The European Accessibility Act (EAA), formally Directive (EU) 2019/882, is the most significant piece of accessibility legislation to come out of Europe. It went into force on June 28, 2025, requiring that a broad range of products and services sold in the European Union meet harmonized accessibility standards. If your business offers digital products or services to EU customers, the EAA almost certainly applies to you — regardless of where your company is headquartered.

What the EAA Covers

The EAA applies to products and services placed on the EU market or provided to EU consumers after June 28, 2025. The scope is deliberately broad:

  • E-commerce websites and mobile applications: Any online store or service platform accessible to EU consumers.
  • Banking and financial services: Online banking, ATMs, payment terminals, and financial service applications.
  • Telecommunications: Phone services, messaging platforms, and related equipment.
  • Transport services: Ticketing, check-in, real-time travel information, and self-service terminals for air, bus, rail, and waterborne transport.
  • E-books and dedicated reading software.
  • Consumer hardware: Computers, smartphones, tablets, self-service terminals, and consumer equipment with interactive computing capability.

The key thing to understand is that the EAA regulates the products and services themselves, not just the organizations. If you sell a SaaS product to customers in the EU, the product must be accessible — even if your company is based in the United States, Canada, or anywhere else.

Technical Requirements: EN 301 549 and WCAG

The EAA does not define its own technical standard. Instead, it references the European harmonized standard EN 301 549, which in turn maps to WCAG 2.1 Level AA for web content and incorporates additional requirements for software, hardware, and documentation. If your web content meets WCAG 2.1 AA, you have covered the web-specific portion of the technical requirements. However, EN 301 549 goes further:

  • Software must be compatible with assistive technologies through platform accessibility APIs.
  • Documentation and support services must themselves be accessible.
  • Hardware with interactive elements must meet tactile and physical accessibility requirements.
  • Real-time communication features must support text alternatives to voice (real-time text, or RTT).

Many organizations are targeting WCAG 2.2 AA rather than 2.1 AA, since 2.2 is the current standard and includes additional criteria that address real user needs. Meeting WCAG 2.2 AA ensures you meet 2.1 AA by definition.

The Microenterprise Exemption

The EAA provides a limited exemption for microenterprises — companies with fewer than 10 employees and an annual turnover or balance sheet total not exceeding 2 million euros. Microenterprises that provide services (not products) are exempt from the EAA requirements. However, this exemption is narrower than it appears: it only applies to service providers, not to manufacturers, importers, or distributors of products. And member states may choose to implement the directive more strictly, potentially narrowing the exemption further.

Timeline and Transition Period

The EAA was adopted in April 2019. EU member states were required to transpose it into national law by June 28, 2022. The enforcement date was June 28, 2025. There is a transition period for service contracts entered into before June 28, 2025 — these may continue under their existing terms until June 28, 2030. After that date, all products and services within scope must comply, regardless of when the contract was signed.

For products already placed on the market before June 28, 2025, there is also a transition: they can continue to be offered until June 28, 2030, provided no significant modifications are made. But any new product or updated product entering the market after the enforcement date must comply from day one.

Enforcement and Penalties

Enforcement is handled by each EU member state through its own market surveillance authorities. The EAA requires member states to establish penalties that are "effective, proportionate, and dissuasive." This means fines and enforcement actions vary by country. Some member states have defined specific fine amounts, while others have granted their authorities broad discretion. In practice, enforcement is expected to be complaint-driven initially, with market surveillance authorities responding to reports from consumers and disability organizations.

Step-by-Step Compliance Path

  1. Determine applicability: Map your products and services against the EAA scope. Identify which of your offerings are sold or provided to EU consumers and which fall within the regulated categories.
  2. Conduct a gap assessment: Audit your current products and services against EN 301 549 and WCAG 2.1 AA (or 2.2 AA). Identify where you fall short and prioritize by severity and user impact.
  3. Build a remediation roadmap: Create a prioritized backlog of accessibility issues. Focus first on critical and serious barriers — issues that prevent users from completing tasks. Then address moderate issues that cause significant difficulty.
  4. Integrate accessibility into your development process: Train your designers and developers on accessibility fundamentals. Add accessibility acceptance criteria to your user stories. Include automated accessibility testing in your CI pipeline.
  5. Create an accessibility statement: The EAA requires that service providers make information available about how their services meet the accessibility requirements. Publish a clear accessibility statement that describes your conformance status, known limitations, and how users can report barriers.
  6. Establish ongoing monitoring: Accessibility is not a one-time project. Set up regular audits, user testing with people with disabilities, and internal review processes to maintain conformance as your products evolve.
  7. Prepare compliance documentation: Maintain records of your accessibility efforts, including audit results, remediation timelines, and testing methodologies. Market surveillance authorities may request this documentation.

Non-EU Companies: Yes, It Applies to You

A common misconception is that the EAA only applies to EU-based companies. In reality, the EAA applies to any economic operator placing products on the EU market or providing services to EU consumers. If a user in Germany can sign up for your SaaS platform, the EAA applies. The regulation follows the product and the consumer, not the headquarters of the company.

The EAA represents a fundamental shift in how the European Union approaches digital accessibility. Unlike previous directives that focused primarily on public sector websites, the EAA brings the private sector fully into scope. The organizations that treat this as an opportunity to improve their products — rather than a checkbox to satisfy regulators — will be the ones that come out ahead.