The European Accessibility Act: Understanding Digital Accessibility

18th December 2024

The European Accessibility Act (EAA) is a directive of the European parliament passed on 17 April 2019. It succeeds the Web Accessibility Directive of 26 October 2016 which applied primarily to public sector websites and mobile applications. The EAA expands responsibility for accessible Information and Communications Technology (ICT) to many product types and service sectors in the EU. It also incorporates by reference accessibility requirements of other EU acts, making it a single legal point of reference for EU accessibility regulation.

This explainer describes the responsibilities on various entities created by the act, including the types of products and services covered by the act. Conformance to the act primarily relies on harmonised standards, and there are measures to address fundamental alteration and disproportionate burden. Finally the explainer collates and describes all the accessibility requirements for various types of products and services.

Introduction

The EAA was created to respond to the growing use of Information and Communications Technology (ICT) in modern society. Creation of this act is also part of the EU's responsibility under the UN Convention on the Rights of Persons with Disabilities.

Applicable products and services placed on the market or updated after 28 June 2025 must conform to the requirements of the act. Products or services already on the market at that time, and not updated since before that date, do not have to conform until a) they are updated, or b) 28 June 2030 at the latest. Long-life self-service terminals installed before 2025 do not have to be replaced until a) they reach the end of their economic life, or b) 28 June 2045. Another exception for emergency services gives them until 28 June 2027 to meet the requirements.

Digital Accessibility Centre Standard of Accessibility - EAA Compliant

These deadlines set by the act are on 28 June of the following years:

  • 2022 - Member states to notify the EU of implementation acts;
  • 2025 - New products and services must conform to the EAA;
  • 2027 - Emergency services must conform to the EAA;
  • 2030 - Expiry of 5-year exception for products and services placed on the market before 28 June 2025;
  • 2045 - Expiry of 20-year exception for long-life self-service terminals.

28 June 2025 is the upcoming deadline for products and services, after which new products and services must conform to the act. At this time covered organisations should have active plans for conformance under way, plans to design for and verify accessibility, document conformance efforts, verify the supply chain, etc.

Interpreting the act

The European Accessibility Act is a Directive of the European Union. As a directive, it directs member states to pass implementation acts, which apply the requirements of the directive in a way that works with their existing national law. It is structured as a delegated act, which allows the European Commission to amend the act without a full legal update process, to allow it to address new technological situations. The act also depends on harmonised standards, where specific technical details about how to conform are defined outside the act.

That is a lot of detail. The act is a legal document, structured to meet those particular requirements. Many of the chapters relate to its function as a EU directive and a delegated act. People in most roles do not need to know those details. Instead, they need to know who is covered and what are their obligations. This information is mainly provided in Chapters III and IV as well as in Annex I.

Entities covered by the act are described as ‘economic operators’ that have responsibility to ensure their products and services meet the accessibility requirements. The responsibilities defined in the main body of the act for these economic operators relate to their conformance efforts, such as their design approach, quality assurance, documentation, etc.

Specific accessibility requirements are provided in Annex I, and are requirements of the act in spite of being in an annex. For each type of economic operator defined, the annex provides a list of accessibility requirements for their products or services. There are several lists of general requirements, followed by lists that address particular types of products and services.

Using this explainer

The complex and abstract structure of the EAA has meant that many organisations are uncertain whether they must conform to the act, and if so, how. This explainer seeks to provide clarity by explaining three aspects of the act:

  • Responsibilities defined in the act - the responsibilities given to member states and economic operators;
  • Conformance and exceptions - how the act addresses conformance, standards, and situations where conformance is not required;
  • Accessibility requirements - detailed requirements specific to each market sector.

This explainer does not organise content in the same way as the act, and each section of the explainer addresses content from various parts of the act. The explainer also consolidates duplicates in the accessibility requirements section. This allows an explanation that progresses in a manner better for understanding.

This explainer does not give you everything you need to know to follow the act. It will help you to understand whether your organisation is covered by the act, and if there are any relevant exceptions. If your organisation does produce products or services covered by the act, the explainer consolidates the relevant requirements. Make sure to review the common requirements for all products and services, general requirements for the category, and requirements for the specific product or service type.

Terms and concepts are introduced progressively, and explained on first use. Most of the content of the explainer attempts to summarise the content of the act in an objective manner. Interpretive advice is given in notes, indented paragraphs that begin with the text ‘Note:’.

