Directive (EU) 2019/882 · applicable since 28 June 2025
The European Accessibility Act, as a checklist you can actually work through.
Twelve questions decide whether the Act applies to you, and eight more decide whether you are meeting it. Below is that sequence, in the order a market surveillance authority would ask it, with what counts as an answer, what counts as evidence, and where the common mistakes are. No legal advice, no scare numbers: the text of the Directive and what it means for a website that sells something.
Seven days free, no card. Signed by Europe Services SE, Prague.
Part one: does it apply to you?
Work down this list. A single yes in the first block and a no in the exemption block puts you in scope.
- Do you sell goods or services to consumers located in the European Union, from anywhere in the world?
- Is the sale concluded online, through a website or an application?
- Do you provide consumer banking, payment accounts, credit or insurance-adjacent services electronically?
- Do you sell, distribute or lend e-books, or the software used to read them?
- Do you provide electronic communications services, including messaging and voice?
- Do you sell tickets, check-in, or provide real-time travel information for air, bus, rail or waterborne transport?
- Do you operate self-service terminals: payment terminals, ATMs, ticketing machines, check-in kiosks?
- Do you manufacture or sell consumer hardware with computing functions, including e-readers and terminals?
- Do you answer emergency communications or route them?
- Are you a public sector body? If so, a different directive already applies to you, 2016/2102, with its own statement model.
- Do you employ 10 or more people, or exceed 2 million euro in turnover or balance sheet total?
- Are you placing products on the market, rather than only providing services? If yes, the microenterprise relief does not help you.
The two most common misreadings we see: believing that a company established outside the Union is out of scope, and believing that the microenterprise exemption covers a shop selling physical products. Neither holds.
Part two: what the service has to do
Annex I of the Directive sets functional requirements in prose rather than as a technical checklist. EN 301 549 turns them into testable criteria, and for web content that means WCAG. Here is the translation, requirement by requirement.
| Directive requirement | What it means on a website | How it is tested |
|---|---|---|
| Information perceivable through more than one sense | Nothing carried by colour alone, captions on video, text alternatives for images | Contrast measurement, screen reader pass, media review |
| Content presented in understandable ways | Clear labels, plain error messages, consistent navigation | Manual review of forms and journeys |
| Content operable through more than one means | Full keyboard operation, alternatives to dragging and gestures | Keyboard-only pass of every flow |
| Compatible with assistive technologies | Names, roles and states exposed to the accessibility tree | Screen reader and accessibility inspector |
| Information about accessibility features | The statement itself, published and findable | Presence, accuracy, date, feedback route |
| Support services accessible | Help and contact channels usable by the same people | Testing the contact and chat paths |
The audit described on the audit page follows exactly this order, because it is the order an enforcement body will follow when it opens your site.
Part three: what goes in the statement
Annex V is short and specific. A statement that omits one of these elements is incomplete even if everything else is perfect.
- Identification of the service, in general and non-technical language, so a consumer understands what is being described.
- A description of how the service meets the requirements, not a claim that it does. Descriptions can be verified; claims cannot.
- The parts that do not meet them, named honestly, with the reason and what is planned.
- The alternatives offered where a barrier remains: a phone line, a human channel, an accessible export.
- A feedback mechanism that a user can actually reach and that reaches you.
- A date, and a commitment to review that survives contact with reality.
We write the statement from the audit findings, which is the only way to satisfy the second and third points without guessing. It is signed by Europe Services SE, a Czech company registered under IČO 03571785, and carries a public code that anyone can verify.
Part four: the same Act, twenty-seven laws
A directive is not directly applicable: each member state writes its own law, and the differences are real. The obligations below are the same everywhere; the enforcement, the wording and the penalties are not.
| Market | National instrument | Practical note |
|---|---|---|
| Germany | BFSG | Detailed national guidance, active supervisory body, statement expected in German |
| Italy | Legge Stanca as amended | Pre-existing accessibility law extended to private operators above a size threshold |
| Spain | Real Decreto 193/2023 | Transposition with its own review cycle |
| France | Code de la consommation provisions | Penalty regime already used for the earlier public-sector rules |
| Netherlands, Belgium, Nordics | Sectoral implementations | Enforcement bodies split across consumer and telecom regulators |
If you sell across several of these, one statement in the right languages is enough, provided it describes the same service truthfully. That is what EU Plus is for.
Part five: the evidence file
The statement is the visible part. What protects you in an inspection is the file behind it, and it should contain five things.
The audit
What was tested, with which technology, on which date, by whom.
The findings
Every barrier with its criterion and severity, including the ones still open.
The plan
What is being fixed, in what order, with realistic dates rather than aspirations.
The feedback log
What users reported, when it arrived, what was answered, what changed.
The versions
Each issue of the statement, dated, so the history is reconstructable years later.
