When did the EAA take effect?

Enforcement began 28 June 2025. Member states transposed it into national law by 28 June 2022; covered businesses had three years to prepare. Services contracts in force on 28 June 2025 enjoy a transition to 28 June 2030.

Who has to comply with the EAA?

Manufacturers, importers and distributors of in-scope products (e-readers, computers, ATMs, self-service terminals) and providers of in-scope services (banking, e-commerce, transport, e-comms, ebooks, audiovisual). Micro-enterprises (<10 employees, <€2m turnover) are exempt for services only.

Does the EAA apply to non-EU companies?

Yes — if you place products on the EU market or provide services to EU consumers, the EAA applies regardless of your headquarters location. US, UK, Indian and Chinese vendors are all in scope when selling to the EU.

What is EN 301 549 and how does it relate to the EAA?

EN 301 549 is the harmonised European standard for digital accessibility, maintained by ETSI, CEN and CENELEC. It incorporates WCAG 2.1 AA and adds hardware/software/documentation requirements. Conformance to EN 301 549 creates a presumption of EAA conformance.

What are the penalties for non-compliance?

Penalties are set per member state and vary widely. Examples: Germany up to €100,000; Ireland up to €60,000 or 18 months imprisonment; Spain up to €1,000,000 for serious repeated infringements. Some states also allow product/service withdrawal orders.

What is the "disproportionate burden" exception?

Covered entities may claim partial exemption if compliance would impose a disproportionate burden, assessed under Annex VI criteria (cost of compliance vs entity size, importance to disabled users, expected use). The exception must be documented and reviewed every five years or on significant change.

How is the EAA enforced?

Each member state designates a national market surveillance authority (e.g. Germany's BFA, Ireland's NDA, France's ARCOM). Authorities respond to consumer complaints, conduct audits, issue corrective orders and impose fines.

When did the EAA take effect?

Enforcement began 28 June 2025. Member states transposed it into national law by 28 June 2022; covered businesses had three years to prepare. Services contracts in force on 28 June 2025 enjoy a transition to 28 June 2030.

Who has to comply with the EAA?

Manufacturers, importers and distributors of in-scope products (e-readers, computers, ATMs, self-service terminals) and providers of in-scope services (banking, e-commerce, transport, e-comms, ebooks, audiovisual). Micro-enterprises (<10 employees, <€2m turnover) are exempt for services only.

Does the EAA apply to non-EU companies?

Yes — if you place products on the EU market or provide services to EU consumers, the EAA applies regardless of your headquarters location. US, UK, Indian and Chinese vendors are all in scope when selling to the EU.

What is EN 301 549 and how does it relate to the EAA?

EN 301 549 is the harmonised European standard for digital accessibility, maintained by ETSI, CEN and CENELEC. It incorporates WCAG 2.1 AA and adds hardware/software/documentation requirements. Conformance to EN 301 549 creates a presumption of EAA conformance.

What are the penalties for non-compliance?

Penalties are set per member state and vary widely. Examples: Germany up to €100,000; Ireland up to €60,000 or 18 months imprisonment; Spain up to €1,000,000 for serious repeated infringements. Some states also allow product/service withdrawal orders.

What is the "disproportionate burden" exception?

Covered entities may claim partial exemption if compliance would impose a disproportionate burden, assessed under Annex VI criteria (cost of compliance vs entity size, importance to disabled users, expected use). The exception must be documented and reviewed every five years or on significant change.

How is the EAA enforced?

Each member state designates a national market surveillance authority (e.g. Germany's BFA, Ireland's NDA, France's ARCOM). Authorities respond to consumer complaints, conduct audits, issue corrective orders and impose fines.

European Union (all 27 member states) · 2019

European Accessibility Act (EAA)

The European Accessibility Act (Directive (EU) 2019/882) is the EU's prescriptive accessibility law that takes effect 28 June 2025, requiring covered products and services — banking, e-commerce, transport, audiovisual media, ebooks and computer hardware — to meet harmonised accessibility requirements derived from EN 301 549 and WCAG 2.1 AA.

What is EAA?

Adopted in 2019 with a six-year transposition runway, the EAA harmonises accessibility law across the EU to remove internal-market fragmentation. Member states transpose the directive into national law; enforcement, penalties and exemptions are then set per country. Penalties range from administrative fines (€10,000) to criminal liability and product-withdrawal orders in serious cases. The enforcement date — 28 June 2025 — has now passed; market surveillance is active.

Who does EAA apply to?

