A comprehensive guide to understanding and complying with Directive (EU) 2019/882 - the groundbreaking European legislation that ensures products and services are accessible to all citizens
The European Accessibility Act (EAA), officially known as Directive (EU) 2019/882, represents a landmark piece of legislation in the European Union's commitment to creating an inclusive society. Adopted on April 17, 2019, this directive establishes harmonized accessibility requirements for specific products and services across all EU member states.
The EAA is fundamentally about ensuring that people with disabilities—which includes approximately 87 million Europeans, or roughly 1 in 6 EU citizens—can access and use products and services on an equal basis with others. This includes permanent disabilities, temporary impairments, and age-related limitations that affect vision, hearing, mobility, or cognitive function.
Unlike previous accessibility legislation in Europe, which primarily focused on the public sector, the EAA extends accessibility obligations to private businesses operating in the B2C (business-to-consumer) market. This marks a significant shift in regulatory approach and reflects the EU's recognition that accessibility is not just a public sector responsibility but a fundamental requirement for fair market participation.
The journey toward the EAA began long before its 2019 adoption. The European Union has been progressively strengthening disability rights through various instruments, including the UN Convention on the Rights of Persons with Disabilities (UNCRPD), which the EU ratified in 2010. This convention recognizes accessibility as a fundamental right and obligates signatory parties to take appropriate measures to ensure access for persons with disabilities.
Prior to the EAA, accessibility requirements varied significantly across member states. A business operating in multiple EU countries faced a complex patchwork of different national regulations, technical standards, and enforcement mechanisms. This fragmentation created several problems:
The European Commission recognized these challenges and proposed the EAA to harmonize requirements, reduce compliance costs for businesses, and ensure consistent accessibility standards across the EU. The directive underwent extensive consultation with stakeholders including disability organizations, industry representatives, and member state authorities before its final adoption.
The European Accessibility Act pursues several interconnected objectives:
By establishing uniform accessibility requirements across all 27 EU member states, the EAA creates a level playing field for businesses. Companies can now design products and services once to meet a single set of requirements, rather than adapting to different national standards. This reduces development costs, simplifies compliance procedures, and facilitates cross-border trade in accessible products and services.
The EAA aims to remove barriers that prevent persons with disabilities from fully participating in society. By ensuring that everyday products and services—from smartphones to banking apps, from e-books to public transport ticketing—are accessible, the directive promotes independence, dignity, and equal opportunities for all citizens. This aligns with the EU's broader social policy goals and its commitment to fundamental rights.
Accessibility requirements often drive innovation that benefits everyone, not just people with disabilities. Features originally designed for accessibility—such as voice controls, text-to-speech, automatic captions, and adjustable interfaces—have become mainstream features that improve user experience for all. The EAA creates market incentives for developing such innovations by establishing a large, harmonized market for accessible products.
Europe's population is aging rapidly. By 2050, it's estimated that over 30% of Europeans will be aged 65 or older. Age-related impairments affecting vision, hearing, mobility, and cognitive function are common, making accessibility increasingly relevant to a growing proportion of the population. The EAA anticipates these demographic shifts and ensures that products and services remain usable as the population ages.
Understanding who must comply with the EAA is crucial. The directive applies to economic operators who provide products or services to consumers in the EU market. This includes:
Any entity that manufactures products covered by the EAA, or has such products designed or manufactured, and markets them under their name or trademark. This includes companies producing computers, smartphones, tablets, e-readers, ATMs, ticketing and check-in machines, payment terminals, and interactive self-service terminals. Manufacturers have primary responsibility for ensuring their products meet accessibility requirements before placing them on the market.
Entities providing services covered by the EAA to consumers in the EU. This encompasses a wide range of sectors:
Importers who place products from outside the EU on the European market must ensure these products comply with the EAA. Distributors who make products available on the market also have obligations to verify compliance and not distribute non-compliant products. This creates a chain of responsibility throughout the supply chain.
Importantly, the EAA applies regardless of where a business is established. If you're a company based in the United States, Asia, or anywhere else in the world, and you sell products or provide services to consumers in the EU, you must comply with the EAA. This extraterritorial application is similar to how the GDPR works for data protection.
The EAA includes a significant exemption for microenterprises, recognizing that very small businesses may face disproportionate burdens in complying with accessibility requirements. A microenterprise is defined under EU law as a business that:
Microenterprises providing services are exempt from accessibility requirements, unless they grow beyond these thresholds. For microenterprises manufacturing products, the situation is more nuanced—they may still need to comply if the products have significant accessibility implications.
Online retailers, marketplaces, and e-commerce platforms must ensure their websites and applications are accessible. E-commerce accessibility requirements include:
Banks, payment providers, and financial institutions offering services to EU consumers must ensure accessibility. This includes digital banking platforms and services like account management, fund transfers, and loan applications.
