European Accessibility Act
European Accessibility Act
Overview
The European Accessibility Act (EAA) harmonizes accessibility requirements for products and services across EU Member States. It ensures people with disabilities have equal access to digital and physical products and services.[1]
From June 28, 2025, covered products and services placed on the market must meet accessibility requirements.
Products and Services in Scope
Products (Annex I)
- Computers and operating systems
- Self-service terminals: ATMs, ticket machines, check-in kiosks
- Consumer terminal equipment: Phones, tablets, TV equipment
- E-readers
Services (Annex II)[2]
- E-commerce services: Online shops and marketplaces
- Banking services: Consumer banking accounts
- Electronic communications: Telephone and messaging services
- Audiovisual media services: Video on demand, catch-up TV
- E-books and dedicated software
- Transport services: Passenger transport information and ticketing
- Websites and mobile applications of in-scope services
Accessibility Requirements
Core Principles
Products and services must be designed to maximize:
- Perceivability: Information and UI accessible to senses
- Operability: Navigation and controls usable by all
- Understandability: Content and operation comprehensible
- Robustness: Compatible with assistive technologies
Technical Standards
Compliance can be demonstrated through:
- EN 301 549: European accessibility standard incorporating WCAG 2.1 Level AA
- WCAG 2.1 AA: Web Content Accessibility Guidelines
- Harmonized standards: Published in Official Journal
Specific Requirements for Digital Services[3]
| Requirement | Description |
|---|---|
| Keyboard accessibility | All functionality via keyboard |
| Screen reader compatibility | Semantic HTML, ARIA labels |
| Focus indicators | Visible focus states |
| Text alternatives | Alt text for images, captions for video |
| Color contrast | Minimum 4.5:1 for normal text |
| Resize support | Content readable at 200% zoom |
| Error identification | Clear error messages and recovery |
| Consistent navigation | Predictable interface patterns |
Cookie Banner Accessibility
Cookie consent interfaces must be accessible:
- Keyboard navigable
- Screen reader compatible
- Clear focus indicators
- Sufficient color contrast
- Operable without timeout pressure
Exceptions
Microenterprises
Businesses with both: fewer than 10 employees, AND annual turnover or balance sheet ≤€2 million are exempt from service requirements (not product requirements).
Disproportionate Burden
Organizations may claim exemption if compliance would require significant change to fundamental nature of product/service or impose disproportionate financial burden. Must be assessed per product/service with documented justification.
Legacy Content
- Products placed on market before June 28, 2025 may continue in use
- Self-service terminals: 20-year transition for existing machines
- Service contracts existing before June 2025: grace period until June 2030
Penalties
Member States determine penalties, which must be effective, proportionate, and dissuasive.
Non-compliant products may be withdrawn from market.
Developer Action Items
Immediate Actions
- Audit existing services against EN 301 549/WCAG 2.1 AA
- Prioritize critical user journeys for accessibility remediation
- Update design systems with accessible components
- Train development teams on accessibility requirements
Technical Implementation
- Semantic HTML structure
- ARIA labels where semantic HTML insufficient
- Keyboard navigation for all interactive elements
- Skip links for main content
- Form labels and error handling
- Image alt text and video captions
- Color contrast verification
- Responsive design and zoom support
- Focus management for dynamic content
- Accessibility statement publication
Ongoing Compliance
- Automated accessibility testing in CI/CD
- Manual testing with screen readers
- User testing with people with disabilities
- Regular accessibility audits