Responsibilities defined in the act

Chapters III and IV of the act describe obligations of ‘economic operators’. These are the types of organisations covered by the act including:

  • Manufacturers of consumer information and communications technologies, as well as their agents,
  • Importers and distributors of these products, and
  • ICT service providers.

The obligations defined in those chapters relate to the process of ensuring and reporting conformance to the act, such as the way accessibility is integrated into the production process, and requirements for record-keeping and engagement with market authorities. Manufacturers whose product uses the CE mark must conform to EAA requirements for a valid certification.

It is the responsibility of the manufacturer, service provider, and their agencies to ensure that their product or service conforms. They must prepare conformance self-assessment reports and keep them on file for at least 5 years, and submit them to market surveillance authorities if requested. Determining conformance is largely a matter of self-assessment. Agents acting on behalf of the manufacturer must also have this documentation available.

Note: Organisations that do not yet have a mature accessibility team as part of their staff may not have the expertise needed to perform a complete and accurate assessment. Nonetheless, they are still responsible to ensure their products conform and the assessment documentation is on file. Unless it creates a disproportionate burden, these organisations should engage competent outside assistance to help ensure they are meeting the full requirements of the act.

The act also sets requirements on member states to pass implementing acts, select harmonised standards, perform market surveillance, and provide enforcement mechanisms. The act states that any penalties from market authorities for non-conformance should generally exceed the cost of conformance, in order for this to be a meaningful deterrent to avoiding conformance.

Note: The act acknowledges that many businesses in these categories are small businesses, with limited ability to meet the requirements. See Disproportionate burden for information about how obligations for small organisations may be reduced.

Manufacturers

The following types of products must conform to EAA requirements:

  • computer hardware and operating systems,
  • self-service machines such as payment terminals, ATMs, ticketing machines, check-in machines, and other interactive self-service terminals (except on vehicles), and
  • devices used for communications, audiovisual media access, and e-readers, i.e., many personal electronic devices as well as digital connection devices like consumer routers.

Manufacturers have responsibility to ensure these products fully meet the accessibility requirements. In addition to the initial product release, they must develop procedures to ensure that the product series stays in conformance through design changes and regulation updates. Products must be traceable through serial or batch number, and the name and trade mark on the packaging must be accompanied by accessible contact information. If an accessibility flaw is discovered in a released product and it cannot be fixed within a reasonable time period, the product must be withdrawn from the market.

Importers and distributors

Importers and distributors are responsible to know that they're part of an accessible supply chain and distribute only products that meet the EAA requirements. This means they must know the product they are receiving meets the requirements, and have their own copy of the documentation. If the product has a CE mark, distributors must substantiate that the product meets requirements for that. Importers and distributors must also ensure that storage and transport conditions do not impact product characteristics in a way that impacts their accessibility. As with manufacturers, importers and distributors must submit relevant documentation to market authorities on request.

Under the act, importers and distributors who modify a product become a ‘manufacturer’ of that product, and must fulfil all the responsibilities of manufacturers for the product. The act also clarifies that products put on the market after 28 June 2025 must conform to the requirements — even if the product was manufactured earlier or is being sold second-hand.

Note: Importers and distributors involved in the second-hand market prepare for the impact of this, as some products may become inadmissible to the EU after the act goes into effect.

Service providers

The EAA addresses accessibility of several specific types of services related to information and communications technology:

  • electronic communications providers, such as fixed and mobile digital connection providers,
  • audiovisual media services, such as digital TV, streaming services, etc.,
  • transport and banking consumer services, such as ticketing and information sites, bank account access, the content on self-service terminals, etc.,
  • electronic books (e-books),
  • e-commerce, including both organisations that sell goods and organisations that sell online services.

Service providers must ensure the service remains accessible as any changes to the service are made, as well as in response to any updated harmonised accessibility standards. They need to make available public documentation about how the service meets the requirements, and if they discover any conformance issue, take corrective measures and inform the appropriate Member state authority.

Note: There is no enforcement of this last requirement, but if a monitoring or enforcement organisation discovers this was not done when an issue was found, they may push for more strict remediation requirements.

Member states

As the EAA is a delegated act, Member states must pass implementing acts. Different states take different approaches, and thus there are a varying number of acts per state. The EAA directs implementation acts to:

  • Adopt harmonised standards that meet the EAA requirements along with any national requirements;
  • Perform market surveillance and provide for enforcement;
  • Ensure that the emergency access number 112 is routed to an accessible service.

