bodies — government, municipalities, public universities. The EAA is the private sector counterpart. If you are a company selling to consumers, the EAA is yours.

Who it applies to

The EAA lists specific products and services rather than applying to the whole economy. On the services side, the ones that catch most companies are:

• E-commerce — any business-to-consumer sale of goods or services through a website or app. This is the broadest category by far and the one most businesses are surprised by.
• Consumer banking services — accounts, credit, payment services aimed at consumers.
• Electronic communications services — telephony, messaging, internet access.
• Passenger transport — air, bus, rail and waterborne. Websites, mobile apps, electronic tickets and real-time travel information.
• Access to audiovisual media services — the interface and programme guides, not the programmes themselves.
• E-books and the software built to read them.

On the products side: consumer computers and their operating systems, smartphones, e-readers, self-service terminals such as ATMs, ticket machines and check-in kiosks, and terminal equipment used for electronic communications or for accessing audiovisual media.

The practical test for most companies is simple. Can a consumer buy something from you online? If yes, you are almost certainly in scope through the e-commerce limb.

Who is exempt

There are three exemptions worth knowing, and two of them are far narrower than people hope.

Microenterprises providing services

A microenterprise — fewer than 10 people and annual turnover or balance sheet total not exceeding €2 million — is exempt from the accessibility requirements when it provides services. Note the conjunction: you need to be under both the headcount and the financial threshold. Note also that this exemption covers services; microenterprises dealing in products get relief from some documentation duties but not from the substantive requirements.

Disproportionate burden

You may claim that compliance imposes a disproportionate burden. This is not a box you tick. The directive sets out the criteria you must weigh — the ratio of cost to your overall costs and revenue, and the estimated benefit to people with disabilities — and you must document that assessment and keep it. Authorities can ask to see it, and a poorly reasoned assessment is worse than none, because it is evidence you knew about the obligation.

Fundamental alteration

You are not required to make a change that would fundamentally alter the basic nature of your product or service. In practice this is a narrow escape hatch. Adding alt text and fixing colour contrast has never fundamentally altered anything.

What standard you are measured against

The directive itself is written in functional terms — content must be perceivable, operable, understandable and robust — and deliberately avoids naming a technical specification. The bridge from that language to something a developer can act on is the harmonised European standard, EN 301 549.

For web content, EN 301 549 points directly at WCAG 2.1 Level AA. That is the practical target. When someone asks "what do we actually have to do", the answer is: meet WCAG 2.1 Level AA across the consumer-facing parts of your service, and be able to show your working.

Conforming to the harmonised standard gives you a presumption of conformity with the directive. You can meet the requirements another way, but then the burden of demonstrating it falls entirely on you. Almost nobody chooses that.

More on EN 301 549 and how it relates to WCAG →

How it is enforced

Each member state designates its own market surveillance and enforcement authorities, and sets its own penalties. The directive requires those penalties to be "effective, proportionate and dissuasive" but does not fix amounts. Some states supervise through a single digital authority; others split it across sector regulators, so a bank, an airline and a retailer may answer to three different bodies in the same country.

The realistic trigger is not a routine inspection. It is a complaint. The directive requires member states to provide a route for consumers and representative organisations to raise non-compliance. Disability advocacy organisations are well organised, and the evidence is trivially reproducible — anyone can run the same automated tests you can, on any page, at any time.

There is also a commercial dimension that arrives sooner than any regulator. Procurement questionnaires increasingly ask for an accessibility statement and a conformance claim. An unanswerable question in a tender is a lost deal, and that tends to concentrate minds faster than a hypothetical fine.

What has actually happened so far is instructive: as far as we can establish, no EAA fine has yet been issued anywhere in the EU — but in June 2026 a French court ordered Carrefour to make its e-commerce site and app fully accessible within six months, with a €500 daily penalty, in a case brought by disability associations rather than a regulator. The penalties and enforcement guide sets out the statutory maximums country by country, checked against the primary legislation.

The accessibility statement

Service providers are expected to publish information about how their service meets the accessibility requirements. In practice this means an accessibility statement: what standard you conform to, what you know is still broken, how someone reports a problem, and what happens when they do.

A statement that honestly declares partial conformance with a listed set of known issues and a remediation timeline is a much stronger position than silence — and a far stronger one than an unsupportable claim of full conformance. Overclaiming is the one thing guaranteed to make a complaint worse.

Generate a structured accessibility statement free →

What to do this quarter

1. Establish whether you are in scope. Sell to consumers online in the EU, above microenterprise thresholds? Assume yes and move on.
2. Get a baseline. Run automated testing across your real user journeys — home, category, product, cart, checkout, contact, account. Not just the homepage.
3. Fix the machine-detectable failures first. Contrast, missing labels, missing alt text, unlabelled buttons, broken ARIA. These are cheap, unambiguous, and they are exactly what a complainant will screenshot.
4. Commission a manual audit of your checkout. Automation cannot tell you whether a screen reader user can actually complete a purchase. That single journey carries most of your risk.
5. Publish an honest accessibility statement with a feedback address that a human monitors.
6. Put a regression check in place. Everything above decays the moment you ship. Testing once and declaring victory is how sites that passed in July fail in September.

Last reviewed 2026-08-22. This is general information about the directive, not legal advice. National implementations differ, and you should confirm the specifics with a qualified adviser in the member states where you operate.