Manufacturers of in-scope products placed on the EU market
Service providers offering in-scope services to EU consumers
Importers and distributors with EU presence
Micro-enterprises (<10 employees, <€2m turnover) are exempt for services only

Scope

Consumer banking services
E-commerce (B2C online sales)
Air, rail, water, bus passenger transport
Audiovisual media services and devices
Electronic communications services
E-readers and ebooks
Self-service terminals (ATMs, ticket machines)
Consumer computer hardware and operating systems

Penalties for non-compliance

Germany: up to €100,000 administrative fine + suspension of service
France: up to €75,000 + daily penalty up to €3,000
Italy: up to €40,000 + product/service withdrawal
Ireland: up to €60,000 / 18 months imprisonment
Spain: up to €1,000,000 for repeat serious infringements

How to comply with EAA

Confirm in-scope status. Determine whether your product/service falls under EAA scope and whether you sell into the EU. Confirm whether micro-enterprise exemption applies.
Map requirements to EN 301 549. The harmonised standard EN 301 549 incorporates WCAG 2.1 AA for web/mobile and adds requirements for hardware, software, documentation, and support.
Audit and remediate. Run combined automated + manual audit. Remediate at source. Prioritise authentication, payment, search and core transaction flows.
Publish an EAA accessibility statement. Per Article 13. Disclose conformance, exceptions claimed (disproportionate burden, fundamental alteration), and contact for complaints. Sample templates available from national bodies.
Maintain market surveillance readiness. Keep technical documentation, conformity assessments, and ACR/VPAT current. Be prepared for member-state authority requests.

Comparisons

EAA vs ADA: EAA is product/service-prescriptive (covers specific sectors). ADA is a broad civil-rights statute covering "public accommodations." EAA is enforced by market surveillance; ADA is enforced by lawsuits and DOJ action.
EAA vs EN 301 549: EN 301 549 is the harmonised technical standard the EAA references. Conformance to EN 301 549 creates a presumption of conformance to the EAA.
EAA vs WCAG 2.2: EAA references EN 301 549, which currently incorporates WCAG 2.1 AA. The standard is expected to update to WCAG 2.2 AA in coming revisions.
EAA vs Web Accessibility Directive: WAD (2016) covers public-sector bodies. EAA (2019/2025) covers private-sector products and services. The two are complementary.

Authoritative sources

Directive (EU) 2019/882 (European Accessibility Act) — European Union
EN 301 549 v3.2.1 — ETSI

A note on widgets and overlays

Can an accessibility widget make your site compliant?

No. Widgets adjust how content renders for individual visitors — text size, contrast modes, dyslexia-friendly fonts. They do not remediate the underlying source code. WCAG conformance is graded at source level, and US federal courts (Murphy v. Eyebobs, Suarez v. Camping World, Hernandez v. Caesars) have repeatedly held that the presence of an overlay does not preclude ADA liability.

Our product produces an IAAP-format audit report with source-level remediation guidance. If you want a preferences panel for end users, ship one separately — opt-in, disclosed, and never marketed as a compliance solution.

See the Overlay Fact Sheet, signed by 900+ accessibility professionals.

FAQ

EAA — frequently asked questions

Cited answers. Sourced. Updated as standards and case law change.

When did the EAA take effect?
Enforcement began 28 June 2025. Member states transposed it into national law by 28 June 2022; covered businesses had three years to prepare. Services contracts in force on 28 June 2025 enjoy a transition to 28 June 2030.
Who has to comply with the EAA?
Manufacturers, importers and distributors of in-scope products (e-readers, computers, ATMs, self-service terminals) and providers of in-scope services (banking, e-commerce, transport, e-comms, ebooks, audiovisual). Micro-enterprises (<10 employees, <€2m turnover) are exempt for services only.
Does the EAA apply to non-EU companies?
Yes — if you place products on the EU market or provide services to EU consumers, the EAA applies regardless of your headquarters location. US, UK, Indian and Chinese vendors are all in scope when selling to the EU.
What is EN 301 549 and how does it relate to the EAA?
EN 301 549 is the harmonised European standard for digital accessibility, maintained by ETSI, CEN and CENELEC. It incorporates WCAG 2.1 AA and adds hardware/software/documentation requirements. Conformance to EN 301 549 creates a presumption of EAA conformance.
What are the penalties for non-compliance?
Penalties are set per member state and vary widely. Examples: Germany up to €100,000; Ireland up to €60,000 or 18 months imprisonment; Spain up to €1,000,000 for serious repeated infringements. Some states also allow product/service withdrawal orders.
What is the "disproportionate burden" exception?
Covered entities may claim partial exemption if compliance would impose a disproportionate burden, assessed under Annex VI criteria (cost of compliance vs entity size, importance to disabled users, expected use). The exception must be documented and reviewed every five years or on significant change.
How is the EAA enforced?
Each member state designates a national market surveillance authority (e.g. Germany's BFA, Ireland's NDA, France's ARCOM). Authorities respond to consumer complaints, conduct audits, issue corrective orders and impose fines.

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