Harmonised standards need to a) meet the requirements of the EAA, and b) be compatible with standards adopted in other states. In practice, this means all states should adopt a single harmonised standard, either directly or by reference from other standards. Member states are allowed or encouraged to include accessibility requirements and standards that go beyond the EAA and the harmonised standards. For instance, if a characteristic of a writing system can create accessibility barriers, then member states where that system is used might include a supplementary standard, which does not conflict with harmonised standard, for content in their country.

States are also encouraged to include requirements around the built environment, mainly in public spaces. The suggested requirements are in Annex III, which is not part of the conformance requirements of the EAA, but contains suggestions for member state implementation acts.

Market surveillance mechanisms for products are defined in Regulation 765 / 2008 and are already in force. The EAA directs that products addressed defined in the act are subject to those market surveillance activities. Market surveillance authorities should be able to respond to complaints and perform assessments. If economic operators do not participate in efforts to remediate conformance failures, member states should be able to issue penalties that are ‘effective, proportionate and dissuasive’. This also includes removal of a product's CE mark.

Regulation 765 / 2008 does not address services. The EAA extracts the requirements summarised in the paragraph above, and applies them to services as well. This means market surveillance should be able to evaluate and work to remediate online services, in a similar manner as for products.

Note: Mechanisms to support this process, which are defined in Regulation 765 / 2008, were not incorporated into the EAA, so they do not apply to services. Some states may choose to use the same enforcement bodies and approaches that they use for products, while others may choose to set up new bodies or approaches for market surveillance of services.

A final requirement on member states is that they must ensure the emergency number 112 will go to an accessible service. However, emergency services do not need to conform until 28 June 2027, two years after other products and services.

Member state implementation acts are listed in the National transposition tab of the act's page in the EUR-Lex site. Although most member states did not meet the 2022 deadline for implementation acts, all 27 states have now notified the EU of their acts. Implementing acts may be new acts, amendments to existing acts, or assertions that existing acts are already sufficient.

There is not a formal indication of whether the set of acts listed is complete or whether additional ones are pending, but most likely member states submitted what they believed to be complete support. Advocacy organisations such as the European Disability Forum work with member states and the EU to address issues.

Conformance

Because the EAA relies on harmonised standards to define technical conformance criteria, it does not provide specific information about how to determine conformance of a product or service. Annexes IV and V provide very generic procedural suggestions, but the details will come from standards. If products or services conform to a harmonised standard, then under the concept of ‘presumption of conformity’, it is presumed to conform to the EAA.

Standards

Detailed conformance guidance for the act will come from harmonised standards. The process for the European Commission to request that standards development organisations produce a technical standard to support an act is defined in Regulation 1025 / 2012.

The standard that has resulted from this process for the European Accessibility Act is EN 301 549 (Accessibility requirements for ICT products and services). EN 301 549 addresses accessibility of information and communications technologies, including both hardware and software aspects as well as access to the digital environment. It is organised in a completely different manner than the EAA, in order to specify requirements across a range of hardware and software types.

Note: At the time of this writing, EN 301 549 is in a finalisation process and not yet fully official. Further updates are not likely to introduce major technical changes, so the standard is generally ready for use, and in practice must be used in its current form as organisations prepare for the EAA conformance deadline. To help with adoption, we will publish an explainer of the EN 301 549 in January 2025.

While the EN 301 549 addresses nearly all of the requirements spelled out in the EAA, its scope is limited to information and communication technologies. There are some EAA requirements that it therefore does not address. This explainer will point these out with ‘[Not in EN 301 549]’ and reference standards for that requirement if they exist. Where standards do not exist, the requirement can be taken as regulatory text and implemented as stated.

Note: The EN 301 549 is the relevant standard for all of the requirements below, unless indicated otherwise.

Exceptions

The EAA exempts one type of product from the general requirements for products — medical devices. Medical devices that also function as assistive technologies, however, are not exempted. This includes devices like cochlear implants, implanted prosthetics, health emergency alert devices, etc.

Long-life installed products like self-service and information terminals can remain installed and operational for up to 20 years before needing to be replaced by a version that conforms. This applies only to products installed before 28 June 2025, and whenever replaced (28 June 2045 at the latest), they must be replaced with a version that conforms to the EAA.

Some types of content are also exempted from the requirements. The main exemption is that content published and not updated before 28 June 2025, the implementation date of the act. Effectively this exempts archives, but content is not archival if it is updated. Therefore, content originally published before the implementation date, but updated after, is covered by the requirements. Technically only content which has been updated needs to conform, but in practice this may require updates to the entire site or repository.

