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European Accessibility Act (EAA): Website and App Requirements

The European Accessibility Act has applied since 28 June 2025. It requires many consumer-facing websites, apps and digital services in the EU to be accessible. This guide explains who is covered, what the technical benchmark is, and how AccessibilityScore.in helps find the barriers to fix first.

Last reviewed by the HalfAccessible accessibility team

Short Answer

The European Accessibility Act (Directive (EU) 2019/882) requires covered products and consumer services in the EU, including e-commerce, consumer banking, e-books, electronic communications and passenger transport websites and apps, to be accessible from 28 June 2025. Microenterprises providing services are exempt. EN 301 549, now aligned with WCAG 2.2 in version 4.1.1, is the usual technical benchmark.

Key facts

Legal act
Directive (EU) 2019/882, the European Accessibility Act
National laws due
28 June 2022
Applies from
28 June 2025
Services covered
E-commerce, consumer banking, e-books, electronic communications, access to audiovisual media, passenger transport websites, apps and ticketing
Microenterprise exemption
Service providers with fewer than 10 staff and annual turnover or balance sheet of no more than EUR 2 million
Technical benchmark
Harmonised standards give a presumption of conformity; EN 301 549 is the reference in practice: V3.2.1 uses WCAG 2.1, V4.1.1 (September 2026) aligns with WCAG 2.2 and maps directly to the EAA
Transition for existing products in services
Until 28 June 2030

Who has to comply with the EAA?

The EAA applies to businesses that place covered products on the EU market or provide covered services to consumers in the EU. For websites and apps, the services that matter most are:

  • E-commerce services: online shops and marketplaces selling to consumers
  • Consumer banking services
  • E-books and dedicated reading software
  • Electronic communications services, such as phone and messaging providers
  • Services providing access to audiovisual media, such as TV and streaming access
  • Air, bus, rail and waterborne passenger transport: websites, mobile apps, e-tickets, travel information and self-service terminals

Are small businesses exempt from the EAA?

Microenterprises that provide services are exempt from the accessibility requirements. The Directive defines a microenterprise as one that employs fewer than 10 people and has an annual turnover, or an annual balance sheet total, of no more than EUR 2 million.

The exemption is for services. Microenterprises that make or sell covered products are not exempt in the same way, although the Directive asks member states to give them guidance. A business that has grown past either threshold is in scope.

What technical standard does the EAA use?

The Directive itself does not name WCAG. It sets functional accessibility requirements, and products and services that follow harmonised standards published in the Official Journal of the EU are presumed to meet them.

In practice, teams use EN 301 549, the European standard for ICT accessibility. Version 3.2.1 (2021), long the benchmark under the EU's Web Accessibility Directive, bases its web requirements on WCAG 2.1 Level AA. Version 4.1.1, adopted in August 2026 and published in September 2026, aligns them with WCAG 2.2 and adds an annex mapping the standard to the EAA's requirements. Building to WCAG 2.2 AA covers both versions.

What content and transition periods are excluded?

The Directive excludes some website and app content, and gives time for existing services:

  • Pre-recorded video and audio published before 28 June 2025
  • Office file formats, such as PDF and Word, published before 28 June 2025
  • Online maps, if essential navigation information is provided accessibly
  • Third-party content the business does not fund, develop or control
  • Archived websites and apps whose content is not updated or edited after 28 June 2025
  • Products already used to provide a service may continue until 28 June 2030; service contracts agreed before 28 June 2025 may run until they expire, but no longer than five years

How should EU-facing teams use an accessibility checker?

Start with an automated scan of your highest-traffic templates, such as the home page, product listings, product pages, basket and checkout, and fix the failures it reports. Then test the full purchase or account journey with a keyboard and a screen reader, because that is where EAA complaints will focus.

The EAA also requires service providers to publish information on how their service meets the accessibility requirements, so keep records of what you tested and fixed. Penalties and enforcement are set nationally by each member state; check the law in the countries where you sell.

EAA vs the Web Accessibility Directive

AspectEuropean Accessibility ActWeb Accessibility Directive
Legal actDirective (EU) 2019/882Directive (EU) 2016/2102
Who it coversPrivate businesses offering covered products and consumer servicesPublic sector bodies' websites and apps
Applies from28 June 2025Already in force for public sector sites and apps
Technical benchmarkHarmonised standards; EN 301 549 in practiceEN 301 549 (V3.2.1: WCAG 2.1; V4.1.1: WCAG 2.2)
Small business exemptionMicroenterprises providing servicesNot applicable

Common Questions

When did the European Accessibility Act start to apply?

On 28 June 2025. Member states had to adopt their national laws by 28 June 2022.

Does the EAA apply to companies outside the EU?

It applies to covered products placed on the EU market and covered services provided to consumers in the EU, so non-EU companies selling to EU consumers can be in scope. Check with a lawyer for your situation.

Does the EAA require WCAG?

Not by name. It sets accessibility requirements and presumes conformity for harmonised standards. EN 301 549 is the practical benchmark; its 2026 version, V4.1.1, aligns with WCAG 2.2.

Is my small online shop exempt from the EAA?

If it is a microenterprise, meaning fewer than 10 employees and no more than EUR 2 million annual turnover or balance sheet total, its services are exempt. Above either threshold, the requirements apply.

Do old PDFs and videos have to be made accessible?

Not if they were published before 28 June 2025. Office files and pre-recorded media published after that date are in scope.

What are the penalties for not complying with the EAA?

Each member state sets its own penalties, which the Directive requires to be effective, proportionate and dissuasive, with remedial action for non-compliance. Amounts and enforcement bodies differ by country.

Can an automated scan show EAA compliance?

No. A scan finds common WCAG failures to fix first, but compliance depends on the full service, including tasks and content a tool cannot judge.

Sources

  1. EUR-Lex: Directive (EU) 2019/882 (European Accessibility Act)
  2. European Commission: European Accessibility Act
  3. ETSI: EN 301 549 V4.1.1 (2026-09)
  4. ETSI: EN 301 549 V3.2.1
  5. W3C WAI: EU accessibility policies
  6. W3C: Web Content Accessibility Guidelines (WCAG) 2.2
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