The European Accessibility Act

Why it matters

The Web Accessibility Directive covers only public sector bodies. The European Accessibility Act (EAA) fills the gap by extending accessibility requirements to the private sector across multiple product and service categories. For accessibility practitioners in Europe, the EAA is the most commercially significant piece of accessibility legislation in a generation. (BoK p. 62)

What the EAA is

Directive 2019/882, commonly called the European Accessibility Act, was adopted in 2019. It required EU member states to transpose it into national law by June 2022, and covered entities must comply from 2025. (BoK p. 62)

Unlike the WAD, the EAA applies to private sector companies. It is a product-and-service accessibility directive: it requires that certain categories of consumer-facing products and services meet functional accessibility requirements. (BoK p. 62)

In-scope products and services

The EAA covers a defined list of products and services, including:

Products:

• Computers and operating systems
• Payment terminals and ticket vending machines
• ATMs (automated teller machines)
• Consumer equipment for electronic communications
• E-readers and e-book reading devices

Services:

• Electronic communications services (telephone, messaging)
• E-commerce (online retail)
• Banking services (consumer banking including online banking)
• E-books and related software
• Audiovisual media services
• Transport services (air, bus, rail, waterborne) — passenger-facing information and ticketing

(BoK p. 62) (BoK p. 63)

Microenterprise exemption

The EAA includes an exemption for microenterprises: companies in the services sector with fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million. These businesses are exempt from the services provisions of the EAA (though not from product requirements). The exemption recognizes that very small service providers may lack resources for full compliance. (BoK p. 63)

Supporting standards: EN 17210 and EN 17161

Two European standards support EAA compliance in specific areas:

EN 17210 specifies functional accessibility requirements for the built environment — the physical spaces and infrastructure within which many covered services are delivered. It provides a standard for accessible buildings and outdoor spaces.

EN 17161 is the Design for All standard. It provides a methodology for embedding accessibility systematically in the design and development of products and services, helping organizations comply proactively rather than retrofitting.

(BoK p. 63)

Real-world example

A bank operating across several EU member states has been preparing for the EAA since 2022. Its online banking portal is an in-scope service. The bank conducts an accessibility audit against EN 301 549, fixes identified barriers, and publishes an accessibility statement. Its physical branch ATMs — also covered by the EAA — are assessed against EN 301 549 hardware requirements. The bank’s legal team checks whether any of its subsidiaries qualify for the microenterprise exemption and concludes they do not. The bank was not previously covered by the WAD (which applies only to public sector bodies), so the EAA represents an entirely new legal obligation for it.