Directive (EU) 2019/882 · applicable since 28 June 2025
The European Accessibility Act, explained for the people who have to comply with it.
Most summaries of this Directive are written for lawyers or for campaigners. This one is written for the person inside a company who has just been told it applies to them: what the law is trying to do, who is actually in scope, what it demands in practice, how it reaches you through twenty-seven national laws, and what the first week of work looks like.
Signed by Europe Services SE, Prague, with a public verification code.
What the Act is trying to do
Before 2019 accessibility law in Europe was a patchwork: some member states regulated public sector websites, a few went further, most did little for the private sector. A manufacturer selling a terminal in five countries faced five sets of expectations, and a consumer's rights depended on where they happened to live.
The Directive replaces that with one set of requirements for a defined list of products and services. It is an internal market instrument as much as a social one, which explains its structure: it describes outcomes rather than technologies, so that the same text still works when the technology changes.
That framing matters practically. The question an authority asks is not whether you used a particular attribute, but whether a person can perceive, operate and understand the service. Technical criteria enter through the standard, not through the law itself.
Who is in scope
| Category | Examples | Common misreading |
|---|---|---|
| E-commerce | Any online sale of goods or services to consumers | Believing a foreign seller is outside the Union's reach |
| Consumer banking | Accounts, payments, credit, related interfaces | Assuming only the app counts, not the website |
| Electronic communications | Voice, messaging, related services | Overlooking the support channels |
| E-books | Files and the software used to read them | Treating the reader app as out of scope |
| Passenger transport | Ticketing, check-in, real-time information | Covering the website but not the kiosks |
| Products | Terminals, e-readers, consumer computing devices | Applying the microenterprise exemption to products |
Two exemptions are real and narrow: microenterprises providing services, on staff and turnover thresholds, and disproportionate burden, which must be assessed, documented and repeated rather than asserted once.
What it actually demands
Annex I sets the requirements in functional terms: information must be perceivable through more than one sense, content must be understandable, functions must be operable in more than one way, and everything must work with assistive technology. It also covers support services, so your help pages are in scope alongside the product.
Annex V then describes the statement: what the service is, how the requirements are met, what does not conform, the alternatives, a feedback route and a date. The detail of each element is on the requirements page.
Between the two sits EN 301 549, the harmonised standard, which converts the functional language into testable criteria and, for web content, adopts WCAG. That is why a WCAG 2.2 AA audit answers the Directive for a website: not because the law names WCAG, but because the standard does. The mapping is set out on the EN 301 549 page.
How it reaches you: twenty-seven national laws
A directive binds member states, not companies, so what applies to you is always a national law: the BFSG in Germany, an amended Legge Stanca in Italy, a royal decree in Spain, and so on. The substance is the same everywhere because it comes from the same text.
What differs is procedure: which authority supervises, how complaints are handled, what the penalty range is, and in which language the statement is expected. For a company selling across several markets the practical conclusion is to stop reasoning country by country. One truthful statement, in the languages you actually sell in, answers whichever authority writes first — and trying to be compliant only where enforcement looks active is more work and less defensible than simply being compliant.
Enforcement in practice
There is no European inspectorate browsing websites. The sequence is almost always the same: a consumer meets a barrier, uses the feedback route, gets no useful answer, and writes to a national body. The body then asks for three things — the statement, the evidence behind it, and the reply the consumer received.
Which is why the evidence file matters more than the wording. An organisation that can produce a dated external test, an honest statement and a logged reply is in a procedural conversation with a deadline at the end of it. An organisation with a template and no testing is producing everything at once, under pressure, while also answering the customer.
The first week, concretely
Run the free scan on your own address; it takes two minutes and tells you whether the situation is tidy or structural. Order the audit; the scope questions take ten minutes and testing starts the same day. Five business days later you have a findings report and a signed statement, published immediately with whatever remains open, plus a feedback route that reaches a named person.
Then the ordinary work: two to six blocking items fixed in the next sprint, a content list handled by whoever publishes pages, and monthly re-testing so the document and the website stay in step. 690 € a year for the European Union, 1,290 € for three domains and six languages, 1,990 € if you also need the United Kingdom and Canada on one renewal date.
None of that makes a site perfect in a week, and nobody honest will claim otherwise. It does move you from an unknown position to a documented one, which is the difference that matters when a letter arrives.
Disproportionate burden, and how it is misused
The Directive allows an operator to claim that meeting a requirement would impose a disproportionate burden. The provision is genuine and it is the single most misunderstood part of the text.
