EAA Compliance

Overview

Guides compliance with the European Accessibility Act (EU Directive 2019/882) and the underlying technical standard EN 301 549. Covers scope, deadlines, exemptions, and enforcement across EU member states.

Instructions

When conducting an EAA/EN 301 549 compliance review:

Determine which law applies:
- Web Accessibility Directive (WAD) — public sector websites and mobile apps (already in force since 2020/2021)
- European Accessibility Act (EAA) — private sector products and services (enforced from 28 June 2025)
Identify if the product/service is in scope (see Products and Services section)
Evaluate against EN 301 549 v3.2.1, which incorporates WCAG 2.1 AA for web content (Clause 9) and extends to:
- Non-web documents (Clause 10)
- Non-web software / mobile apps (Clause 11)
- Hardware and self-service terminals (Clause 12-13)
Check exemptions — microenterprises, disproportionate burden, fundamental alteration
Provide remediation guidance with reference to specific EN 301 549 clauses
Recommend accessibility statement — required under both WAD and EAA

Products and Services in Scope (EAA)

Products

Computers and operating systems
Smartphones and tablets
TV equipment and related services
E-readers
Self-service terminals (ATMs, ticket machines, check-in kiosks, payment terminals)
Consumer telecommunication equipment

Services

E-commerce websites and mobile apps
Banking services (online and ATMs)
E-books and dedicated software
Audiovisual media services
Transport services (websites, apps, ticketing, real-time travel info)
Telephony and messaging services

EN 301 549 Structure

| Clause | Scope | Key Requirements | |---|---|---| | 5 | Generic requirements | Closed functionality, biometrics, preservation of accessibility | | 6 | ICT with two-way voice communication | Real-time text (RTT), caller ID, video communication | | 7 | ICT with video capabilities | Captions, audio description, player controls | | 8 | Hardware | Physical dimensions, connections, keypads, biometrics | | 9 | Web content | WCAG 2.1 Level AA (all success criteria) | | 10 | Non-web documents | WCAG 2.1 AA applied to documents (PDFs, Word, spreadsheets) | | 11 | Non-web software | WCAG 2.1 AA adapted for native apps and desktop software | | 12 | Documentation and support | Accessible docs, help desk, support services | | 13 | ICT providing relay or emergency services | Relay services, 112 emergency access |

Who Must Comply

| Law | Sector | Scope | |---|---|---| | Web Accessibility Directive (2016/2102) | Public sector | All EU public sector websites and mobile apps | | European Accessibility Act (2019/882) | Private + public | Manufacturers, service providers, importers, distributors offering in-scope products/services in EU |

Territorial reach: Any organization offering in-scope services to EU consumers, regardless of where the organization is headquartered.

Deadlines

| Obligation | Date | |---|---| | WAD — Public sector websites | 23 September 2020 | | WAD — Public sector mobile apps | 23 June 2021 | | EAA — All in-scope products and services | 28 June 2025 | | EAA — Products placed on market before June 2025 | Grace period until 28 June 2030 | | EN 301 549 v4.1.1 (planned, includes WCAG 2.2) | Expected 2026 |

Exemptions

Microenterprises — fewer than 10 employees AND annual turnover ≤ €2 million (EAA only)
Disproportionate burden — documented assessment required; does not exempt from all requirements
Fundamental alteration — compliance would change the nature of the product/service
Third-party content — not funded, developed, or controlled by the economic operator
Archived content — not updated after 28 June 2025

Penalties

Enforcement is per member state. Examples:

| Country | Penalty | |---|---| | General range | Up to €500,000 in fines | | Some states | Product removal from market | | At least one state | Criminal penalties possible |

Penalties must be "effective, proportionate, and dissuasive."

Presumption of Conformity

Products/services conforming to harmonised European standards (notably EN 301 549) benefit from a "presumption of conformity" — they are presumed to meet EAA requirements without further proof.

Accessibility Statement

Both WAD and EAA require publishing an accessibility statement that includes:

Scope of content covered
Standard used (EN 301 549)
Level of conformance achieved
Known limitations with rationale
Contact mechanism for reporting barriers
Link to enforcement procedure

Examples

Example: E-commerce Audit

Input: "Our online store sells to EU customers, what do we need?"

Response approach:

Confirm the store is in scope (e-commerce service)
Check for microenterprise exemption
Audit website against EN 301 549 Clause 9 (= WCAG 2.1 AA)
Audit mobile app against Clause 11 if applicable
Check self-service terminals (kiosks) against Clause 8 if applicable
Verify accessibility statement is published

Example: SaaS Product

Input: "We're a US company with EU customers, does EAA apply?"