Two further types of content are exempted:

  • Digital maps do not have to meet the requirements, if an accessible alternative is available, such as turn-by-turn text directions;
  • Content provided by a third-party, who is outside the EU and not subject to the requirements, and over which the economic operator has no control, is exempted.

Note: when content is provided by a third party as part of a contracted service, that content is under control of the economic operator contracting the content. This content is not exempted even if provided by a third party outside the EU. Contracts with third party content providers should include EAA conformance obligations.

Fundamental alteration

Accessibility is not meant to be a burden, and for most economic operators, implementing accessibility well does not require an unreasonable proportion of the product or service cost. In some circumstances, however, this is not true, and the act exempts requirements that would impose ‘fundamental alteration’ to the product or service.

Fundamental alteration means a change for accessibility to a product or service requires a significant change to its nature. For example:

  • A device intended solely for audio transmission, such as a ‘dumbphone’, would be fundamentally altered by adding video support;
  • A game whose core user experience is designed around two-handed operation, might be fundamentally altered by adding single-switch access;
  • A self-service terminal designed for operation at average standing height would be fundamentally altered by positioning it for seated height;
  • A visual learning test that would be invalidated by the use of non-visual cues.

Not all design changes constitute fundamental alteration. A dumbphone that intentionally does not provide video would be fundamentally altered by adding that capability, while a smartphone that already supports video is not fundamentally altered by following the requirement to synchronise video and speech in live conversation. Some design changes may seem like fundamental alteration, such as tactile and force requirements for input controls, but just require a more inclusive rethink of the overall design.

The act also uses the example of a bank of self-service terminals, where it might fundamentally alter their operation to position them all at wheelchair height, or present a disproportionate cost burden to add hearing assistance support to each of them. In such cases, the act points out that altering only some of the self-service terminals can achieve the same accessibility benefit — for instance, ensuring that for every bank of ticket machines, at least one has accessible approach and operation. When such an approach is feasible, the fundamental alteration exemption may not apply.

Disproportionate burden

Disproportionate burden is a concept that applies to smaller organisations without the ability to meet all the EAA requirements with their resources. Organisations may claim the disproportionate burden exemption for a feature in this case, but must observe the following conditions:

  • Most importantly, if a particular accessibility feature is a disproportionate burden but others are not, the organisation must implement those other features;
  • The organisation is still required to maintain an accessibility assessment report, available on request to market authorities, which includes the claim of disproportionate burden and the reasons for it;
  • Every 5 years, or whenever the product or service is altered, the organisation must review whether the disproportionate burden exemption still applies;
  • Organisation should consider the cost / benefit ratio for an accessibility improvement as part of determining whether it constitutes a disproportionate burden;
  • The act explicitly says ‘Lack of priority, time or knowledge should not be considered to be legitimate reasons’.

Micro-enterprises, with 10 or fewer employees, are exempt from the above assessment and reporting requirements, and market surveillance authorities are directed to have proportionate expectations of smaller organisations. In practice, this effectively exempts micro-enterprises from the act altogether, though they are still encouraged to implement accessibility features as much as possible. Small and medium enterprises (SMEs) are also less likely to be reviewed by market authorities, though this may depend on the economic importance of the product or service.

Note: Annex VI provides some criteria to assess disproportionate burden. While some of those criteria refer to considerations like cost / benefit ratios, the annex does not indicate what would be acceptable ratios.

Accessibility requirements

As a general description of accessibility, the act says products and services follow the principle of ‘Perceivable, Operable, Understandable, and Robust (POUR)’. This means users must be able to:

  • Perceive content, notwithstanding any sensory disabilities they have;
  • Operate content, notwithstanding any motor disabilities they have;
  • Understand content, notwithstanding challenges from perception or operation, or from cognitive disabilities;
  • Rely on Robust content to work for them, notwithstanding the use of personalization or assistive technology.

Specific accessibility requirements are defined in Annex I. Several lists in this annex address functional performance, requirements for all products and / or services, and for specific types of products and services. The remainder of this explainer extracts and clarifies the content from those lists.

Note: Many products and services place an organisation's obligations into several of the categories below at once. For instance, a manufacturer of consumer ICT that sells the product online and provides customer support needs to follow the hardware requirements, e-commerce requirements, and support service requirements.

