Does the European Accessibility Act Apply to You?

Q: "What sectors does the EAA cover?"

"The EAA targets six service categories and one product category. Services: e-commerce and digital marketplaces, consumer banking and financial services, telecommunications, audiovisual media services, transport booking and ticketing. Products: computers, smartphones, tablets, ATMs, self-service kiosks, e-readers, and consumer hardware with digital interfaces."

Q: "What exactly is the microenterprise exemption?"

"Under Article 4(3) of the directive, a company qualifies as a microenterprise if it has fewer than 10 employees AND annual turnover or balance sheet total at or below EUR 2 million. Both conditions must be met simultaneously. The exemption applies only to service obligations and has no grace period."

Q: "Does the EAA apply to B2B-only services?"

"No. The EAA applies to services provided to consumers. If your platform or service is used exclusively by other businesses with no consumer-facing component, it falls outside the directive's scope."

Q: "What is the technical standard behind the EAA?"

"The EAA references EN 301 549, the European standard for ICT accessibility. For websites and digital interfaces, EN 301 549 aligns with WCAG 2.1 Level AA."

Q: "Is there a grace period for existing products or services?"

"For new products and services, compliance was required from 28 June 2025. For self-service terminals already in use before that date, a transitional period extends until 28 June 2030. There is no grace period for digital services."

Q: "Do I need to publish an accessibility statement?"

"Yes. The EAA requires organizations to make accessibility information publicly available, including a statement describing how products or services meet requirements and a contact mechanism for reporting accessibility issues."

The European Accessibility Act (Directive 2019/882) has been enforceable across all 27 EU member states since 28 June 2025. It covers e-commerce, banking, telecom, media, transport, and consumer hardware. Any company selling to EU consumers is potentially in scope, regardless of where it is headquartered. Microenterprises providing services may qualify for a narrow exemption. Answer five questions to find out where your business stands.

Step 1 of 5

Do you sell or provide products or services to consumers located in the EU?

Step 2 of 5

What best describes what you offer to EU consumers?

Step 3 of 5

How many people work at your company, including founders?

Step 4 of 5

What is your annual turnover or total balance sheet?

Step 5 of 5

Do you manufacture, import, or distribute physical hardware products?

In scope

Yes, the EAA applies to you.

Your business sells or provides covered products or services to EU consumers and exceeds the microenterprise thresholds. The European Accessibility Act has been enforceable since 28 June 2025. Non-compliance can result in fines up to EUR 100,000 or 4% of annual revenue depending on the member state.

The EAA requires WCAG 2.1 Level AA compliance (via EN 301 549) for your websites, mobile apps, and digital interfaces. Each EU member state sets its own penalties and enforcement body.

Audit your website and app against WCAG 2.1 Level AA
Publish an accessibility statement on your site
Ensure TTS and audio content is captioned and transcribed
Verify full keyboard navigation and screen reader compatibility
Review EN 301 549 for any additional requirements specific to your product type
Consult legal counsel for each EU member state you serve

Read our EAA voice guide

In scope: products

Yes, the EAA applies to your products.

The microenterprise exemption covers services only, not physical products. If you manufacture, import, or distribute hardware in scope of the EAA, you must comply with its product requirements regardless of company size or annual turnover.

Services you offer alongside those products may still qualify for the microenterprise exemption. Product obligations and service obligations are assessed separately under the directive.

Review Annex I of Directive 2019/882 for product-specific requirements
Ensure device interfaces include text-to-speech output where applicable
Provide product information in accessible formats (braille, large print, electronic)
Apply CE marking obligations for in-scope hardware categories
Consult a legal advisor for your specific product category and target markets

Likely exempt

You may qualify for the microenterprise exemption.

Under Article 4(3) of the EAA, microenterprises providing services (fewer than 10 employees and annual turnover or balance sheet at or below EUR 2M) are exempt from mandatory EAA service requirements. This exemption does not apply if you manufacture or distribute physical products in scope of the directive.

