FAQs about the EAA

These FAQs are updated and checked regularly.

Please contact us if you have any questions or spot any mistakes.

What is the European Accessibility Act (EAA)?

• The European Accessibility Act (EAA) is a landmark legal change that will improve the lives of disabled people by ensuring equal access to digital products and services for European Union (EU) consumers.
• The EAA becomes law in all EU member states on 28 June 2025 and applies to any organisation that provides products and services to consumes in the EU, inclduing businesses and public bodies in the UK.

What are the aims of the European Accessibility Act?

• The EAA aims to improve the lives of disabled and older people in the EU by ensuring equal access to selected products and services within the EU. It also makes it easier for businesses to understand and adopt common standards for digital accessibility.

Who does the European Accessibility Act apply to?

• Unlike previous accessibility legislation, such as the Public Sector Bodies Accessibility Regulations (PSBAR), the EAA is mainly focused on private sector firms, including companies in the UK.
• It applies to any business with at least 10 staff and a turnover above €2 million;
• It applies to any business that trades in the EU
• Companies with headquarters based outside the EU must also comply with the EAA if they sell relevant goods or services within the EU.

What is covered by the European Accessibility Act?

• The EAA applies to any business that provides goods and services to consumers in the EU
• It covers a wide range of goods and services
• It is mainly focused on digital accessibility but it does crossover with physical accessibility
• It will affect any UK business that provides services to EU consumers
• It will also affect any UK business that provides services to public or private bodies that are in scope

What services does the European Accessibility Act cover?

The EAA is largely focused on technology and covers the products and services deemed most important to people with disabilities. These include:

• Computers and operating systems
• Smartphones
• TV equipment and related broadcasting services
• Services related to various forms of transport
• Banking
• E-books
• E-commerce
• ATMs (cash machines), ticketing and check-in machines

Each product or service is covered by specific standards, which identify voluntary requirements and must be met for that product or service to be legally traded inside the EU.

Does the European Accessibility Act apply to the UK?

The EAA will not become part of UK law, but it does apply to any business that provides goods and services to consumers in the EU.

Therefore UK businesses that provides goods and services in the EU must comply with it.

Is the European Accessibility Act already law?

The EAA becomes law on 28 June 2025.

How is the European Accessibility Act being implemented?

Some EU laws are implemented centrally, but for the EAA each member state is publishing their own individual laws and detailed regulations.

They must show who is responsible for its implementation and lay out the monitoring processes and penalties for non-compliance. For example these articles explain how the EAA is being implemented in Ireland and in Germany1.6.

What are the key accessibility requirements of the EAA?

• The EAA requires products and services to be Perceivable, Operable, Understandable, and Robust (known as POUR) which are the underpinning principles of all digital accessibility.
• Our Beginners Guide to Digital Accessibility explains the POUR principles and many other accessibility principles which will be relevant to the EAA.
• Specific requirements exist for different categories, for example self-service terminals need to provide text-to-speech options. Further details are available within the Directive.
• The European Accessibility Act (EAA) establishes common accessibility requirements across the EU for certain products and services.
• However, it does not replace existing national accessibility laws in EU member states. Instead, it complements them, meaning businesses and organisations will need to comply with both the EAA and any relevant national accessibility legislation that remains in force.
• AbilityNet's EAA Readiness Service can help address country-specific requirements on a case-by-case basis, including a referral to a legal partner if required.

What are the benefits of the EAA?

Benefits for businesses

• The EAA introduces common accessibility standards across the EU, helping businesses to be able to compete in new markets throughout the EU with reduced compliance costs.
• The EAA decreases the complexity of navigating different national regulations.
• As disabled consumers seek accessible options, companies that meet these needs can increase their customer base.

Benefits for disabled people

• The EAA ensures a wider range of accessible products and services in the market.
• This means that disabled people and older people will find it easier to use everyday items and access essential services.
• Competition amongst providers and growing use of accessibility by design is likely drive down prices.
• New job opportunities in sectors focused on inclusive design and compliance.