Functional performance criteria

The functional performance criteria can be thought of as the next level of detail from the ‘POUR’ model above. They describe general types of issues that challenge people with disabilities:

  • Usage without vision;
  • Usage with limited vision;
  • Usage without perception of colour;
  • Usage without hearing;
  • Usage with limited hearing;
  • Usage without vocal capability;
  • Usage with limited manipulation or strength;
  • Usage with limited reach;
  • Minimising the risk of photosensitive seizures;
  • Usage with limited cognition;
  • Privacy.

Each of these criteria fit into one of the POUR categories, except for privacy. This is because accessibility accommodations can create new privacy risks that might not be discovered in a mainstream privacy review. Safe features are important to an accessible user experience.

While the functional performance criteria are a useful model to organise and understand the general approach to accessibility taken in the EAA, the act does not provide much more detail about them. It states that they are not considered sufficient for conformance for any situation that is addressed in the remainder of the annex. However, the act does state that a product or service might use functional performance criteria for conformance, if it still complies with existing requirements and ‘the design and production of products and the provision of services results in equivalent or increased accessibility’. This means an improved technological solution, not yet recognised by the standards, is allowed to be deployed.

Note: It is in principle possible to conform to the EAA without use of harmonised standards. In practice, this is not a recommended venture, as it requires additional work and documentation, and is likely in most cases to converge on the same solutions anyway.

Common requirements for all products and services

The act includes a few specific requirements in support of the general requirements that apply to all products and services:

  • Content must be available in more than one sensory channel (alternate sensory channels may be provided by assistive technology when possible);
  • Text must be displayed in a font of ‘adequate’ size and shape, sufficient contrast, and with adjustable spacing between letters, lines, paragraphs (‘adequate’ is not clearly defined);
  • Content must be understandable;
  • Make available a text version of content that can be used with assistive technology;
  • Provide alternative forms of presentation for non-textual content.

Requirements for specific service types

The act addresses several service sectors:

  • Electronic communications providing emergency service access;
  • Audio and visual media;
  • Passenger transport;
  • Consumer banking;
  • E-commerce services;
  • Support services;
  • Real-time communication.

Services must follow the common requirements for all products and services, and in addition follow the sector-specific requirements below.

Electronic communications providing emergency service access

The European Communications Code provides requirements for electronic communications services and networks, such as internet access services, interpersonal communications services such as telephones and videoconferencing, and broadcasting services. That code includes some accessibility requirements:

  • Regulatory consultation for electronic transmission projects include accessibility to end users with disabilities as part of the considerations;
  • Provide APIs and electronic programme guides;
  • Impact of accessibility to be considered when determining whether a service has enough market power to be given extra obligations;
  • Ensure equivalent access to emergency communication services and the emergency number ‘112’, and provide accessible information about it;
  • Provide equivalent access to the missing children number ‘116000’;
  • Member states may include accessibility features as part of ‘must carry’ obligations;
  • Member states set regulation that requires users with disabilities have equivalent access to electronic communications services, with meaningful options to exercise market choice.

Note: The above requirements are incorporated by reference from regulations. Those regulations do not use harmonised standards, and the EN 301 549 does not address non-ICT aspects of the transport industry. These requirements in this section should be treated as regulatory text and implemented as stated.

In addition to incorporating the above requirements, the EAA addresses electronic communication services which provide emergency service access, and emergency services themselves. They must:

  • Support real-time text channels in addition to voice channels;
  • Have procedures to address callers with disabilities;
  • Respond to calls in the same channel (voice, text, relay, etc.) in which it was received.

Services are also encouraged to provide the capability to respond to multi-channel (e.g., video and voice, voice and text, etc.) calls, but this is not a conformance requirement.

Audio and visual media

The Audiovisual Media Services Directive defines audiovisual media services as television broadcasts, on-demand television and streaming media, and audiovisual commercial communication such as advertising. All these industries are responsible under EAA to:

  • Ensure that accessibility features of content they handle are fully transmitted with adequate quality to display, including features such as subtitles, audio descriptions, and sign language windows;
  • Synchronise subtitles and sign language with audio and video;
  • Encode subtitles and sign language video with sufficient quality to be useful to the viewer;
  • Where there is a user interface, such as on a television or streaming app, the UI must provide accessible controls for users to control how alternative content is displayed;
  • Services that provide electronic programme guides must ensure that those provide information about accessibility features of the content, and are themselves accessible. [Not in EN 301 549]

Passenger transport

Several regulations related to passenger transport already include accessibility requirements, which the EAA incorporates by reference. Each regulation applies to a specific segment of the passenger transport industry, including the Air Passengers Rights regulation, Rights of disabled persons and persons with reduced mobility when travelling by air regulation, Rail passengers' rights and obligations regulation, Maritime passenger rights regulation, and Rights of passengers in bus and coach transport regulation. The EAA specifically exempts urban, suburban, and regional transport services, categories which are also not directly addressed in the above regulations.

