What is the EAA? A guide to the European Accessibility Act

Although the EU and most member states have ratified the UN Convention on the Rights of Persons with Disabilities—committing to accessibility laws—inconsistencies in national regulations create challenges for people with disabilities and businesses navigating different regulatory requirements. The EAA addresses these challenges by creating a common set of accessibility requirements that safeguard the rights of individuals with disabilities and ease compliance burdens for businesses operating across the European single market.

What is the EAA?

Simply put, the EAA mandates that certain products and services in the EU be designed 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 ageing populations. While ageing individuals may not identify as part of the disability community, they share similar challenges, such as reduced mobility, declining eyesight, hearing loss, and decreased dexterity. As a result, implementing the EAA is a means of future proofing products and services for all of us.

Because of its dual aim of supporting both individuals and businesses, the EAA applies to those products and services identified as the most important for people with disabilities and the most likely to have inconsistent accessibility standards across member states.

The Directive sets out broad accessibility requirements alongside more detailed rules for packaging, instructions, user interfaces, and support services. For example, websites and mobile apps must meet WCAG 2.1 standards; computers and smartphones need accessibility features like screen readers and text-to-speech; and self-service terminals must offer accessible interfaces, such as audio guides and screen reader support.

The EAA specifies which functionalities must be accessible without dictating how companies should implement them. Instead, it builds on the accessibility requirements laid out in existing EU laws—such as those covering public procurement and transport—without altering existing sector-specific legislation on accessibility. 

What companies, services, and products does the EAA affect?

The EAA doesn’t apply to all manufacturers and service providers in the EU, but it does cover companies that manufacture, distribute, import, or provide specific products and services.

When it comes to these selected products and services, the EAA applies to all businesses trading within the EU, no matter where they are based. It covers both private- and public-sector +companies, with exemptions for businesses with fewer than 10 employees and a turnover of less than €2 million. The regulation sets out accessibility requirements for manufacturers, distributors, and importers operating within the EU, including those selling through e-commerce platforms.

Services covered by the EAA

The EAA applies to the following services:

• 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.

Products covered by the EAA

The EAA also applies to the following products:

• ATMs, ticketing, and check-in machines,
• smartphones,
• TV equipment related to digital television services,
• telephony services and related equipment,
• interactive self-service terminals providing information,
• computers, terminal equipment, and operating systems, and
• e-readers.

What effect does the EAA have on the built environment?

While the EAA does not prescribe requirements for the built environment, its annex provides physical infrastructure standards for buildings where EAA-covered digital services are provided–such as bank branches, public transport stations, retail stores, and other public spaces—thereby ensuring that people with disabilities can access these services in practice.

For example, a retail banking building should have accessible entrances so that all people can use its internal electronic banking terminals and kiosks. Otherwise, having accessible electronic terminals does not result in the universal usability that the EAA intends to facilitate. Likewise, banks should have clear floor space, adequate circulation areas, and appropriate height and reach ranges so that wheelchair users can easily use the ICT within the building.

Built environment accessibility standards for buildings covered by the EAA

Buildings in which EAA-covered services are provided should adhere to universal design principles, which create spaces that can be used by all people, regardless of their abilities.

Specific built environment features include:

• Wheelchair-accessible entrances, which have aspects such as step-free access, ramps, automatic doors, and other facets that support easy access for wheelchair users;
• Accessible toilets, which include features such as wide doors, support rails, and sufficient space for maneuvering; 
• Elevators and lifts with multisensory communication, which make multistory buildings accessible to people with mobility, visual, and auditory impairments; and
• Accessible signage, which includes high-contrast signs with text and pictograms as well as braille and tactile signage in certain public areas, like at ATMs and in elevators.

Implementation deadline

The European Parliament and EU Council passed the EAA in 2019, with implementation set for 28 June 2025. Since the EAA is a directive, member states had to incorporate its requirements into their national laws—a process known as transposition—by 28 June 2022.

From 28 June 2025, any new products and services entering the EU market must comply with the EAA. However, businesses have until 28 June 2030 to update products and services already on the market, giving them a five-year transition period to align existing offerings, contracts, and systems with the new accessibility standards.

Self-service terminals get an additional grace period: they can remain in use until the end of their economically useful life or for a maximum of 20 years, whichever comes first.

The EAA and market access

When consumers examine most products purchased in the EU, they often notice the CE (Conformité Européene) marking. These letters indicate that the product meets strict safety, health, and environmental standards. To trade within the European Economic Area (EEA), manufacturers, importers, and distributors must ensure that their products—including digital ones—carry the CE marking.

The EAA and the national laws implementing it tie accessibility requirements to the existing CE certification process. Quite simply, if a product does not meet accessibility standards, it will not receive the CE mark and therefore cannot be manufactured, sold, imported, or distributed in the EU market.

What is a conformity assessment?

Before a product can be sold in the EU, it must undergo a conformity assessment to ensure compliance with relevant safety, health, and environmental regulations. This process includes testing, inspection, and certification, following procedures specified in various pieces of legislation.

Once a product passes the assessment and receives the CE mark, it can be traded freely within the single market. Consumers throughout the EU benefit from consistent standards for health, safety, and environmental protection, while the CE mark also promotes fair competition because it holds all companies accountable for the same requirements.

The EAA and CE marking

Under the EAA, businesses must now demonstrate that their products meet accessibility requirements to obtain a CE mark. By integrating accessibility into this existing compliance system, the EAA builds on a process with which market participants are already familiar.

Typically, the manufacturer is responsible for securing a CE mark, but importers must also ensure that the products they bring into the EU are properly certified. Similarly, distributors must verify that products bear a CE mark before placing them on the market. This chain of responsibility helps ensure accountability across the supply chain.

Once a product receives CE marking, it remains subject to ongoing monitoring and reporting to confirm continued compliance. The mark remains valid indefinitely, provided there are no major changes to the product—such as modifications to its operation, intended use, components, or suppliers. If significant changes occur, the company must update its Declaration of Conformity.

Enforcement of the EAA

Each EU member state must designate a market supervisory body to oversee compliance with the EAA, though enforcement strategies may differ because of variations in national law implementation.

Manufacturers, distributors, and importers are required to report any instance of non-compliance if they become aware that a product does not meet accessibility requirements. When notifying authorities, manufacturers must also outline the steps they have taken—or plan to take—to bring the product into compliance. They must retain all related records, and supervisory bodies can request technical documentation and additional information to verify compliance. Although distributors and importers must report non-compliant products, they are not responsible for ensuring compliance—that duty falls on manufacturers.

Supervisory bodies may also proactively monitor products and conduct spot checks to enforce compliance. Additionally, consumers and consumer organisations can file complaints with authorities regarding non-compliant products.

Penalties for non-compliance

Each EU member state determines its own penalties for non-compliance, which may include fines and imprisonment. However, the most significant consequence for many businesses is exclusion from the European market—since products without a CE mark cannot be traded within the EU. Failing to meet accessibility requirements means failing the conformity assessment, effectively blocking market access.

The EAA in Ireland

Ireland implemented the EAA through the European Union (Accessibility Requirements of Products and Services) Regulations 2023. This legislation clarifies how the EAA applies at the national level. For instance, it confirms that the built environment is not covered for in-scope services and that Ireland will use the grace period for self-service terminals.

The regulation also designates supervisory bodies responsible for enforcement:

• Competition and Consumer Protection Commission (CCPC): All products subject to the EAA as well as e-books, dedicated software, and e-commerce services
• Commission for Communications Regulation: Electronic communications services
• Coimisiún na Meán: Services providing access to audiovisual media
• Irish Aviation Authority: Transport services
• National Transport Authority: Transport services
• Central Bank of Ireland: Consumer banking services

The regulation has also granted special advisory status to the National Disability Authority so that it can support these supervisory bodies with accessibility requirements.

Penalties

Ireland’s regulation states that companies—as well as their directors, secretaries, and other officers—can be held liable for breaches. Penalties depend on the severity of the infringement and include:

• fines of up to €5,000 and up to six months’ imprisonment for lesser offences, and
• fines of up to €60,000 and up to 18 months’ imprisonment for more serious offences.

The long-term impact of the EAA

The European Accessibility Act represents a significant step toward a more inclusive society by making both digital and the built environment more welcoming, safer, and usable for people with disabilities across the EU.

Its main goal—and likely outcome—is a more accessible European market for people with disabilities, which will feature more inclusive products and services at competitive prices. Additionally, people with disabilities will face fewer barriers when accessing transportation, education, and the job market. It is likely that the EAA will also create jobs that benefit individuals with disabilities by increasing the demand for accessibility expertise.

Beyond these individual benefits, the EAA may also benefit businesses. A common set of accessibility rules will reduce market fragmentation, simplify cross-border trade, and lower compliance costs for companies operating across the EU. Moreover, market opportunities will expand as the high demand for accessible products and services continues to grow alongside an ageing EU population, creating room for innovation and business growth.

This guide draws heavily on the work of Disability IN. For a comprehensive overview of disability inclusive legislation in the EU, check out A Legal Analysis to Guide Corporate Responsibilities Under New EU Disability Inclusive Legislation.