European Accessibility Act (EAA) Compliance: A Guide for Businesses
EAA compliance for businesses selling in the EU. Enforceable June 2025, EN 301 549 / WCAG 2.1 AA standard, extraterritorial reach, and what non-EU businesses must do.
What the EAA is
The European Accessibility Act (Directive 2019/882) is an EU law that requires businesses operating in the EU to make a defined set of products and digital services accessible to people with disabilities. It became enforceable on June 28, 2025 — meaning enforcement is now underway.
Unlike previous EU accessibility rules that targeted public sector bodies only, the EAA targets the private sector directly. It applies to companies of all sizes (with a narrow microenterprise exemption) and covers both consumer-facing and business-to-business digital products.
Who has to comply
The EAA applies to any business that places in-scope products on the EU market or provides in-scope services within the EU — regardless of where the business is based.
- EU-based companies selling covered products or services to EU consumers or businesses
- Non-EU companies (US, UK, APAC) with EU customers — the extraterritorial reach is explicit
- B2C and B2B — both are in scope
The only exemption is for microenterprises providing services: fewer than 10 employees AND annual turnover or balance sheet total under €2 million. Product obligations apply to all companies regardless of size.
Products and services covered
The EAA covers a defined list of product and service categories:
- Computers and operating systems
- Smartphones and tablets
- E-readers
- ATMs and ticketing machines
- E-commerce websites and apps
- Banking and financial services
- Electronic communications services (messaging, VoIP)
- Audiovisual media services and platforms
- Transport passenger services (booking, ticketing, real-time information)
- E-books and related software
EN 301 549 and WCAG 2.1 AA
The EAA references EN 301 549, the European harmonized standard for ICT accessibility. For websites, web applications, and mobile apps, EN 301 549 incorporates WCAG 2.1 Level AA in full.
Meeting WCAG 2.1 AA (or the superset WCAG 2.2 AA) gives you presumption of conformity with EN 301 549 for digital content — meaning your technical compliance is assumed by regulators unless proven otherwise.
EN 301 549 also covers non-web ICT (apps, documents, hardware), so a full compliance program must go beyond just website testing.
Deadlines and exemptions
| Milestone | Date |
|---|---|
| EAA enforcement begins | June 28, 2025 (already passed) |
| Existing service contracts transition period | June 28, 2030 (for contracts predating June 2025) |
| Self-service terminals (existing) | June 28, 2030 |
| Documentation retention requirement | 5 years after last sale |
What happens if you don't comply
Penalties are set by individual EU member states and vary in severity. Common enforcement mechanisms include:
- Financial fines — amounts vary by country but can be substantial
- Market withdrawal orders — regulators can ban non-compliant products from sale
- Consumer complaints — any EU consumer can file a complaint with their national authority
- Reputational exposure — enforcement actions are typically public
How to comply
- 1. Assess scope — Determine which of your products and services fall under the EAA's covered categories.
- 2. Audit to WCAG 2.1 AA — Run automated and manual audits of all web and app properties.
- 3. Extend to non-web ICT — Apply EN 301 549 requirements to mobile apps, documents, and hardware interfaces.
- 4. Prepare documentation — Create and maintain a conformance assessment and declaration of accessibility. Retain for 5 years.
- 5. Post an accessibility statement — Required for digital services. Should explain your conformance level and how to request accessible alternatives.
- 6. Establish a feedback mechanism — Users must be able to report accessibility issues and request accommodations.
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Get EAA-compliant with Zylyn
Services that address EN 301 549 and the European Accessibility Act directly.
- ServiceEN 301 549 Testing
WCAG 2.1 AA testing with conformance documentation that satisfies EAA regulatory requirements.
- ServiceVPAT & ACR Services
Conformance documentation retained for the EAA's 5-year regulatory requirement — backed by real test evidence.
- AdvisoryAccessibility Consulting
Strategic advisory to design an EAA compliance programme across your EU digital estate.
Real teams, real results.
Companies use Zylyn to cut manual testing time, ship accessibly, and stay ahead of demand letters.
“We've reduced manual accessibility testing time by over 70%. Zylyn flags issues in real-time and suggests fixes. Our audit process is now faster and more reliable than anything we had before.”
Frequently asked questions
Common questions from businesses navigating EAA compliance across EU member states.
The EAA (Directive 2019/882) is an EU law that requires private sector businesses to make a wide range of products and services accessible. It became enforceable on June 28, 2025.
Yes. If your business sells products or services to customers in any EU member state, the EAA applies regardless of where your company is headquartered. This extraterritorial reach is one of the most significant aspects of the law.
The EAA references EN 301 549, the European standard for ICT accessibility. For websites and digital products, EN 301 549 maps directly to WCAG 2.1 Level AA.
Businesses with fewer than 10 employees AND annual turnover or balance sheet total below €2 million are exempt from the EAA's service requirements. Product requirements still apply to all companies, regardless of size.
Yes. The EAA covers both B2C and B2B businesses. If you sell digital products or services to EU customers — whether those customers are consumers or other businesses — the EAA requirements apply.
Businesses that can demonstrate that compliance would impose a disproportionate burden may claim an exemption. They must document this assessment and notify national authorities. This exemption is narrow and must be re-evaluated regularly.
EAA documentation — including conformance assessments, technical specifications, and declarations of conformity — must be retained for five years.
Penalties are set by each EU member state and vary. Most countries have established fines, market access restrictions, and the ability to ban non-compliant products from being sold. Early enforcement activity began in 2025.
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