Requirements for transport apply to portions of the journey arriving at or originating in the EU, but extraterritorial carriers are encouraged to follow the same guidance for the entire journey, in particular regarding assistance during transfers.

Most of the requirements in these regulations apply across all the industries:

  • Do not refuse service because a person has a disability or reduced mobility;
  • Allow persons with special needs to identify their needs when making a travel reservation;
  • Transmit that information to relevant operators on the itinerary, including transfer and endpoint ports and stations, and operators of all segments of the journey;
  • Provide mobility assistance at ports and staffed stations including during connections, if passengers have identified their needs at least 48 hours in advance;
  • Provide accessible routes at ports and stations for the entire process from entrance to boarding, including security;
  • Ensure accessible routes are clearly marked;
  • Ensure passenger transport vehicles (aeroplanes, boats, coaches, trains) can accommodate passengers with disabilities;
  • Meet the special needs of persons with reduced mobility, and any persons accompanying them;
  • If this is impossible due to safety, vehicle size, or port / station accessibility, inform the passenger immediately and offer reasonable alternatives;
  • Provide public information, in accessible formats, about the accessibility of services;
  • Ensure documentation such as booking information and tickets are accessible;
  • Not charge additional fees on the basis of access requirements;
  • Reimburse or reroute passengers, at their choice, if safety or other conditions make a reserved journey impossible;
  • Allow passengers to be accompanied by service animals;
  • Compensate passengers for lost or damaged mobility equipment, such as wheelchairs.

In addition to these common requirements, the regulations include a few sector-specific requirements:

  • For buses and coaches, where access requires help from a companion, allow this person to join the journey without charge, and seat them together if possible;
  • For coaches and water transport, the obligation above to provide mobility assistance for embarkation applies, but requires the passenger to arrive at least 60 minutes before embarkation;
  • For air travel, carriers must:
    • give priority to carrying persons with reduced mobility and any persons or certified service dogs accompanying them, and
    • in cases of flight delays, provide care (meals, hotel, etc.) for persons with reduced mobility and any persons accompanying them soon as possible.

The EAA does not summarise these requirements, but states that meeting them is part of the EAA regulation. It adds a few additional requirements:

  • Carriers must provide information about the accessibility status of vehicles used in the trip, and about ports and stations;
  • Provide information in accessible online formats relating to ticketing, travel info, service updates, etc.;
  • Notwithstanding the general exemption for urban and regional transport services, these providers must at least ensure self-service terminals meet EAA requirements.

Note: The above requirements are incorporated by reference from regulations. Those regulations do not use harmonised standards, and the EN 301 549 does not address non-ICT aspects of the transport industry. These requirements in this section should be treated as regulatory text and implemented as stated.

Consumer banking

Consumer banking is defined by several EU acts (Directive 2008 / 48, Directive 2014 / 17, Directive 2014 / 65, Directive 2015 / 2366, Directive 2014 / 92, Directive 2009 / 110), which together address organisations that provide:

  • consumer credit or mortgage agreements,
  • investment services,
  • payments services,
  • consumer banking services, and
  • electronic money services.

Requirements related to many of these services are covered by other areas of the act, such as requirements for accessible online information, support service, and self-service terminals (ATMs). In addition, requirements specific to consumer banking services include:

Note: At level B2, the expectation is that people ‘can understand the main ideas of complex text on both concrete and abstract topics, including technical discussions in his/her field of specialisation’. That is a fairly high comprehension expectation especially for a universal service, and while statistics are not available, probably applies only to people above the 50th percentile. The goal of accessibility, however, is to meet the needs of more than the most proficient half of the population. Level B1 says people ‘can understand the main points of clear standard input on familiar matters’, and I suggest targeting Level B1 wherever feasible, especially in customer-facing content.

E-commerce services

E-commerce services include both services that sell products online, and online services that are themselves the product. The online storefront of these services is covered by the general requirements of the EAA. Beyond these, the act requires:

  • Online services must ensure the service itself as well as the storefront meet the requirements of the act;
  • Online services must provide accessible identification methods, electronic signatures, security, and payment services;
  • Services selling products must provide available information from the vendor about the accessibility of the product.

