European Accessibility Act
What is the European Accessibility Act?
European Accessibility Act (EAA) is the EU directive that requires a defined set of consumer products and services, including e-commerce, to meet common accessibility requirements in every member state. It was adopted as Directive (EU) 2019/882 and has applied to covered businesses since 28 June 2025.
Before the EAA, accessibility rules differed from one member state to the next, which meant a merchant selling across the EU faced a patchwork of national standards. The directive replaces that patchwork with one baseline, so a checkout built to meet it in Germany also meets it in Spain. For online sellers, the practical scope is the whole purchase path: product pages, account creation, the , and the customer support channels attached to them.
Key facts
- Legal reference: Directive (EU) 2019/882 of the European Parliament and of the Council
- Applies from: 28 June 2025, after a member-state transposition deadline of 28 June 2022
- Technical benchmark: the harmonised standard EN 301 549, which incorporates WCAG 2.1 level AA for web content
- Covered services: , consumer banking, electronic communications, e-books, transport ticketing, and audiovisual media access services
- Covered products: computers, smartphones, e-readers, payment terminals, and self-service terminals such as ATMs and ticketing machines
- Enforced by: national market surveillance and service-compliance authorities designated by each member state
Key requirements
The directive sets functional outcomes rather than a list of prescribed techniques. Information has to be presented through more than one sensory channel, interfaces have to work without relying on a single input method, and content has to be readable by assistive technology such as screen readers. Conformity with EN 301 549 creates a presumption of conformity with the directive.
For a card payment flow, that translates into a specific set of obligations:
- Every field in the carries a programmatic label, so a screen reader announces what the field is for rather than reading an unlabelled box.
- Errors are identified in text, not by colour alone, and the error text says what to correct. A declined card or a mistyped expiry date produces a message an assistive technology can read.
- The full checkout is operable by keyboard, with a visible focus indicator, since a customer using switch access or a screen reader never touches a pointer.
- Timeouts on the payment session can be extended or turned off, which matters when a step adds time to the flow.
- Text and interactive controls meet the contrast ratios in WCAG 2.1 level AA.
- The service publishes accessibility information describing how the service meets the requirements.
Payment terminals and self-service terminals carry hardware obligations as well, including tactile identification of keys and speech output for anything shown on screen.
Who it applies to
The EAA reaches manufacturers, importers, distributors, and service providers that place covered products or services on the EU market. Establishment outside the EU doesn't remove the obligation: a merchant based anywhere that sells to EU consumers falls in scope for the services it offers them.
Scope turns on the consumer relationship. A service is covered when consumers, meaning people acting outside their trade or profession, can use it. Purely B2B services sit outside the directive because no consumer is on the receiving end.
Two carve-outs and two transitional rules narrow the picture:
- Microenterprises providing services are exempt. The EU definition is fewer than 10 employees and annual turnover or balance sheet total of €2 million or less. The exemption covers services only, not products.
- Disproportionate burden can be claimed for specific requirements, but it has to be assessed, documented, and made available to the authorities on request.
- Service contracts concluded before 28 June 2025 may run unchanged until they expire, and no longer than five years from that date.
- Self-service terminals lawfully in use before 28 June 2025 may stay in service until the end of their economically useful life, capped at 20 years from entry into use.
Penalties for non-compliance
The directive doesn't set a single EU-wide fine. Each member state defines its own penalties, which the directive requires to be effective, proportionate, and dissuasive, so the exposure for the same failing differs between countries. Alongside financial penalties, authorities can require a non-conforming product to be brought into conformity, withdrawn from the market, or recalled.
Enforcement runs through two routes. National authorities carry out market surveillance and act on complaints, and member states also have to give consumers and representative bodies a way to take action under national law when a service falls short. A merchant selling across several EU markets can therefore face parallel proceedings over one inaccessible checkout.