Financial services are covered by the EAA and must be accessible regardless of whether they're provided through websites, mobile apps, ATMs, or other digital channels. This is particularly important because financial services are essential to participating fully in modern society.
E-book publishers, distributors, and platforms providing e-book services to EU consumers must ensure accessibility. This includes both the e-books themselves (with proper formatting, text alternatives for images, accessible formatting for tables and lists) and the platforms used to distribute and access them (apps, websites, reading software).
The EAA applies to passenger transport services, including airlines, railways, bus operators, and urban public transport. This covers both the physical infrastructure (booking terminals, stations) and digital services (booking websites, mobile apps, real-time information systems).
Operators must provide accessible ways for persons with disabilities to book tickets, check schedules, receive real-time information about delays or changes, and get assistance. Services must be accessible through multiple channels (online, phone, in-person) to ensure all travelers can use them.
Telecommunications providers must ensure accessibility of their services to consumers in the EU. This includes telephone networks, internet access services, and related services. Providers must ensure that persons with disabilities can access their services, including those who use relay services or devices for text communication.
Most digital accessibility requirements under the EAA ultimately derive from the WCAG framework, which is organized around four principles known as POUR:
Information and user interface components must be presentable to users in ways they can perceive. This means providing alternatives for different sensory modalities:
User interface components and navigation must be operable by all users, regardless of the input methods they use:
Information and the operation of user interface must be understandable to users:
Content must be robust enough to be reliably interpreted by a wide variety of user agents, including assistive technologies:
Beyond general digital accessibility principles, the EAA includes specific requirements for different product categories:
Understanding the EAA timeline is critical for compliance planning:
As a directive rather than a regulation, the EAA requires transposition into national law by each member state. While the core requirements are harmonized, member states have some discretion in implementation details, enforcement mechanisms, and penalties. This means that while the accessibility standards are the same across the EU, the specific laws you'll comply with and the authorities you'll interact with will vary by country.
Each member state was required to adopt national laws by June 28, 2022. These national laws typically:
Achieving EAA compliance requires a systematic approach. Here's a comprehensive strategy:
Begin by thoroughly evaluating your current products and services against EAA requirements. This assessment should:
Accessibility should be embedded in your organizational processes, not treated as a one-time project:
Accessibility knowledge should extend throughout your organization:
Prioritize fixing accessibility issues in your current offerings:
Ensure all new products and features are accessible from the start:
The EAA requires that accessibility information be made available. You should create:
Accessibility is not a one-time achievement but an ongoing commitment:
Each EU member state is responsible for enforcing the EAA within its territory. National authorities conduct market surveillance, investigate complaints, and can take various enforcement actions:
Enforcement can be triggered by various means: routine market surveillance, consumer complaints, reports from disability organizations, or compliance checks following the introduction of new products or services.
The EAA requires that penalties be "effective, proportionate, and dissuasive," but leaves the specific amounts to member states. This has resulted in varying penalty regimes across the EU. Here are examples from key markets:
Germany's implementation, the Barrierefreiheitsstärkungsgesetz (BFSG), provides for fines ranging from €10,000 to €100,000 depending on the severity and persistence of the violation. Factors affecting penalty amounts include the size of the business, the duration of non-compliance, and whether violations were intentional or due to negligence.
French implementing legislation provides for penalties ranging from €5,000 for initial violations up to €250,000 for serious or repeated violations. Administrative fines can be compounded by other consequences such as exclusion from public procurement processes.
Spain's penalty structure ranges from €5,000 for minor infractions to €300,000 for very serious violations. The classification of violations takes into account the number of affected users, the economic impact, and the respondent's good faith efforts to comply.
While compliance with the EAA is legally required, accessibility also makes excellent business sense. The disability market in Europe represents enormous purchasing power—an estimated €80 billion annually. When you include friends, family members, and colleagues of persons with disabilities who may prefer to support accessible businesses, the impact is even larger.
Moreover, accessible design benefits many more people than those with permanent disabilities. Consider that accessibility features help:
Accessibility requirements often drive innovations that become mainstream features benefiting all users. Consider these examples:
Many accessibility practices also improve search engine optimization (SEO). Search engines, like screen readers, rely on well-structured, semantic HTML and meaningful text. Accessible websites typically:
Demonstrating commitment to accessibility enhances your brand reputation and fulfills corporate social responsibility (CSR) goals. Particularly for consumer-facing businesses, being known as inclusive and accessible can:
Q: I'm based outside the EU. Does the EAA apply to me?
Yes. The EAA applies to any economic operator who places products on the EU market or provides services to consumers in the EU, regardless of where the business is established. This extraterritorial reach is similar to the GDPR. If you have EU customers, you must comply.