Are there penalties for not complying with the EAA?

Non-compliance with the EAA will result in various penalties, depending on the severity and context - and also which country you are trading in.

Fines and Prison Sentences

• Regulatory authorities in a member state may impose fines on businesses that do not comply with the accessibility standards outlined in the EAA
• The amount of the fine will vary based on the specific location, the nature of the violation and the size of the business
• Ireland's laws can result in prison sentences

Legal Proceedings

• Organisations could face legal action from individuals or advocacy groups representing disabled people
• This could result in lawsuits, court orders or settlements requiring the business to rectify accessibility issues

Reputational Damage

• Non-compliance will harm reputation and lead to negative publicity which affects the brand

Loss of Customers

• Inaccessible products or services alienate potential customers, whereas businesses and organistaions that prioritise accessibility are more likely to attract a diverse customer base

Business Disruption

• Businesses and organisations may be forced to modify products, services or websites to meet EAA standards which will be costly and disruptive

Exclusion from procurement processes

• EAA compliance will become more common in public and private sector procurement requirements
• Non-compliant businesses may be excluded from participating in public procurement processes

How should I prepare for the European Accessibility Act?

The EAA became law on 28 June 2025. To ensure that you are compliant you need to:

• Speak to your legal team to make sure the EAA is on their radar
• Work out how it applies to your business
• Check the accessibility of products and services
• Create a plan to address any concerns 
• Address the priority issues
• Document your plans and create an EAA-compliant version of your accessibility statement
• Adapt your processes to ensure new products and services created after June 2025 are compliant

Our webinar recorded in July 2024 provides a useful introduction to the EAA and discusses the steps organisations need to take to prepare:

You can access the webinar slides, transcript and supporting resources on our website.

We are running a series of webinars in March, April and May 2025.

How are others preparing for the European Accessibility Act?

In July 2024 we spoke with Christopher Patnoe, the Head of EMEA Accessibility and Disability Inclusion at Google, about how they are gearing up to meet the EAA’s requirements, ensuring their products remain accessible and compliant across Europe.

"What was interesting is we started off just looking at the EU declaration as the basis, and then we had to start pulling apart each member state's different implementation of it, and some of them have a fine of money [and] Ireland allegedly has a fine of jail time. This is why you want to partner with your legal team, but also you want to make sure that you focus with the people that understand the law in these different member states."

Christopher Patnoe, Head of EMEA Accessibility and Disability Inclusion at Google

Read the full interview with Christopher Patnoe about how Google is approaching the EAA.

There does not seem to be enough accessibility experts to understand the EAA requirements in economic operators and market surveillance authorities. What can we do to fill the gaps? 

Sabine Lobnig: One recommendation could be to revert them to platforms such as the International Association of Accessibility Professionals (IAAP) and start with the low level certifications. It is important for them to know that there are established syllabi and programmes on how you can get started in accessibility, and that you do not need to find all the necessary information on your own.  

Susanna Laurin: I believe the lack of basic accessibility knowledge among general web professionals (designers, content providers, developers etc.) is a much bigger problem than the lack of accessibility experts (which is also an issue). We need to make sure that higher education and vocational training on “anything” related to web includes digital accessibility. That is the key to sustainable change. DPOs (Disabled People's Organisations) can help by training its own staff and members (there are free trainings online) to become more aware and active in the space. I personally believe the lived experience of inaccessibility is a huge merit to anyone looking for a job in IT (Information Technology) – and demand will increase in 2025. 

Would you recommend an Accessibility Maturity Assessment to work out where a company is now? 

Susanna Laurin: I would recommend to investigate the current status of your website/app/digital services. A maturity assessment could be part of that, as long as it is concrete. 

What are the main differences between EN and Web Content Accessibility Guidelines (WCAG)? 

Susanna Laurin: The EN has a much broader scope since it covers hardware, software etc. and WCAG only covers web (you may also argue that WCAG covers apps, but the jury is still out on that one).  
The EN covers both functional performance and technical requirements, it has an annex on how to select which requirements etc. which the WCAG does not have.  
WCAG on the other hand, has “How to meet,” “Understanding” and “Techniques” documents that the EN does not have.