This exemption disappears the moment you hire a 10th employee or exceed EUR 2M in turnover, with no grace period. If public procurement is a goal, many tenders now require EAA compliance even from small vendors.

Confirm your headcount and turnover remain below both thresholds
Plan for compliance before hiring your 10th employee
Check your member state's national law, as some exceed the EAA minimum requirements
Voluntary compliance broadens your addressable market significantly

Read our EAA voice guide

Not in scope

The EAA does not apply to you.

The European Accessibility Act applies only to entities that place products or services on the EU consumer market. If you have no customers or users in EU member states, you are outside its scope. If you expand to EU markets, you will need to reassess.

The EAA applies to any company targeting EU consumers, regardless of where the company is headquartered. A US or UK business that begins acquiring EU users falls in scope from that point onward.

Outside scope

Purely B2B services are outside EAA scope.

The EAA applies to services "provided to consumers." Software platforms and digital services used exclusively within businesses, with no consumer-facing access, are outside the directive's scope. If any part of your product reaches end consumers, that portion is back in scope and must be assessed separately.

Your business customers may still require EAA compliance from you as part of their own supply chain obligations, particularly if they are building consumer-facing products with your tools or infrastructure.

Check with legal counsel

Your offering may not fall within the EAA's defined scope.

The EAA explicitly covers e-commerce, banking, telecom, media, transport, and a defined list of hardware products. If your service does not fit any of these categories, it may fall outside the directive's current scope. However, the categories are interpreted broadly, and national implementations vary across the 27 EU member states.

When in doubt, review Annex I of Directive 2019/882 directly and consult a legal advisor in the relevant member states. The EAA acts as a minimum floor: individual countries may apply broader requirements.

Frequently asked questions

What sectors does the EAA cover?

The EAA targets six service categories and one product category. Services: e-commerce and digital marketplaces, consumer banking and financial services, telecommunications, audiovisual media services, transport booking and ticketing. Products: computers, smartphones, tablets, ATMs, self-service kiosks, e-readers, and consumer hardware with digital interfaces. Internal enterprise tools and purely B2B platforms are outside scope.

What exactly is the microenterprise exemption?

Under Article 4(3) of the directive, a company qualifies as a microenterprise if it has fewer than 10 employees AND annual turnover or balance sheet total at or below EUR 2 million. Both conditions must be met simultaneously. The exemption applies only to service obligations. If you manufacture, import, or distribute physical hardware products covered by the EAA, the exemption does not apply regardless of company size. The exemption has no grace period: crossing either threshold makes you subject to the full requirements immediately.

Does the EAA apply to B2B-only services?

No. The EAA applies to services “provided to consumers.” If your platform or service is used exclusively by other businesses with no consumer-facing component, it falls outside the directive’s scope. However, your business customers may require EAA compliance from you as part of their own supply chain obligations, particularly if they build consumer-facing products using your tools.

What is the technical standard behind the EAA?

The EAA references EN 301 549, the European standard for ICT accessibility. For websites and digital interfaces, EN 301 549 aligns with WCAG 2.1 Level AA. WCAG (Web Content Accessibility Guidelines) is maintained by the W3C and covers perceivability, operability, understandability, and robustness. Organizations planning for long-term compliance should also review WCAG 2.2, published in October 2023.

Is there a grace period for existing products or services?

For new products and services, compliance was required from 28 June 2025. For self-service terminals (ATMs, ticket machines, kiosks) already in use before that date, a transitional period extends until 28 June 2030. There is no grace period for digital services: websites, apps, and platforms must comply now. There is also no grace period for companies crossing the microenterprise thresholds.

Do I need to publish an accessibility statement?

Yes. The EAA requires organizations to make accessibility information publicly available. This means publishing a statement describing how your products or services meet the applicable requirements, providing a contact mechanism for users to report accessibility issues, and keeping both up to date. Several member states have specified additional requirements for the format and content of these statements.