All five are produced and retained as part of the plan for five years, and the monthly re-test keeps the first two current instead of frozen at the day of signature.
Part six: the mistakes that cost the most
Four patterns account for most of the trouble we are called in to repair.
Publishing a claim of full conformance. It is almost never true, it is trivially disprovable, and it converts a technical problem into a credibility problem. A statement that names three open barriers and a fix date is stronger than one claiming perfection.
Treating the feedback channel as decoration. An address that bounces, or a form nobody reads, is worse than none: it is documented failure to provide a route the law requires.
Relying on a widget. An overlay changes what a page looks like to some users and nothing about the structure underneath. It does not satisfy Annex I and it does not produce the description Annex V asks for.
Doing it once. A statement written in 2025 for a site redesigned in 2026 describes a website that no longer exists. This is why the re-test is monthly and not annual.
If you want the shape of the document before deciding, the generator page shows what belongs inside one and what a template leaves out, and the EAA overview covers the legal background in less detail than this page but with more context.
Part seven: what an inspection looks like in practice
Enforcement under the Act rarely begins with an inspector at the door. It begins with a consumer who could not finish a purchase, writing to a national body with a screenshot and the address of the page. What follows is procedural and largely predictable.
The body writes to the operator and asks three things: the accessibility statement, the evidence behind it, and the response given to the user through the feedback channel. Everything after that depends on those three answers. An operator who can send a dated audit, an honest statement listing the barrier the consumer hit, and a logged reply with a fix date is usually left to complete the plan. An operator who sends a template claiming full conformance, with no test behind it and no record of the complaint, has just confirmed the problem in writing.
This is why the checklist above puts the evidence file before the wording. The text takes an afternoon. The file takes a process, and it is the file that answers the letter.
Part eight: a realistic timeline
For a shop with a few hundred products and a standard checkout, the sequence runs like this. The free scan takes two minutes and tells you whether there is an obvious problem. The order form takes ten minutes. Testing runs over five business days and produces the findings and the signed statement, which goes online immediately, listing whatever is still open. The development work that follows is usually two to four weeks for the blocking items, because they are few and specific, and a quarter for the rest if the team folds them into normal releases. Each month the site is re-tested, and the statement is re-issued as items close.
Six weeks from start to a site that is not only described accurately but has actually improved is a normal outcome. Nothing about the Act requires perfection on day one; it requires a truthful description, a route for users, and visible movement.
The EAA questions that actually get asked
Who does the European Accessibility Act apply to?
Economic operators placing covered products or services on the Union market for consumers: e-commerce, consumer banking, e-books, electronic communications, passenger transport services, ticketing and self-service terminals, among others.
Since when does it apply?
28 June 2025. There are transitional arrangements for service contracts concluded before that date and for self-service terminals already in use, both with hard end dates.
Is my company too small to be covered?
Microenterprises providing services are outside the services obligations, defined as fewer than 10 people and turnover or balance sheet total not above 2 million euro. That exemption does not extend to products.
Does it apply to companies outside the EU?
Yes, if you sell into the Union. The obligations follow the market, not the address of the seller.
What exactly must be published?
An accessibility statement describing how the service meets the requirements, the parts that do not, the alternatives offered and a way for users to report problems.
Where should the statement sit?
Somewhere a user can find it without searching: the footer of every page is the convention, with a stable address that does not change with a redesign.
Which technical standard applies?
EN 301 549 is the harmonised European standard, and it incorporates WCAG for web content. Meeting WCAG 2.2 level AA covers the web part comfortably.
What about disproportionate burden?
The Directive allows it, but it is an assessment you must document and repeat, not a sentence you write once. Regulators expect figures.
Who enforces it?
Each member state designates market surveillance authorities for products and enforcement bodies for services. They act on complaints and on their own initiative.
What are the penalties?
Set nationally. They range from orders to comply to administrative fines, and in several states a suspension of the service is possible.
Is Germany different?
Germany implemented it as the BFSG, with its own guidance and its own authority. The substance is the Directive.
Does it cover mobile apps?
Yes where the app delivers a covered service, which for e-commerce and banking it usually does.
Do I need a statement per country?
One statement can serve several markets if it is available in the languages of the consumers you serve and reflects the same service.
What does your EU plan cover?
One domain, the audit, the statement written to Annex V, the feedback channel, monthly re-testing and five years of records, for 690 € a year.
And if I have several brands?
EU Plus covers three domains and six languages for 1,290 € a year.
How fast can I be compliant on paper?
The statement is signed within five business days. Being compliant in fact depends on how many barriers your site has and how quickly your team fixes them.
Does an overlay satisfy the Act?
No. The Directive is about the service being accessible, not about a script asserting that it is.
Where do I start?
With the free scan, then the checklist on this page, then the audit if the scan shows what it usually shows.