European Accessibility Act

Directive (EU) 2019/882 sets accessibility requirements for specified products and services. Its main application date was June 28, 2025, with transitional provisions and exceptions that need to be checked for the actual offering. Having EU customers alone does not answer every scope question.

Updated September 11, 2026 · whatisADA / Grow Wild Agency

Start with a covered category

Article 2 identifies the covered products and services. Product categories include specified consumer computer hardware and operating systems, payment and other self-service terminals, certain consumer terminal equipment and e-readers. Service categories include specified electronic communications, access to audiovisual media services, parts of passenger transport services, consumer banking, e-books and ecommerce services. Each category has definitions and conditions.

For a website, determine the service it provides and its connection to a covered offering. A business outside the EU can still have relevant obligations when offering covered products or services in the EU. Review the national implementing law and the role the business plays in the supply chain.

The microenterprise exemption is specific to services

Article 4(5) exempts microenterprises providing services from the directive’s service accessibility requirements. Article 3(23) defines a microenterprise as employing fewer than 10 persons and having annual turnover or an annual balance-sheet total not exceeding €2 million. The financial test uses either measure, and a value of exactly €2 million is within the threshold.

This service exemption does not exempt covered products. Other laws, contracts or funding conditions can still require review. Confirm the relevant business figures and legal entity instead of inferring an exemption from a website’s size or revenue estimate.

WCAG is one part of technical evaluation

WCAG helps evaluate web content, including structure, names, keyboard operation, contrast and error recovery. The EAA’s requirements also address the covered product or service, information and support in the relevant scope. Passing a WCAG scan is not a complete EAA assessment.

When relying on a harmonised standard or technical specification for a presumption of conformity, check the current official reference and the requirements it covers. Do not assume that an EN 301 549 version cited for another legal framework automatically establishes the same status under the EAA.

Review dates, transitions and claimed exceptions

Check Article 32 and the applicable national implementation for transitional provisions. A claim based on fundamental alteration or disproportionate burden requires the assessment and documentation applicable to that provision; it is not a general exemption obtained by installing a widget or publishing a statement.

Enforcement and penalties are implemented by member states. Review the current national law for the relevant country rather than relying on an uncited table of maximum fines.

A practical review sequence

  1. Identify the legal entity, covered category, market and relevant national implementation.
  2. Document the product or service boundary, including purchase, support, documents and third-party interfaces.
  3. Confirm the technical requirements and any documented exception or transition.
  4. Evaluate complete user journeys using automated checks, rendered-browser testing and assistive technology.
  5. Assign repairs, retest the results and keep the supporting information current.

Sources and next steps

This is general educational information. Confirm legal applicability and any claimed exemption with a qualified adviser using the actual facts and current national rules.