Time to check-out… the European Accessibility Act and its impact on travel, hospitality and leisure

The European Accessibility Act (Directive (EU) 2019/882) or EAA is a significant legislative measure aimed at improving accessibility for consumers with disabilities across the European Union. The EAA identifies specific products and services which fall within its scope, impacting various sectors, including travel, hospitality and leisure. The EAA becomes binding across all EU member states from 28 June 2025. 

The EAA seeks to give effect to the obligations of each of the EU and its Member States as parties to the United Nations Convention on the Rights of Persons with Disabilities and to promote “full and effective equal participation by improving access to mainstream products and services that, through their initial design or subsequent adaptation, address the particular needs of persons with disabilities.”

During preparatory work on the EAA a decade ago, passenger transport, e-commerce and hospitality were all identified as being priority sectors for reform. Hospitality fell away as a separate category during legislative development but certain categories within scope of the EAA are relevant to each of these sectors, including hospitality, which we explore briefly below. 

The EAA and travel, hospitality and leisure

The EAA applies to a number of products and services, and the following are those most relevant to travel, hospitality and leisure:

• e-commerce services which cover the online sale of any product or service, including booking flights, rental cars, excursions, events, and accommodation.
• The following elements of air, bus, rail and waterborne passenger transport service passenger transport services: 
  • websites, 
  • mobile apps, 
  • electronic tickets, 
  • transport service information (including real-time travel information), and
  • interactive self-service information terminals located in the EU.
• The following products where used to provide the above passenger transport services: ticketing machines, check-in machines and interactive information kiosks. 
• point-of-sale devices and other payment terminals.
• The physical spaces used by clients of services covered by the EAA (such as passenger transport and e-commerce services) may apply where the Member State implements the EAA’s optional requirements concerning the built environment. These may apply, for example, to the environment in which ticketing machines and information kiosks are placed in an airport or railway station.

For all in-scope services, they must conform with the EAA’s accessibility requirements as and from 28 June 2025. Some exceptions and transitional measures may apply to products used within the service or certain contracts already in existence by that date, but generally, there is no holiday from compliance for in-scope service providers. 

For in-scope products, those supplied for distribution, consumption or use in the EU after 28 June 2025 must comply with the EAA’s accessibility requirements. Those already supplied or placed on the EU market prior to that date are not subject to the EAA’s accessibility requirements.

If the service or product is made available on the market in any EU country, it is in-scope even if the service provider or manufacturer is located outside the EU.

Opportunities for the travel, hospitality and leisure sector

The EAA will apply to the websites and platforms of travel operators and online e-commerce services for booking flights, accommodation and other activities. From this initial point, the EAA introduces accessibility requirements to a wide range of steps in the consumer journey.

According to data published in January 2025 by the European Disability Expertise (EDE) for the European Commission, 27% of the EU population over the age of 16 has a disability. For many travellers, booking a trip often begins online. Two recent surveys of over one million websites across a range of industries worldwide found travel and hospitality websites to be among those with the most significant accessibility issues. For travellers with disabilities, barriers to accessibility online can be commonplace and lead to a frustrating, sometimes unnavigable, planning and booking experience. For the operator, they signal lost revenue and opportunities. Where operators address accessibility shortcomings on their sites and platforms, they stand to benefit from the spending power of a significant cohort of consumers with disabilities.

How we can help your compliance programme take off

We are currently assisting a wide range of operators in the sector in addressing their requirements, with approaches varying depending on their role in the supply chain, the jurisdictions in which they operate, and the nature of the products or services of their business that are in-scope of the EAA.

Ahead of 28 June 2025, in-scope operators (as well as their suppliers and vendors) should:

1. Assess whether your product, service, or space is within scope and familiarise yourself with the applicable accessibility requirements for each in-scope element.
2. Identify which territories are relevant to your business and whether any additional local requirements apply through national implementing laws, such as requirements concerning the built environment.
3. Conduct a gap analysis to identify whether applicable accessibility requirements are met or whether further measures are required.
4. For operators providing e-commerce or passenger transport 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.

The EAA will apply through the national laws of each of the EU member states, and in addition to any existing accessibility laws (such as those concerning, for example, equal treatment in the provision of goods, facilities or services; inclusive design of the built environment; and accessibility and assistance for passengers with disabilities or reduced mobility).

Further Information

For more information on the EAA, please visit our dedicated site or see our previous articles:

• 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?

If you would like further information or for help with your EAA compliance plans, please contact Deirdre Kilroy and Kelly Mackey.