EU: Accessibility Deadline – The European Accessibility Act comes into force

On 28 June 2025, the European Accessibility Act (EAA) came into force across the European Union, harmonising accessibility requirements for many mainstream consumer digital products and services. The EAA will be implemented and enforced through the national laws of each of the 27 Member States.

Sectors in scope of the EAA include e-commerce, telecoms, banking and payment services, passenger transport and media. The EAA’s new framework impacts upon operators across the whole supply and distribution chain of in-scope products and services. Operators offering such products or services in the EU will be subject to the EAA requirements in all EU Member States where they operate, whether or not they are based or established within the EU.

Consequences for non-compliance

The business case for accessibility (i.e. failing to be accessible is refusing service to a largely underserved market) is now going to be accompanied by a compelling legal case.

National regulators now have new powers to address non-compliance through corrective measures (including withdrawing products from the market), fines and penalties. Consumers and representative groups also have rights to being legal proceedings before national courts and tribunals.

In-scope operators are also subject to positive obligations to ensure their products and services are designed and provided to maximise their use by people with disabilities and comply with the EAA’s accessibility requirements.

For products, detailed accessibility requirements cover information and instructions, user interface and functionality design, support services and packaging. Technical documentation and a declaration of conformity must also be drawn up and a CE marking applied to the product by manufacturers. Downstream importers and distributors also have obligations to verify steps in these conformity procedures.

For services, the accessibility requirements apply to digital interfaces, support services, and organisational practices, policies and procedures. Service providers must also prepare and publish a public-facing statements which must include information on the service in accessible formats, how to use the service and how it complies with relevant accessibility requirements.

In the event that a product or service no longer complies with the accessibility requirements, immediate corrective action must be taken to address the non-conformity. In addition, the operator must notify the relevant national regulator of the non-conformity in the countries where the service or product is available. 

Are there any exceptions?

The general rule under the EAA is that all products and services covered by it must comply with its accessibility requirements unless doing so would alter the basic nature of the product or service, or impose a disproportionate burden on the operator. Relying on these exceptions requires a documented assessment.

Transitional measures may ease the transition to compliance for certain operators in limited scenarios. For example, depending on how the EAA has been implemented at national level, EU Member States may allow service providers to continue to provide their services using in-scope products until 28 June 2030 or self-service terminals until the end of their economically useful life (but no later than 20 years from their entry into use), and service contracts agreed before 28 June 2025 may continue without alteration until they expire (but no later than 28 June 2030).

Practical steps for compliance

Due to  the lead time required to implement the changes required to ensure compliance with the EAA, we recommend taking the following actions immediately, along with plans to keep these steps under review and updated where products or services are updated or introduced to the market:

1. Map which of your products and services are in scope and familiarise yourself with the applicable accessibility requirements for each in-scope feature or functionality.
2. Identify which countries or territories are relevant to your business and whether any additional local requirements apply. The EAA is not a full harmonisation law so optional provisions in the EAA (e.g. certain transitional measures) may vary across countries.
3. Assess current conformity levels and conduct a gap analysis to identify whether applicable accessibility requirements are met or whether further measures are required.
4. For operators providing in-scope services, prepare and publish the accessibility notice or statement, ensuring all mandatory information required by the EAA is included.
5. For manufacturers providing in-scope products, draw up technical documentation needed to assess compliance and the required EU declaration of conformity. Importers and distributors will need to confirm that these and certain other information are present with the products.
6. Update internal policies and procedures and train appropriate staff, e.g., staff members who develop or design in-scope products or services, or provide support to consumers using them.
7. Review your vendor/service provider contracts to ensure responsibility for complying with the accessibility requirements is appropriately allocated through the supply chain.

Our infographic, further information and resources

For more information on the EAA and to see a snapshot of the products and services it covers, recommended next steps and enforcement actions, see our infographic here.

For more information on the EAA, please visit our dedicated site where you can find our articles on the EAA including:

• Time to check-out… the European Accessibility Act and its impact on travel, hospitality and leisure
• European Accessibility Act: Focus on Financial Services
• A guide to navigating the European Accessibility Act for online retailers, service providers and platforms
• European Accessibility Act: is it time to update your websites, products & services to meet Europe’s accessibility requirements?

For more information or help with your EAA compliance plans, please contact Deirdre Kilroy and Kelly Mackey.