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?"