Support services

Any customer support service (call centres, online support interactions, training, etc.) associated with a product or service is also covered by the act. Customer support services must:

  • Provide information to customers about the accessibility of the product, including its compatibility with assistive technologies;
  • Use accessible modes of communication to interact with customers, following applicable requirements for the mode of communication.

Real-time communication

Real-time communication services exist on a variety of devices and include features like mobile phones, SMS / MMS, video chat, and text chat. Not all devices support specific channels (voice, text) addressed by the act, for ones they support:

  • Devices able to handle text as well as voice must:
    • provide high fidelity audio, and
    • support the use of real-time text;
  • Devices with video in addition to text or voice must:
    • synchronise the channels so text and audio coincide with the video, and
    • provide the video in a resolution sufficient to be able to understand sign language.

Requirements for all products

Beyond services, the EAA also addresses several types of products. Products must follow the common requirements for all products and services, and in addition follow the requirements in this section that apply to all products:

  • Features:
    • Support communication in more than one sensory channel, specifically ‘alternatives to vision, auditory, speech and tactile elements’;
    • Provide alternatives to speech input, such as keyboard, pointer, etc.;
    • Ensure that visual elements can have magnification, brightness, contrast adjusted;
    • When using colour to convey information (such as to distinguish elements or categorise features), convey that information as well by alternate means;
    • If there are auditory signals important to the interaction with the product, provide alternate forms of notification as well;
    • Provide ways to increase visual clarity (which is not further explained but examples may include display adjustment or image processing); [Not in EN 301 549]
    • Ensure the user can control audio volume and speed; [Not in EN 301 549]
    • Do not trigger photosensitive seizures, which are connected to display details and visual patterns;
    • Protect the privacy of users of accessibility features, such as by ensuring both auditory and visual masking of password input;
    • Products that include biometric features for user identification or device control must provide alternative forms of those features as well;
    • Design products to provide consistent functionality; [Not in EN 301 549]
    • Provide enough time for users to complete interactions and support user requests for more time.
  • Physical input aspects of the hardware:
    • Where physical input requires fine motor control, alternate physical inputs are also provided;
    • Support a sequential control mode, in which a user can operate the device with a binary control, such as a button (single-switch access);
    • Include modes of input that do not require the use of multiple controls simultaneously;
    • Design physical controls so they can be discerned from each other by touch;
    • Do not require extensive reach or strength to operate the controls.
  • Assistive technology:
    • Hardware and software must support assistive technology, which may require hardware and software interfaces;
    • Products must ensure that visual elements are implemented in a way that they can be accessed with assistive technology.
  • Customer support services related to products must meet the support service requirements.
  • Online product documentation must provide descriptions of:
    • accessibility features of the product,
    • interoperability with assistive technology, including a list of specific tools used in testing (if any), and
    • product user interface and functionality.

Requirements for specific product types

Beyond the above requirements that apply to all products, above, products also follow requirements for their specific type:

  • self-service terminals,
  • e-readers and e-books,
  • consumer network provision devices,
  • consumer audiovisual devices, and
  • distribution.

Self-service terminals

Public terminals that provide consumer self-service functions for payments, banking, ticketing, information, etc. must:

  • Provide text-to-speech support on the device that users can enable, so text displayed on screen will be spoken;
  • Allow users to connect headsets for private audio;
  • Display content with adequate contrast;
  • Design keys and controls to be tactilely discernible;
  • If the product uses audio or audible signals, the product must be compatible with assistive listening devices;
  • If the product requires user response within a given time, it must alert the user in more than one sensory channel, and allow them to extend the time given;
  • For accessibility features that must be activated by the user, there must be an accessible way for the user to activate them without that feature being yet active.

Note: the EAA does not necessarily expect that all self-service terminals will meet these requirements, just enough of them that users with disabilities are equivalently served. See Fundamental alteration above for further information.

E-readers and e-books

The EAA categorises e-books as services, but as the content requirements are associated with hardware capabilities, this explainer addresses both e-books and e-readers here. Requirements for e-books:

  • E-books that provide audio narration in addition to text must synchronise the text and audio;
  • Content must be in a format that allows users to access it with assistive technology; [Not in EN 301 549]
  • Provide access to content and navigation features, and allow flexible presentation; [Not in EN 301 549]
  • Include metadata about accessibility features in the content; [Not in EN 301 549]
  • Digital Rights Management (DRM) implementations allow assistive technology to interact with content.

