Four practical steps for navigating the built environment component of the European Accessibility Act

The European Accessibility Act (EAA) aims to make products and services more accessible for the EU's approximately 87 million people with disabilities. It mandates that companies design certain products and services so that people with disabilities can use them fully and equally. By enhancing accessibility, the EAA improves both the lives of people with disabilities and the usability of products and services for our ageing population, helping to ensure that everyone can participate fully in society.

The EAA is a wide-reaching regulation, with steep non-compliance penalties. While its primary focus is on the accessibility of digital products and services, many companies operating within the EU will also need to ensure that their service areas have an accessible built environment to achieve compliance.

Implementing these new requirements can be challenging, and knowing where to begin can be difficult. Below are four practical steps that companies can take to navigate the built environment requirements of the European Accessibility Act.

Step 1: Understand the regulation

It may sound obvious, but understanding the details of the regulation is key for ensuring compliance.

The EAA only covers specific products and services, so it doesn’t apply to all manufacturers and service providers in the EU. The legislation applies to companies that manufacture, distribute, import, or provide specific products and services identified as essential for enabling people with disabilities to fully participate in society.

Although the EAA doesn’t explicitly prescribe detailed requirements for all aspects of the built environment, its annex includes infrastructure standards for buildings providing EAA-covered services. These services include: electronic communications services, services providing access to audiovisual media services (e.g. television broadcast), transport services, consumer banking services, e-books, and e-commerce services.

That means that places providing these services—such as bank branches, public transport stations, retail stores, and more—must ensure that people with disabilities can access them in practice. For example, a retail bank must have accessible entrances so that all users can access its internal electronic banking terminals and kiosks. Otherwise, making the electronic terminals accessible does not achieve the aims of the EAA because individuals with mobility impairments cannot realistically access them.  

Step 2: Evaluate the accessibility of your physical environments

Assess the built environment in which EAA covered services are offered.

Look for features that could create potential barriers for some people, thinking inclusively about a range of impairments and disabilities. Evaluate exterior and interior spaces, considering the areas both as a whole and as multiple subareas. Review the accessibility of each one, considering everything from the overall structure to the smallest details of each feature.

Companies can begin by focusing on some specific built environment features that fall in-scope for compliance with the EAA. For instance, they’ll need wheelchair-accessible entrances, which include step-free access or ramps. They’ll also need accessible toilets with aspects like wide doors, support rails, and enough space for manoeuvring.

Elevators should include multisensory features—braille buttons, audio announcements, and visual displays—to accommodate people with visual or hearing impairments. Likewise, companies should ensure that they have accessible signage and wayfinding in public areas, which includes high-contrast signs with information displayed in text, pictograms, and braille.

After assessing general building features, evaluate areas specific to the provided services.
For example, retail banks may need to make changes to teller service areas. The waiting area should contain multiple seating options (e.g. armchairs, seats with backrest, seats of varied heights, seats with cushioning)  for those waiting in the queue who cannot stand for long periods. The position and design of the service counters should facilitate easy access and communication between staff and customers, including those of shorter stature, those using mobility devices, and those with hearing impairments. If a glazed screen is in place, then a speech enhancement intercom should be available for use.

Step 3: Make your plan now

The EAA’s implementation deadline is 28 June 2025. Some adjustments to physical environments—such as rearranging furniture for manoeuvrability, fitting support rails, or installing audioloops—don’t require much planning or cost much. However, other updates could require larger investments and more preparation time.

For instance, ramp installation or doorway widening require relatively significant capital expenditure. Some adjustments can also cost more than expected: While a single sign doesn’t cost much, creating and installing signage for an entire building can add up.

Companies in historic buildings or neighborhoods may find that national conservation regulations might prohibit certain building modifications. In these cases, a company may need to seek planning permission before making changes, and, depending on the updates required, they may need to implement alternative approaches to achieve their accessibility goals, such as installing a platform lift instead of a ramp. Alternative approaches can come with additional long-term considerations. For example, platform lifts have additional costs, such as regular maintenance service, and can need trained staff nearby to assist with their usage.

Plan now to ensure that your company has the appropriate lead time and budget to make the appropriate changes.

Step 4: Continuously assess and improve

After making necessary changes to their built environment, seek ongoing customer feedback. If customers identify issues that the first round of adjustments haven’t addressed, make plans to address these issues as quickly as possible.

Enforcement strategies will vary from country to country, but all EU member states will have a market supervisory body that oversees compliance. These supervisory bodies can proactively conduct spot checks to enforce compliance. Some countries also have complaint mechanisms that enable consumers to take legal action against noncomplaint businesses.
To maintain compliance, continually respond to feedback and assess the built environment, particularly after making any changes to the physical environment, such as renovations.

Ideally, buildings with EAA-covered services will adhere to universal design principles, which create spaces that can be used by all people, regardless of their abilities. Companies should make an effort to follow these principles as they make adjustments to achieve EAA compliance, and moving forward, they should use universal design principles whenever making physical modifications to ensure service areas remain accessible for everyone.

Rather than focusing on the challenges, it’s important to view the EAA as a valuable tool that helps create a more inclusive future. As our population ages, many of us will face changes in mobility, hearing, vision, and cognition. The EAA is a powerful tool that helps ensure everyone remains part of a welcoming, accessible, and user-friendly society.