Q: What if I only sell to businesses (B2B), not consumers (B2C)?
The EAA primarily targets products and services provided to consumers. However, this doesn't mean B2B businesses can ignore accessibility entirely. Many of the products covered (computers, software, etc.) may be used in B2B contexts and may still need to comply. Additionally, other laws like the Web Accessibility Directive apply to public sector procurement, and private sector procurement increasingly requires accessibility.
Q: Can I just add an accessibility overlay or widget to my website?
No. Accessibility overlays—JavaScript-based tools that claim to make any website accessible at the click of a button—are not sufficient for legal compliance and often create more problems than they solve. These tools can interfere with assistive technologies, provide a false sense of security, and actually make the user experience worse for people with disabilities. The only way to achieve genuine accessibility is to properly code and design your website according to WCAG standards.
Q: What's the difference between the EAA and GDPR?
The GDPR focuses on data protection and privacy, while the EAA focuses on accessibility for persons with disabilities. Both are EU laws with extraterritorial application, both require compliance from any organization serving EU markets, and both are enforced by national authorities with significant penalties for non-compliance. However, they address completely different aspects of digital products and services.
Q: How does the EAA relate to the Web Accessibility Directive?
The Web Accessibility Directive (Directive 2016/2102) applies to public sector bodies—government websites, public universities, hospitals, etc. The EAA applies to private sector businesses. Both reference the same technical standard (EN 301 549, which incorporates WCAG 2.1 Level AA), so the actual accessibility requirements are effectively the same. If you're a private company, you follow the EAA; if you're a public body, you follow the Web Accessibility Directive.
Q: How do I know if my website is compliant?
Use our accessibility checker as a starting point—it will automatically identify many common issues. However, automated tools can only catch about 30-40% of accessibility problems. You also need manual testing, including testing with actual assistive technologies (screen readers, voice control, etc.) and ideally user testing with persons with disabilities. Consider hiring an accessibility consultant for a comprehensive audit.
Q: Do I need to make every single page 100% compliant immediately?
For new products and services placed on the market after June 28, 2025, yes—they must be compliant from the start. For existing products and services, you have until June 28, 2030. However, we strongly recommend a phased approach starting now: prioritize high-traffic pages and critical user journeys first, then work systematically through the rest of your content. Document your remediation plan and progress.
Q: What about user-generated content on my platform?
You're not responsible for ensuring that user-generated content is accessible, but you are responsible for ensuring that your platform provides accessible tools for creating content. For example, if you run a blog platform, you must ensure the editor has accessible tools for adding alt text to images, structuring content with headings, etc. You should also encourage users to create accessible content by providing guidance and making accessible features easy to use.
Q: Can I claim disproportionate burden to avoid compliance?
The EAA allows for exemptions based on disproportionate burden, meaning compliance would impose excessive costs relative to your business size or would fundamentally alter the nature of your product. However, this exemption is narrow and requires thorough documentation. You must demonstrate why compliance is disproportionate, what you've already done to improve accessibility, and provide alternative means of access where possible. Don't assume you qualify—consult legal counsel.
Q: What documentation should I keep?
Maintain comprehensive records: accessibility testing results, remediation plans and progress, training records, third-party accessibility audits, user feedback and complaint resolution, documentation of accessibility features in product manuals, and any communications with national authorities. Good documentation demonstrates good faith efforts to comply and can be crucial if disputes arise.
Q: Do I need to support every assistive technology?
No, but you do need to follow accessibility standards that enable compatibility with widely-used assistive technologies. If you properly implement WCAG 2.1 Level AA using semantic HTML and appropriate ARIA attributes, your content will work with the major screen readers (JAWS, NVDA, VoiceOver, TalkBack), voice control software, screen magnifiers, and other assistive tools.
Q: What about mobile apps?
Mobile apps are covered if they provide services falling under the EAA (e-commerce, banking, e-books, transport ticketing, etc.). Mobile accessibility follows similar principles to web accessibility but with platform-specific guidelines: iOS apps should follow Apple's accessibility guidelines and Android apps should follow Google's. The functional requirements are the same—operable with various input methods, screen reader compatible, sufficient contrast, etc.
Q: Are PDFs covered by the EAA?
If PDFs are part of a service covered by the EAA (e.g., bank statements, e-commerce invoices, e-books), they must be accessible. This means properly tagged PDFs with reading order, headings, alternative text for images, form labels, and table structure. Note that PDFs are inherently less accessible than HTML—when possible, provide HTML alternatives or offer the information in multiple formats.
Q: What about video content?
Videos must have captions for deaf and hard-of-hearing users, and should have audio descriptions for blind users when important visual information is present. Live video should have real-time captions when feasible. Media players must have accessible controls, and transcripts should be provided as an additional alternative.
Ready to begin your accessibility journey? Here's what to do next:
