European Accessibility Act
2019 European Union directive
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Through Disability, Smartphone and E-commerce
Originally proposed in 2011, this act was built to complement the EU's Web Accessibility Directive which targets the public sector and became law in 2016. It also reflects the obligations of the UN's Convention on the Rights of Persons with Disabilities. It includes a wide range of systems including personal devices such as computers, smartphones, e-books, and TVs, as well as public services like television broadcast, automated teller machine (ATMs), ticketing machines, public transport services, banking services, and e-commerce sites.
The laws, regulations and administrative provisions necessary to comply with this Directive have to be adopted and published by the member states by 28 June 2022. Three years later, in 2025, the requirements of the European Accessibility Act must have been implemented.
Compliance deadline (2025)
Under the provisions of the European Accessibility Act (EAA), all relevant products and services made available on the EU market must now comply with accessibility requirements defined by the directive. The EAA aims to improve the functioning of the internal market for accessible products and services by removing barriers created by divergent rules in different member states. It is also intended to improve access for persons with disabilities and the elderly.
The requirements and obligations of this Directive do not apply to microenterprises providing services within the scope of this Directive – whereby ‘microenterprise’ means an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding €2 million or an annual balance sheet total not exceeding €2 million.
The European policy of applying "Design for all" principles on digital technology led to the creation of the European Harmonized Accessibility Standards EN 301 549 which defines "Accessibility requirements suitable for public procurement of ICT products and services in Europe".
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Key requirements
The EAA outlines general accessibility standards for all products and services within its scope with additional requirements for specific products and services.
For products, businesses must:
- Design products to maximise usability for individuals with disabilities;
- Provide accessible instructions for use and maintenance;
- Ensure packaging and support services are accessible;
For services, requirements include:
- Ensuring websites and mobile apps are accessible;
- Providing information on service features in accessible formats;
- Offering customer support systems that cater to people with disabilities;
These standards aim to improve usability and foster inclusivity across the EU.
Conformity assessment
The European Accessibility Act allows economic operators to declare their own conformity with the directive. Unlike some other CE-marking directives, the EAA does not provide for notified body involvement or third-party certification.
For products, the route is set out in Article 14 and Annex IV — the internal production control procedure, based on Module A of Decision No 768/2008/EC. The manufacturer prepares the technical documentation, carries out the conformity assessment, issues the EU declaration of conformity, and applies the CE marking.
Services follow a different mechanism. Under Article 13 and Annex V, the provider assesses its own compliance and publishes that assessment in its general terms and conditions or an equivalent public document. The published text must describe the service, explain how it works, and set out how each applicable accessibility requirement is met.
In both cases, responsibility for the assessment rests with the economic operator. Technical documentation — or, for services, equivalent records — must be retained and made available to national market surveillance authorities on request. Those authorities may verify the self-assessment against the requirements of the directive. Application of the harmonised standard EN 301 549, cited in the Official Journal under the directive, confers a presumption of conformity.
Accessibility widgets
Accessibility widgets are generally not sufficient on their own to address all requirements of the European Accessibility Act (EAA) or the Web Content Accessibility Guidelines (WCAG).
Such widgets typically operate as user interface layers that provide optional adjustments to visual presentation, including changes to text size, color contrast, or font appearance. These features may improve usability for some users but do not alter the underlying structure or source code of a website.
Meeting WCAG success criteria and related accessibility legislation commonly involves changes to website markup, semantics, and interaction patterns, such as proper use of HTML elements, form labeling, keyboard navigation, and compatibility with assistive technologies. For this reason, accessibility widgets are often described as complementary tools rather than replacements for code-level accessibility remediation.
Country-specific requirements
This Directive, has been transposed into national laws by each Member State. Each nation has implemented it in their own way, producing a range of specific legal texts, enforcement authorities, and penalties. Each country may have their own legislation which will restrict the use of lawsuits.