I'm interested in the implications of the European Accessibility Act (EAA) for the UK. Christopher Patnoe mentioned partial overlap in some other markets. Has the UK adopted any standards since the Public Sector Bodies Accessibility Regulations 2018? 

Susanna Laurin: I am not an expert in UK regulations. Organisations who want to sell products or services in scope of the EAA in the EU will have to comply with the requirements, no matter where they are based. 

What is the uptake from the UK given we are no longer a member state - are they seeing higher levels of positive engagement or just minimum compliance to secure future business? 

Vayia Malamidou: We are seeing an increasing interest in the details of the EAA and its impact on UK-based organisations. As Susanna mentions in the questions above, “organisations who want to sell products or services in scope of the EAA in the EU will have to comply with the requirements, no matter where they are based”. From a business perspective, compliance with the minimum requirements is often the goal but, as the EAA includes principles for design for all, we are also seeing a growing willingness among businesses to go beyond mere compliance. 

How can we encourage action on accessibility from the top of an organisation?  

Sabine Lobnig: Ideally it would be integrated into the corporate culture, but in the beginning most likely there has to be a commitment from the top.  

Susanna Laurin: I believe the drive can come from many levels depending on the type and size of the organisation. But leadership must be onboard, otherwise you risk killing yourself fighting for it. 

May I please ask why EN 301 549 is being used in conjunction with the EAA. I am not suggesting that it should not, but I believe the EAA does not directly reference any kind of technical standard when it comes to compliance. Are people using EN 301 549 as it is the existing standard for the public sector? 

Susanna Laurin: Yes it does. Presumption of conformity is explained in Chapter 6 Article 15(2) of the EAA: “The Commission shall, in accordance with Article 10 of Regulation (EU) No 1025/2012, request one or more European standardisation organisations to draft harmonised standards for the product accessibility requirements set out in Annex I." The standardisation request is called mandate 587. An overview of what the mandate covers is published.

Do you have an opinion on how the EAA might extend to the packaging of products named within the EAA? 

Susanna Laurin: The EAA already covers packaging of products in scope of the act. 

How is compliance with the act monitored? And what are the penalties for non-compliance? 

Sabine Lobnig: Since the EAA is a market access directive, compliance will be monitored by the market surveillance authorities. They are differently organized in the member states. Penalties also differ between member states and range from fees for non-compliance to market withdrawal and in worst case even recall and prison time.

Susanna Laurin: Each member state has/will appoint relevant market surveillance authority/ies to monitor compliance and handle complaints. Penalties are also decided at member state level. 

How alike and how different will this be from the Americans with Disabilities Act in what it requires and how it will be enforced? 

Susanna Laurin: It is extremely difficult to make useful comparisons between US and EU legislation as the whole legal system is so different. It would require many pages to list all the differences. Lainey Feingold and I are making a “US vs EU legislation” session at M-enabling in DC in October, I believe it will be streamed. 

Is there a compliance difference between what is expected of small organisations vs large organisations?

Sabine Lobnig: Microenterprises are mostly exempt. Microenterprise is a business which employs fewer than 10 persons and which has an annual turnover or balance sheet total not exceeding EUR 2 million. 

Susanna Laurin: No. But if a small organisation claims disproportionate burden, it would of course be easier to argue that something is “too expensive” if you have a lower turnover. 

Is compliance currently only based on company size? Any advice on how to push to make changes if we 'technically' are outside the size requirement?  

Sabine Lobnig: We have by now several reports that explain the business benefit of both, including people with disabilities in the workforce, as well as the benefit of accessible products and services to reach a huge target group. One example is the 2023 Accenture report.

Susanna Laurin: Compliance has nothing to do with the size of the organisation in scope of the legislation. There is an exemption for microenterprises. I personally never use legislation as a way to drive change, as that has a tendency to be a race to the bottom (i.e. minimum requirements). Explaining how accessibility can help “maximising the foreseeable use” of a product end/or service is usually a better way forward in my experience. 

