The European Accessibility Act (EAA) applies to private-sector economic operators that place specific products or provide specific services on the EU market after June 28, 2025. This covers manufacturers, importers, distributors, and service providers tied to in-scope products like computers, smartphones, e-readers, self-service terminals, and ticketing machines, along with services such as ecommerce, banking, e-books, electronic communications, and audiovisual media access services. Microenterprises offering services are exempt. Public sector bodies fall under the separate Web Accessibility Directive, not the EAA.
| Category | Who Is Covered |
|---|---|
| Economic operators | Manufacturers, importers, distributors, service providers |
| Products in scope | Computers, smartphones, ATMs, ticketing terminals, e-readers, TV equipment |
| Services in scope | Ecommerce, banking, e-books, telecoms, audiovisual media access, transport info |
| Exemptions | Microenterprises providing services (under 10 employees and under 2M euro turnover) |
| Effective date | June 28, 2025 |
Which Economic Operators Are Covered
The EAA places obligations on four roles in the supply chain. Each carries a different responsibility, but every role connects back to keeping in-scope products and services accessible.
Manufacturers design and produce the product. They carry the heaviest burden because accessibility starts at the design stage. Importers bring products from outside the EU into the market and verify the manufacturer met requirements. Distributors sell within the EU and confirm proper labeling and documentation are in place. Service providers offer the in-scope services directly to consumers in the EU.
If your company sits in any of these roles and touches an in-scope product or service, the EAA applies.
What Products Fall Under the EAA
The product list is specific. The Act does not cover every consumer product, only those tied to information access and communication.
Computers and operating systems. Smartphones and other communications devices. TV equipment related to digital television services. E-readers. Self-service terminals (ATMs, ticketing machines, check-in kiosks, payment terminals).
If your product is on this list and you sell it in the EU, you fall under the Act regardless of where your company is headquartered.
What Services Fall Under the EAA
Services in scope tend to be the area most companies overlook, especially U.S. companies selling into Europe. The service categories are broad and capture a wide range of digital business models.
Ecommerce (any business-to-consumer online sales). Banking and financial services for consumers. Electronic communications services. Services providing access to audiovisual media. E-books and dedicated e-reading software. Air, bus, rail, and waterborne passenger transport services (specifically the digital information components).
An ecommerce store based in the United States that ships to consumers in Germany is covered. A SaaS banking app used by Spanish consumers is covered. Geographic location of the company does not determine coverage. The customer location does.
Who Is Exempt From the EAA?
Microenterprises that provide services are exempt. A microenterprise is defined as a business with fewer than 10 employees and either an annual turnover or balance sheet total not exceeding 2 million euros.
This exemption applies only to service providers, not to microenterprises that manufacture in-scope products. A small electronics manufacturer still needs to comply even if it has five employees.
Public sector bodies are not covered by the EAA. They fall under the EU Web Accessibility Directive, which has been in effect since 2016 and applies to public sector websites and mobile apps.
Does the EAA Apply to Companies Outside the EU?
Yes. If a company outside the EU places in-scope products on the EU market or offers in-scope services to consumers in the EU, the Act applies. This is one of the most misunderstood points.
An ecommerce brand in the U.S. that has European customers needs to meet EAA requirements for its website, checkout, and product information. The same is true for SaaS companies, fintech apps, and any digital service with EU users.
Member states enforce the Act within their borders. Penalties vary by country but include fines and orders to remove non-conforming products from the market.
What Standards Apply for Conformance?
The EAA references EN 301 549 as the harmonized standard. EN 301 549 incorporates WCAG 2.1 Level AA for web and mobile content, plus additional requirements for hardware, software, and documentation.
For most digital services, meeting WCAG 2.1 AA through a thorough accessibility audit is the practical path to demonstrating conformance. Hardware and self-service terminals carry additional technical criteria beyond WCAG.
How Companies Should Approach EAA Conformance
The starting point is determining whether your company is covered. Map your products and services against the in-scope categories. Confirm your customer geography. Identify your role in the supply chain.
From there, conduct an audit against EN 301 549 (or WCAG 2.1 AA for web and mobile content). The audit identifies issues that need remediation. After fixes are made and validated, you produce documentation showing conformance, similar in concept to an ACR for U.S. procurement.
Scans alone do not meet the bar. Scans only flag approximately 25% of issues. EAA conformance requires a manual evaluation by qualified auditors.
Frequently Asked Questions
Does the EAA apply to my U.S. based ecommerce store?
If you sell to consumers in any EU member state, yes. The Act applies based on where your customers are, not where your business is registered. Any EU consumer transactions place you within scope.
Are B2B SaaS companies covered by the EAA?
The Act focuses on services offered to consumers. Pure B2B SaaS is generally outside the consumer scope, but if your platform reaches end consumers (for example through embedded ecommerce or banking features), those consumer-facing parts fall under the Act.
What happens if my company does not comply?
Each member state sets its own penalties. Consequences range from fines to product market withdrawal. National enforcement bodies investigate complaints and conduct compliance checks.
Is there a grace period after June 28, 2025?
Some transitional provisions apply for service contracts already in place and for self-service terminals already in use. New products and new service contracts must meet requirements from the effective date forward.
Does the EAA require a specific document like the ACR?
The Act requires technical documentation demonstrating conformance and an EU declaration of conformity for products. Services require accessible information about how the service meets requirements. The format differs from a U.S. ACR but the underlying purpose, proving conformance, is comparable.
Coverage under the European Accessibility Act comes down to three questions: what you sell, who you sell to, and what role you play in the supply chain. Answer those three and you know where you stand.
Contact me for help with EAA conformance: Contact Kris Rivenburgh.