The European Accessibility Act for digital products: does it apply to you?
Gideon Awolesi ·
The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. If you sell an online shop, a consumer banking product, an e-book, or a transport booking service to consumers in the EU, it very likely applies to you, even if your company is based in the UK or the US. This guide goes through who's covered, what you have to do, and which standard to build to, with the article numbers so your legal team can check them.
01Which digital products and services are covered
The Act covers a set list of products and a set list of services provided to consumers. For software teams, the services are what matter most:
- E-commerce services
- Consumer banking services, including payment services, credit agreements, and e-money
- E-books and the software used to read them
- Electronic communications services
- Services that give access to audiovisual media
- The websites, apps, e-tickets, and real-time travel information of air, bus, rail, and waterborne passenger transport
The products include consumer computers and operating systems, smartphones and other consumer devices used for communication or media, e-readers, and self-service terminals like ATMs, ticket machines, and check-in machines.
E-commerce is defined broadly. Article 3(30) calls it services "provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract." So if a consumer can buy something from you through your website or app, assume you're in scope.
02Companies outside the EU
Nothing in the Act exempts companies based outside the EU. Article 3(4) defines a service provider as anyone "who provides a service on the Union market or makes offers to provide such a service to consumers in the Union." What counts is where your customers are. A US SaaS company selling to consumers in Germany has the same obligations as a German one.
03The microenterprise exemption
Microenterprises that provide services are exempt from the accessibility requirements under Article 4(5). A microenterprise is a business with fewer than 10 people and an annual turnover or balance sheet total of no more than €2 million.
It's important that you read this carefully, because it only covers services. A microenterprise that makes or sells covered products still has to comply. It just gets lighter paperwork when it relies on the exceptions in Article 14.
04The dates that matter
| Date | What happens |
|---|---|
| 28 June 2025 | The Act applies to new products and services (Article 31). |
| 28 June 2030 | The transition ends for services that keep using products they already used lawfully before 28 June 2025 (Article 32). |
| Up to 5 years | Service contracts agreed before 28 June 2025 can continue unchanged until they end, but for no more than five years from that date. |
| Up to 20 years | Member states may let self-service terminals already in use stay in use until the end of their useful life, capped at 20 years. |
05Which standard to build to
The European standard for digital accessibility is EN 301 549. The version most teams use as their benchmark today is v3.2.1 from 2021, which is based on WCAG 2.1 level AA.
A new version, EN 301 549 V4.1.1, was published on 2 September 2026. It adopts WCAG 2.2 as the benchmark for websites, software, and documents, and it's the first version written with the Accessibility Act in mind. It isn't yet cited in the EU's Official Journal. Ireland's National Disability Authority expects that to happen on 16 December 2026.
So if you're designing or fixing something now, build to WCAG 2.2 AA. It adds new success criteria on top of 2.1, like minimum target sizes and accessible authentication, and it's where the legal reference is heading.
06What you have to do
Article 13 sets out what service providers have to do:
- Design and provide the service in line with the accessibility requirements in Annex I.
- Publish accessibility information, in your general terms and conditions or an equivalent document, describing the service and how it meets the requirements (Annex V). This is often called an accessibility statement.
- Keep that information available for as long as the service is running, and keep the service compliant as it changes.
- If the service stops conforming, fix it and inform the national authorities in the countries where you provide it.
07The two exceptions
Under Article 14, the requirements don't apply where meeting them would fundamentally alter the basic nature of the service, or would impose a disproportionate burden. You make that assessment yourself using the criteria in Annex VI, keep the results for five years, and inform the authorities that you're relying on it. You can't claim a disproportionate burden if you've received outside funding to improve accessibility.
08Penalties
Each member state sets its own penalties, and Article 30 only requires them to be effective, proportionate, and dissuasive. In Germany, for example, the law that transposes the Act allows fines of up to €100,000 for offering a non-compliant service. Because the amounts vary so much, check the rules in each country you sell into.
09Where to start
- List the journeys a consumer goes through to buy or use your product, like sign-up, checkout, and account management.
- Run a free automated scan on them to catch the obvious problems.
- Test those journeys by hand with a keyboard and a screen reader, because that's where a lot of the problems a scan misses show up.
- Write and publish your accessibility information.
If you'd like us to do the manual testing, our Accessibility Audit covers up to five key journeys against WCAG 2.2 AA in two weeks, and includes a draft accessibility statement.