Where can we find links to the EAA? For the annexes and standards? 

Sabine Lobnig and Sussana Laurin:

• European Accessibility Act including annexes
• European Accessibility Act 
• Current version of the EN301549 (will be updated) 

In the webinar there was a mention that the Act only requires businesses with 10 or more employees to comply.  As a sole trader am I required to follow these standards and can get fined if I don't?   

Sabine Lobnig: I recommend reading through the parts on Microenterprises in the Act.

Susanna Laurin: Microenterprises providing services are exempt. But not all microenterprises. 

I would like to know if there has been an economic evaluation of the increased sales or turnover for firms when becoming more accessible in Europe, will businesses need a third-party accessibility audit to prove their accessibility? If yes, what qualifications will third party organisation have to offer? Either way, who will guarantee the compliance of businesses? 

Sabine Lobnig: You have three ways of showing compliance with market access directives: 

1. following harmonised standards 
2. self-assessment  
3. notified labs  

The responsible market surveillance authority will check for compliance and is the authority you need to prove compliance to.  

Susanna Laurin: The economic operator is responsible for the accessibility of their product or service. Third part assessment is not needed.  
The business case for accessibility is an eternal discussion. From a scientific point of view it is very hard to prove that increase of sales is happening because of an accessibility problem being solved, because that would require the organisation to do exactly the same marketing etc. for a period of time, measure sales and customer satisfaction (how many started sales but fell out) and then make only specific accessibility remediations and do exactly the same test again. Usually, you do not only make accessibility updates, but you also do several things at once. So how can I know that it was the accessibility solution that made sales increase? 

Our website contains a lot of images of properties, with vast descriptions of holiday lets, can you provide us with some advice on how we would make this accessible? 

Susanna Laurin: I would need to look at the website to say anything useful, but from what you explain, a first step may be to make sure your images have alternative texts. 

Several countries (including Australia, Canada, Kenya, and Mexico) have already adopted EN 301 549 in their own accessibility-related legislation. Do you know which other counties are considering adopting EN 301 549?

Susanna Laurin: I do not believe anyone talked about global adoption, the use of the EN is a decision made by each country individually.  

Can I ask if broadcasters and streaming companies will be required to make their content (i.e. TV shows etc.) accessible? 

Susanna Laurin: Yes. 

Sabine Lobnig: “(…), this Directive applies to the following services provided to consumers after 28 June 2025: (…) (b) services providing access to audiovisual media services. So, yes. Additionally, we have the Audiovisual Media Services Directive (AVMSD) which refers to the EAA for accessibility requirements.  

I work at a UK charity where accessibility is unfortunately not a primary focus. What can I do to shift our attention to better align with EU standards on accessibility? 

Sabine Lobnig: EDF’s European Accessibility Act Toolkit for transposition might be an inspiration, as they list activities that DPOs can do to push for the EAA implementation, but you can extrapolate from there to accessibility in general.  

Susanna Laurin: I would ask: if the charity does important work that they are proud of, or any kind of communication – why would they want to exclude 15-20% of the population from their message? Meeting EU standards may not sound very appealing but taking one or two steps to make sure that their outreach reaches as many as possible may be a way forward.

Could there be any impact to private company products/services that are not listed? 

Susanna Laurin: Indirectly yes. In the EU, we often talk about the “spill-over” effect. When sector A is starting to see accessibility as a natural thing to do, chances are that sector B (where companies do business with sector A) does the same thing. In the long term, the scope of the legislation could of course be widened, but I don’t see that happening any time soon. 

Will companies using accessibility overlays be considered compliant? 

Susanna Laurin: An overlay does not make the website either accessible nor compliant. 

Does the Act also cover educational services? If an educational organisation is based outside the EU but the student is based in an EU country, will this directive apply? 

Susanna Laurin: The EAA covers consumer products and services. 

