The European Accessibility Act: What you need to know

Accessibility matters. Whether you’re a business leader or a software developer, ensuring your products and services are accessible isn’t just good practice – it’s also now a legal requirement across the European Union with the European Accessibility Act (EAA), a game-changing directive designed to create a more inclusive digital experience. But it’s not just for European based businesses; in addition, this is relevant for all businesses offering their products or services to the EU.

The EAA, or Directive (EU) 2019/882, is a sweeping piece of legislation that mandates common accessibility standards across the EU. Its goal? To make products and services more accessible to persons with disabilities, fostering inclusivity by eliminating inconsistent accessibility rules among EU member states.

At its core, the EAA is about creating an inclusive society. It empowers individuals with disabilities by enabling independent living, and participation in society on equal terms. On a macro level, it harmonizes accessibility requirements across the EU, making cross-border trade smoother for businesses.

The EAA aligns with the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) in defining persons with disabilities. But its benefits extend beyond this group. Pregnant women, the elderly, and travelers with temporary physical limitations will also see improved access to essential services.

The directive casts a wide net, covering both products and services. Highlights include:

• Products: Smartphones, consumer computers, e-readers, and self-service terminals like ATMs.
• Services: Electronic communications, e-commerce, transportation, consumer banking, and audiovisual media.

The EAA applies to a broad range of industries that offer products and services within the EU market, even if the provider is based outside the EU. Here’s a breakdown of who’s directly affected: 

• E-commerce: Online retailers, marketplaces, and SaaS platforms must ensure that websites, mobile apps, and customer support are accessible under EN 301 549 and WCAG 2.2 AA standards.
• Finance: Banks, fintech platforms, and insurance companies must make their online banking interfaces, payment systems, and self-service kiosks accessible to all users. 
• Transport: Airlines, rail, bus, and ferry operators – along with ticketing and booking systems – must provide accessible digital interfaces and automated services. 
• Media and telecom: Telecommunication providers, streaming services, and broadcasters must ensure audiovisual content includes captions, transcripts, and accessible navigation. 
• Hardware and software: Manufacturers of smartphones, e-readers, terminals, and similar devices must design products with perceivable, operable, and understandable interfaces. 
• B2B and B2G procurement: Public authorities and business clients increasingly require suppliers to demonstrate accessibility compliance under the EAA, so even B2B organizations need to prepare. 

Penalties vary by country but may include steep fines (reported up to roughly three million euros), removal of products/services from the market, and suspension of the right to do business. 

Yes, many service-related EAA requirements exempt microenterprises with fewer than 10 employees and under €2M annual turnover. However, manufacturers of covered products may still have obligations. ‘Undue burden’ exemptions can also apply case-by-case. 

Yes. Any provider offering covered products or services in the EU must comply, regardless of where they are based. For example, airlines outside the EU with departures from the EU are in scope. 

The EAA acknowledges that smaller businesses might face challenges in meeting all its requirements.

Microenterprises (typically those with fewer than 10 employees and annual turnover under €2 million) may be exempt from certain product and service obligations. However, if a product is manufactured for the general public – such as smartphones, ATMs, or payment terminals – the manufacturer may still need to meet basic accessibility requirements. 

Businesses claiming a “disproportionate burden” exemption must document their justification and make it available to national authorities upon request. 

The EAA outlines specific accessibility features that businesses must incorporate:

• Alternative text for images
• Keyboard navigation
• Adjustable font sizes
• Text-to-speech and speech-to-text functionalities
• Captioning and audio descriptions
• Accessible customer support services

These requirements ensure that your products and services are perceivable, operable, and understandable. A statement or online notice of how you comply with the act may also be necessary.

Under the EAA, most organizations must publish an accessibility statement describing how their product or service meets accessibility requirements. This statement should include: 

• A summary of accessibility features and any known limitations 
• A feedback mechanism for users to report accessibility issues 
• Contact information for assistance or complaints 
• A link to the enforcement or monitoring authority in the relevant EU member state 

You can find templates and examples of accessibility statements from the European Commission and W3C’s Accessibility Statement Generator. 

To show compliance with the European Accessibility Act, organizations should align their products and services with these key standards: 

• EN 301 549 – The harmonized European standard that defines accessibility requirements for ICT products and services. It serves as the technical benchmark for EAA conformity. Read EN 301 549 here. 
• WCAG 2.2 AA – The Web Content Accessibility Guidelines that define how to make web content perceivable, operable, understandable, and robust. Learn more about WCAG 2.2. 
• Conduct regular accessibility audits and testing, using both automated tools and manual reviews. 
• Keep documentation of design decisions, audits, and remediation work as evidence of due diligence. 
• Include accessibility criteria in procurement and vendor management processes. 

As of June 28, 2025, all products and services must comply with the EAA’s requirements. National authorities across EU member states will oversee enforcement through market surveillance, investigations, and penalties for non-compliance.

The consequences of failing to meet EAA requirements vary by country but can include: 

• Administrative fines or financial penalties imposed by national market surveillance authorities. 
• Temporary or permanent bans on the sale or provision of non-compliant products and services. 
• Orders to withdraw or recall non-conforming products from the market. 
• Reputational damage and loss of eligibility for public sector contracts. 

Each EU member state designates a national authority responsible for enforcement – examples include Germany’s Federal Network Agency (BNetzA) and France’s Ministry for the Economy (DGCCRF). Businesses should familiarize themselves with their applicable supervisory authority. 

• June 28, 2021: Draft standards introduced.
• June 28, 2025: Deadline for compliance with accessibility standards for new products and services.
• June 28, 2030: Transitional period ends for older contracts and products.
• Indefinite future: Self-service terminals in use before 2025 can remain operational for up to 20 years.

The EAA isn’t just a checklist—it’s an opportunity. By embracing accessibility, you’re opening your doors to a wider audience, improving customer satisfaction, and aligning with global standards.

“As we are transcending more and more into a digital world, the importance of this accessibility act is becoming even more relevant. Many users are opting to use online sites and applications instead of the physical domain (a great example is in the banking industry where over 70% of all bankers are using digital banking applications instead of in bank experiences. So now more than ever, people with disabilities need to have guaranteed access to this digital world, much like already in place in the physical world.”

Darine Fayed VP General Council EMEA for Sinch

The EAA is here to stay, and businesses have a window to adapt. Start early to make compliance less daunting. Remember, accessibility isn’t just about meeting legal obligations—it’s about building trust and inclusivity in every interaction.

Stay ahead of the curve and make your emails and digital services accessible. Mailgun is here to help. Let’s build smarter, more inclusive communications together.

Author: Darine Fayed Darine Fayed is the Vice President Head of Legal EMEA for Sinch. She provides legal counsel on our international contracts, oversees our data protection and handles a variety of other legal matters. She writes often about compliance laws and policy standards that affect email communication.

Co-author: Em Blitstein Em Blitstein is a Sr. Content Marketing Manager at Sinch Mailgun. She manages the Mailgun Blog, curates top-notch content, and falls down SEO rabbit holes. She writes about all things email and loves a good dev deep dive.