It is an assessment, not a sentence. It weighs the cost of the change against the benefit to people with disabilities, taking into account the size and resources of the organisation, and it must be documented, produced on request and repeated periodically. It applies to a specific requirement, not to a website as a whole. And it does not survive contact with the facts: when the finding is an unnamed button, an hour of developer time is difficult to present as disproportionate.
Where it genuinely applies is narrower than people hope: legacy systems that cannot be modified without replacement, archived content that nobody uses, hardware in the field. Even there, the Directive expects the alternative to be offered rather than the obligation simply dropped.
What the Act does not cover
Worth knowing, because scope creep wastes budgets. Purely internal tools used only by employees are not covered by this Directive, though employment law and national disability legislation may well reach them. Content published before the date, in archives that are not part of the current service, is treated differently from live content. Broadcast content itself falls under separate audiovisual rules, while access to the service delivering it is covered here. And public sector bodies follow the earlier directive, with its own prescribed statement model.
None of that means those areas are safe to ignore commercially. It means the legal pressure on them comes from somewhere else, which changes the priority rather than removing the topic.
Why the business case usually arrives second
Every organisation we work with starts with the legal question and discovers the commercial one afterwards. The order is understandable and slightly unfortunate, because the commercial case is the stronger of the two.
Consider who a barrier actually excludes. Not only people with a registered disability, but anyone whose situation temporarily matches one: a broken wrist, a phone in bright sunlight, a noisy train, a slow connection that kills the script your dropdown depends on, an older customer who navigates with the keyboard out of habit. The population affected by a keyboard trap in a checkout is far larger than the population the law had in mind, and none of them write to explain why they left.
The fixes also happen to be the ones usability people have recommended for twenty years. Labels reduce form errors. Announced totals reduce support contacts. Visible focus reduces mis-clicks. Clear error messages reduce abandonment. There is no accessibility change in a typical findings report that makes the site worse for anybody else, which is unusual among compliance obligations.
That is why we suggest ordering the work by user impact rather than by criterion number: it happens to produce the commercial return first, which is also what keeps the project funded past the initial deadline.
What happens to the Directive from here
Two things are worth watching without waiting for them. National enforcement bodies are still finding their rhythm, so complaint volumes and public cases will rise as they do, and procurement language tends to harden faster than regulation because buyers move first. Meanwhile the standard underneath continues to evolve: WCAG advances, EN 301 549 follows, and a report written against an old version ages without anybody noticing.
Neither is a reason to delay. Both are reasons to build the habit now rather than the document once, because the organisations that will be comfortable in three years are the ones testing monthly today.
Questions about the Act
What is the European Accessibility Act?
Directive (EU) 2019/882, which sets common accessibility requirements for a defined list of products and services sold to consumers in the Union.
When did it start applying?
28 June 2025, with narrow transitional arrangements for pre-existing service contracts and terminals already in use.
Why was it introduced?
To replace twenty-seven divergent national approaches with one set of requirements, so that accessible products can circulate freely and consumers get the same protection everywhere.
Which products are covered?
Computers and operating systems, self-service terminals, consumer terminal equipment for communications, e-readers, and some others.
Which services are covered?
E-commerce, consumer banking, electronic communications, e-books, passenger transport services and access to audiovisual media services.
Is my website automatically covered?
Only if it delivers a covered service. Selling to consumers online is the most common route in.
Does it apply to B2B?
It targets consumers. B2B obligations usually arrive through customer contracts and procurement instead.
What about companies outside the EU?
The obligations follow the market. Selling into the Union brings you into scope.
Are small companies exempt?
Microenterprises providing services are exempt on staff and turnover thresholds. The exemption does not cover products.
What is Annex I?
The accessibility requirements themselves, written as outcomes rather than technical criteria.
What is Annex V?
The content the accessibility statement must have for services.
How does it relate to WCAG?
Through EN 301 549, the harmonised European standard, which adopts WCAG criteria for web content.
Who enforces it?
Market surveillance authorities for products and designated enforcement bodies for services, in each member state.
What are the penalties?
Set nationally, ranging from orders to comply to administrative fines.
Is it the same as the public sector directive?
No. Directive 2016/2102 covers public sector bodies and has its own statement model.
What do we have to publish?
An accessibility statement describing the tested state, the open barriers, the alternatives and the feedback route.
How fast can we be documented?
Five business days from a complete form, with seven days free and no card.
What does it cost?
690 € a year for the EU, 1,290 € for three domains and six languages, 1,990 € including the UK and Canada.