What advice would you give to someone who has no official role or responsibility regarding accessibility implementation and working for an organisation that is not really supporting these efforts? 

Susanna Laurin: Tricky question without context, but I believe meeting users with disabilities is what usually makes people focus on the topic. And again, I would always recommend investigating the current state – where do we have most challenges – and then start prioritising and acting from there.

Sabine Lobnig: Stress the business benefit and start implementing accessibility now. We have by now several reports that explain the business benefit of both, including people with disabilities in the workforce, as well as the benefit of accessible products and services to reach a huge target group.  One example is the 2023 Accenture report.

Does the act apply to newly generated apps and websites, or if existing (older products) need to be updated by that date as well? 

Susanna Laurin: EAA covers products and services placed on the market after 28 June 2025. 

Do providers of audio visual services have to (mandatory) provide subtitles and audio description, or is the requirement only that if they provide these services, they need to be clear, accessible etc? 

Susanna Laurin: EAA requirements for audiovisual media services are covered in Annex 1 Section 4. 

It is difficult to gauge precisely whether our services (as a UK company) fall under the "Products or Services in scope of the Act". Can you advise where I could go to seek clarification?

Sabine Lobnig: The market surveillance authority or regulator is responsible for your sector. For telecom, it would be Ofcom for instance.  

Susanna Laurin: Read the EAA: Article 2 lists the products and services in scope. Article 3 is a list of definitions.

AbilityNet: Although various people can offer interpretations of the Act we suggest that the only way to remove the risk of misunderstanding is to speak to a legal expert. If you do not have your own legal experrise we have partnered with Russell Cooke as part of our EAA Readiness Service.

It was mentioned that 26 out of 27 EU members have implemented EAA to local law. Which is the missing one? 

Susanna Laurin: All member states have either transposed or are in the process of transposition. Bulgaria hasn’t reported it’s measures to the voluntary repository, but that doesn’t mean they haven’t done anything. 

Will the EAA having an impact on other countries outside of the 'European continent', for example companies like Samsung, Sony, Honor, LG, Huawei, based in Asia? Do you think that changes to products will lead to a push for better global accessibility globally with manufacturers not wanting to re-create devices across regions 'just' to be complaint? 

Susanna Laurin: Yes, definitely. The EAA covers economic operators who want to sell their products or services in the EU. It usually doesn’t make economic sense to sell different versions of products to different regions, therefore it is probable that the EAA will lead to global companies selling (more) accessible products at a global scale.

Sabine Lobnig: Yes. Companies prefer to sell the same device model in all world markets without having to adjust to regional requirements. Hence, why we stressed the importance of global harmonisation. Members of the Mobile & Wireless Forum report on the accessibility features in their devices in the GARI (Global Accessibility Reporting Initiative) database (www.gari.info), which covers all regional requirements.  

Who will be monitoring the compliance of the European Accessibility Act?

Sabine Lobnig: The national market surveillance authorities.  

Susanna Laurin: Surveillance authorities in each member state. 

I work in a web development agency, if we are implementing a website for a client which is a private company are we directly liable under EAA for the accessibility of what is produced, or is that the responsibility of the client? 

Susanna Laurin: The economic operator manufacturing, importing, distributing or representing products or services in scope of the EAA are responsible for meeting the requirements (not the supplier of the website).

But as a supplier to an organisation in scope of the act, you should be careful with the contracts you sign, so that you are in agreement about what happens if your client receives a complaint.

What steps can companies take if they realise that complying with certain standards will result in an undue burden? How can they demonstrate this as part of a procurement process under the EAA? 

Susanna Laurin: This is described in Chapter 4 of the EAA.

AbilityNet: Any organistaion can claim exemption by showing that achieving compliance will be an disproportinate burden on its business, or will fundamentally change the nature of the product. The requirmeents for making a cliam are laid out in CHapter 4 of the EU Directive.

We are a company with less than 10 people and under £2m revenue, so as I understand it, we do not need to be compliant with EAA, but we use bigger vendors to sell eBooks. Will we have to be compliant to keep using these vendors?  

