Who Needs to Comply With the European Accessibility Act?

The European Accessibility Act (EAA) applies to businesses that manufacture, import, distribute, or provide covered products and services to consumers in the EU, regardless of where the company is based. Key sectors include e-commerce, consumer banking, electronic communications, passenger transport, e-books, and audiovisual media. Since 28 June 2025, applicable businesses must meet the relevant accessibility requirements, although specific exemptions and transitional arrangements may apply.

Which Businesses Must Comply with the EAA?

Businesses that place covered products on the EU market or provide covered services to consumers in the EU may have European Accessibility Act (EAA) obligations, including companies headquartered outside Europe. The scope depends on the product or service offered, the applicable national rules, and any relevant exemptions—not simply whether a business operates within the EU. Companies should assess their accessibility obligations to determine whether they must meet the applicable EU accessibility requirements.

Which Economic Operators Are Responsible for EAA Compliance?

• Manufacturers: Must design and manufacture covered products to meet applicable accessibility requirements, conduct the required conformity assessment, and prepare technical documentation and an EU declaration of conformity.
• Authorized Representatives: Carry out the tasks specified in the manufacturer's written mandate, such as maintaining compliance documentation and cooperating with market surveillance authorities.
• Importers: Must verify that covered products from outside the EU meet applicable requirements and that the necessary conformity documentation, CE marking, and instructions are in place.
• Distributors: Must exercise due care, check relevant conformity information, and avoid making products available when they know or suspect that accessibility requirements are not met.
• Service Providers: Must design and deliver covered services in accordance with applicable accessibility requirements, document how those requirements are met, and take corrective action when necessary.

Which Products and Services Must Meet EAA Requirements?

• Computers and operating systems: Consumer computer hardware and operating systems.
• Smartphones and communication equipment: Covered smartphones, consumer communication devices, and related services.
• Self-service terminals: ATMs, payment terminals, ticketing machines, and check-in machines.
• Audiovisual media services: Services that provide access to audiovisual content, including relevant interfaces and equipment.
• Passenger transport services: Covered websites, mobile apps, electronic tickets, booking systems, and travel information.
• Consumer banking services: Digital banking functions, including identification, electronic signatures, security, and payment services.
• E-books and e-readers: Digital books and the software and devices used to access them.
• E-commerce services: Online shops and digital purchasing journeys, including accessible identification and payment processes.

Do EAA Requirements Apply Across All EU Member States?

Yes. Since 28 June 2025, the European Accessibility Act (EAA) has applied across all 27 EU Member States through national laws implementing Directive (EU) 2019/882. It establishes common EU-wide accessibility requirements for specified products and services, helping businesses serve customers across the EU with a more consistent compliance framework. However, enforcement procedures, competent authorities, and penalties can differ between EU countries, so businesses should check the national rules applicable in each market

Does the European Accessibility Act Apply to Businesses Outside the EU?

Yes. The European Accessibility Act (EAA) can apply to businesses based outside the EU. What matters is whether they place covered products on the EU market or provide covered services to consumers in the EU. A company headquartered in the United States, the United Kingdom or Türkiye may therefore have obligations under the Act.

Where the business is incorporated is not the deciding factor. Some exemptions apply. Microenterprises providing services are exempt from the service requirements. Because the EAA is a directive, each EU member state enforces it through its own national law. Requirements and penalties can vary by country.

How Can You Determine Whether Your Business Is Covered by the EAA?

To determine whether the EAA applies to your business, businesses should assess their products or services, target markets, and legal responsibilities under the applicable legislation. The following checklist helps identify whether your organisation may have accessibility obligations and which EAA requirements it needs to review.

• Check your target market: Do you sell products or provide services to consumers within the EU, even if your company is headquartered elsewhere?
• Identify covered products and services: Does your business operate in a sector covered by the EAA, such as e-commerce, consumer banking, electronic communications, e-books, or passenger transport?
• Determine your role: Are you a manufacturer, importer, distributor, authorised representative, or service provider? Your role affects your legal responsibilities.
• Review applicable exemptions: Does your business qualify for the microenterprise exemption for services, or could a documented disproportionate burden exception apply?
• Map the relevant requirements: Identify the specific accessibility requirements applicable to your products or services and the national legislation implementing the EAA.
• Assess and document compliance: Evaluate relevant digital interfaces and service journeys, address identified accessibility issues, and maintain documentation supporting your compliance decisions.

What Are the EAA Responsibilities of Manufacturers, Importers, and Distributors?

Under the European Accessibility Act (EAA), manufacturers, importers, distributors, and Authorized Representatives have distinct responsibilities for ensuring that covered products meet applicable accessibility requirements. Their obligations depend on their role in the supply chain, from product design and conformity assessment to verification and cooperation with market surveillance authorities.

• Manufacturers: Design and manufacture covered products to meet applicable accessibility requirements, carry out conformity assessments, prepare technical documentation, issue the EU declaration of conformity, and apply CE marking where required.
• Importers: Verify that products imported from outside the EU comply with applicable requirements before placing them on the EU market. They must also check conformity documentation, CE marking where applicable, and required instructions and contact details.
• Distributors: Exercise due care when making products available on the market, verify relevant conformity information and markings, and take appropriate action if a product appears not to comply.
• Authorized Representatives: Perform the specific compliance tasks assigned by the manufacturer through a written mandate, which may include keeping documentation available and cooperating with market surveillance authorities.