E-book requirements imply requirements for e-reader hardware that are not addressed in other sections about hardware. In particular, e-readers need to:

  • Provide mechanisms to personalise display;
  • Synchronise text with audio;
  • Support users to navigate content.

There is not a requirement that e-readers support assistive technology, even though the content must be in a format that supports it. If e-readers do support external devices, however, they need to allow assistive technology to access the content, even when it is protected by DRM.

E-readers are not specifically required to support audio content; however, the EAA does specifically mandate that E-readers provide text to speech capability, allowing audio access to the content without use of assistive technology.

Note: EPub 3 is a format for e-books that meets these requirements (except for DRM features which must be handled separately). It is well-supported for accessibility and provides its own explanation of how it maps to the EAA.

Note: The Marrakesh Treaty defines an international copyright regime that allows authorised organisations to create accessible digital copies of copyrighted works, with requirements to avoid unauthorised distribution. Directive 2017 / 1564 defines how this works in the EU, and Regulation 2017 / 1563 allows the accessible digital content to be shared with authorised entities across the entire treaty zone.

Consumer network provision devices

Modems, routers, etc. provide consumer access to digital data. When these devices provide user configuration features that include voice or video, they must:

  • Support high-fidelity audio;
  • If they support text, provide real-time text support;
  • If they support video,
    • provide a resolution enabling sign language communication, and
    • support full synchronisation of audio, video, and real-time text.

Network devices that use a radio signal as part of its operation, such as a wifi router or bluetooth device, must support ‘wireless coupling’. Wireless coupling is a generic term for approaches to send audio data directly to a hearing aid over a wireless connection. Designed primarily for room-scale range, they use similar frequencies to other devices designed for that range, and those devices must be sure not to create signal interference. A wifi router may also be a component of the wireless coupling process between two other devices, so the act requires that the network device ensure that hearing technologies can connect with them. Specifically:

  • Ensure effective wireless coupling to hearing technologies; [Not in EN 301 549]
  • Avoid emitting signals that could interfere with assistive listening devices. [Not in EN 301 549]

Note: ETSI TR 102 791 addresses these requirements.

Consumer audiovisual devices

Televisions and radios that present digital audiovisual media must ensure that accessibility features in the content are made available to users. Users should be able to activate and control desired features, and use any customization features available. When assistive technology is connected to the audiovisual device, this content must also be passed on to the AT.

Distribution

Product information that is distributed along with the product, such as usage instructions, must be made accessible. Information about accessibility of the product should also be provided on the package itself when feasible. [Not in EN 301 549]

Note: While some forms of digital packaging information exist,included product information is usually printed material. The EN 301 549 addresses accessibility of digital content, not of print content, and therefore does not provide information about how print materials should conform to this requirement.

Note: Emerging technologies may support digital product information available directly from product packaging. Those technologies will need to provide accessible digital content to meet this requirement.

When products provide product information online, that information must also meet the common requirements above. [Not in EN 301 549]

Note: It is helpful for included documentation to provide an easy to usereference to accessible online documentation, such as with a visible simple URI and/ or a QR code.

Next steps

This was a high-level summary of the obligations and accessibility requirements of the European Accessibility Act. It focused mainly on clarifying the act for ‘economic operators’, businesses that produce products or services covered by the act. Reading this explainer should give you an understanding of whether your products or services are covered, and if so what are your obligations.

Neither this explainer nor the text of the act itself provide enough information to be able to certify that a product or service conforms to the requirements. The EN 301 549 standard provides most of the technical information about how to conform, with a few exceptions noted above. That standard will be used primarily by product designers and developers, acting on organisational activities to ensure conformance to the act.

Note: We will publish an explainer of the EN 301 549 standard in January 2025. It will describe how EN 301 549 divides the requirements by type of ICT product, some of which include real-time text, 2-way audio and video, ICT hardware, web content, software, electronic documents. Requirements in the standard can be understood via an expanded POUR model, an approach that also shows how requirements combine for various products. The explainer will provide information to help interpret requirements that refer to Web Content Accessibility Guidelines (WCAG) 2.1. Finally the explainer will provide a comprehensive summary of all the requirements, organized contextually.

Requirements for products and services go into effect this 28 June 2025. Economic operators should have plans for conformance well under way by this point. These plans need to include accessibility of the product or service itself, development practices that ensure accessibility does not back-slide, assessment of the product, and preparing reports for market surveillance authorities. Clarification of these responsibilities in the explainer will help you to ensure your organisation is ready for that date.

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Document author: Michael Cooper on behalf of The Digital Accessibility Centre Limited