Susanna Laurin: A bigger vendor is in scope of the EAA, so they will need to sell e-books that are compliant. Which indirectly means that you will have to comply as well. 

Are widgets and overlays outright banned to use or can they be used as a tool amongst other things? 

Susanna Laurin: Nothing is banned, but tools added on top of a website does not make the website itself compliant. Some of these tools add more accessibility issues than they claim to solve. 

What is the risk that a lack of harmonisation of member states' regulations could diminish the scope of the EAA? 

Susanna Laurin: Member states can choose to go beyond the minimum requirements, not do less. I don’t see how that could diminish the scope. 

Is there a course available to prepare professionals to fulfil the EAA requirements? 

Sabine Lobnig: The International Association of Accessibility Professionals (IAAP) is working on that.  

Susanna Laurin: There are many providers of courses, for example, the Funka Foundation offers customised courses depending on sector and role. There are quite a lot of free resources online as well, but I am not sure how precisely they focus on the act. 

AbilityNet: We have various training courses and we are starting to include the relevant EAA references.

Does the Act apply to internal/colleague-used systems, as well as external/consumer-used systems? 

Susanna Laurin: The EAA only covers consumer products and services.

Why are schools excluded from EAA? 

Susanna Laurin: That sounds like a misunderstanding. EAA doesn’t define or exclude sectors, it covers products and services. In the Web Accessibility Directive, member states can opt out when comes to schools and kindergarten. 

For a US company that ONLY sells products in the UK, should they be concerned with complying with the EAA? 

Susanna Laurin: Only if the UK decides to implement the EAA, but that is not currently being considered. 

Does the European Commission provide information regarding the EAA? Who has to notify companies of changes in each country? 

Sabine Lobnig: The AccessibleEU Centre is organizing informational events in the members states. Usually, the chambers of commerce inform their members of such regulatory changes.  

Susanna Laurin: European Directives are transposed into national law, so it is up to each member state to inform, monitor enforcement etc of the act. 

We are a B2B consultancy working in the UK (in Ireland) does the EAA apply to B2B or just B2C? 

Susanna Laurin: The EAA covers consumer products and services. 

AbilityNet: It is possible you will included in a supply chain consideration if your customer delivers services to consumers. For example third party plug-ins on a website, or ecommerce platforms.

Would you consider packaging of products part of the scope of the EAA or only in spirit? 

Sabine Lobnig: The EAA specifically says: “In addition to the requirements of Section I, the packaging and instructions of products covered by this Section shall be made accessible, in order to maximise their foreseeable use by persons with disabilities.”  

Susanna Laurin: Packaging of products in scope of the EAA must be accessible. That clearly stated in Annex 1 section 2. 

Do you think this will open more digital accessibility positions in Europe? 

Sabine Lobnig: Yes. 

Susanna Laurin: The demand for accessibility professionals in the EU is already high, and I am convinced it will increase further. 

Does this act also cover elevators? 

Susanna Laurin: Member states may opt in for adding EAA accessibility requirements for the built environment (including elevators) to their national legislation. 

Will businesses need a third-party accessibility audit to prove their accessibility? What qualifications must a third-party organisation have to offer accessibility audits? 

Susanna Laurin: There is no requirement for a third-party assessment. However, the surveillance authority in a member state may choose to set up guidelines around the requirmeents for how the audit is conducted and who conducts the audit. 

Do you have guidance for convincing senior members within an organisation on the importance of accessibility? 

Susanna Laurin: If you want to sell to 15-20% of the population, it makes business sense to provide accessible products and services. In my experience, meeting people with disabilities and seeing how they may struggle with inaccessibility (of your tools) is often what makes people understand the importance. 

Would a radio station streaming their broadcast online need to provide alternative content (subtitles) for people with hearing impairment? 

Susanna Laurin: EAA covers audiovisual media services, not radio stations. 

How can I keep up to date with changes in the EAA?

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