Does the EAA apply if I sell to EU customers from outside the EU?

Yes. The EAA covers any economic operator that places covered products or services on the EU market, regardless of headquarters. A US-based ecommerce site shipping to EU consumers is in scope unless it qualifies for the micro-enterprise exemption.

What is the micro-enterprise exemption?

Businesses with fewer than 10 employees AND less than €2 million annual turnover or balance sheet total may be exempt from EAA service obligations. The exemption is narrow and is generally interpreted strictly; companies that are part of a larger group typically do not qualify.

I have an existing service from before June 28, 2025 — when do I need to comply?

Article 32 of Directive 2019/882 is narrower than a blanket grace period. It provides three transitional carve-outs: (i) Member States may allow service providers to continue using *products* lawfully used to deliver similar services before June 28, 2025 until June 28, 2030; (ii) service contracts agreed before June 28, 2025 may continue without alteration until they expire, but no longer than 5 years from that date; (iii) self-service terminals lawfully used before June 28, 2025 may continue to be used for up to 20 years from their entry into use. There is no statutory clause saying "websites already live before June 28, 2025 have until 2030." Plan for the June 28, 2025 compliance date; do not assume your existing site benefits from the 2030 transition unless one of the Article 32 carve-outs actually applies.

Where do I publish my EAA accessibility statement?

Annex V §1 says the information should be included in the general terms and conditions or an equivalent document, made available to the public in written and oral format, in a manner accessible to persons with disabilities. The cleanest and most discoverable implementation is a dedicated public page (e.g. at /accessibility, linked from the global footer), and most operators do this — but the directive does not prescribe a specific URL or page name. The “publish a statement on the website” model with a fixed location comes from the Web Accessibility Directive 2016/2102 (public sector), not the EAA.

Compliance

European Accessibility Act (EAA) Guide

Last updated May 25, 2026

The European Accessibility Act (Directive 2019/882) became enforceable on June 28, 2025. It applies to an enumerated list of consumer products and services — e-commerce, consumer banking, passenger- transport digital touchpoints, electronic communications, audiovisual media access, e-books and dedicated software, plus consumer computing hardware/OS, self-service terminals (ATMs, payment / ticketing / check-in machines) and e-readers — placed on the market or provided to EU consumers from that date. It is not a blanket obligation on every business that sells to EU consumers — but beware one important nuance: e-commerce services are themselves on the Article 2(2)(f) list, so a store can be in scope via its e-commerce service even when the physical goods it sells are not enumerated as covered products. A Shopify storefront selling t-shirts (not an EAA-covered product per se) can still be in scope because the e-commerce service it provides is covered. If neither what you sell nor how you sell it is on the Article 2 list, you are likely out of scope. Where the EAA does apply, the technical bar is set by EN 301 549, which maps directly to WCAG 2.1 Level AA. Unlike the ADA, the EAA explicitly names a technical standard and applies to the private sector by default.

Who the EAA Applies To

The EAA applies to any business that places coveredproducts or services (as enumerated in Article 2) on the EU market, regardless of where the business is headquartered. If you sell covered products or services to EU consumers through a website or app, you are likely in scope. Micro-enterprises (fewer than 10 employees and under €2 million annual turnover) are exempt, but the exemption is narrow and does not apply to businesses that are part of a larger group.

Products and Services Covered

The EAA covers a broad range of digital products and services:

E-commerce — Online stores and marketplaces, including product information, checkout, and payment.
Banking and financial services — Online banking, investment platforms, and payment terminals.
Transport — Websites and apps for air, bus, rail, and waterborne passenger transport services.
Telecommunications — Websites, apps, and equipment for electronic communication services.
E-books and e-readers — Digital publications and the devices used to read them.
Computing hardware and software — Operating systems, consumer hardware, and general-purpose software.

Technical Standard: EN 301 549

The EAA points to the harmonised European standard EN 301 549 as the presumption of conformity. For web content, EN 301 549 directly references WCAG 2.1 Level AA. This means achieving WCAG 2.1 AA conformance satisfies the web accessibility portion of the EAA. EN 301 549 also includes additional requirements for non-web software, hardware, and documentation that go beyond WCAG.

Enforcement and Penalties

Each EU member state enforces the EAA independently through its own market surveillance authority. Penalties vary significantly by country:

Italy — Under D.Lgs. 82/2022 (the EAA transposition), AgID can impose administrative fines of €5,000–€40,000 per violation, plus €2,500–€30,000 for ignoring supervisory orders. Italy also has the older Stanca framework (Legge 4/2004, extended to private companies via DL 76/2020) which can sanction private companies with 3-year average turnover above €500 million up to 5% of annual turnover through an AgID notice-and-cure procedure.
Spain — Under Ley 11/2023, Article 27 defers to sectoral legislation and supplementarily to the TRLGDPD (Real Decreto Legislativo 1/2013) Title III sanctions regime: fines run up to €1,000,000 for very serious infringements (TRLGDPD Article 83), with accessory measures under Article 85 including loss of public subsidies and disqualification from contracting with public administrations.
Germany — Germany's transposition law is the Barrierefreiheitsstärkungsgesetz (BFSG), which entered into force on June 28, 2025. Market surveillance is conducted by the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF AöR), a joint authority of the 16 Länder based in Magdeburg, established by interstate treaty and operational since September 26, 2025. § 37 BFSG sets fines from €10,000 to €100,000 per violation.
France — The EAA is transposed by Loi 2023-171 and points to RGAA 4.1 as the operational checklist. Enforcement runs through DGCCRF for ecommerce-side obligations, with parallel civil claims available to disability-rights organisations under the Consumer Code.

Beyond fines, non-compliant businesses risk being barred from selling in specific EU markets until they demonstrate conformity. Consumer organizations can also bring complaints on behalf of affected users.

How the EAA Differs from the ADA

Explicit technical standard

The EAA directly references EN 301 549 (WCAG 2.1 AA). The ADA Title III has no codified technical standard — WCAG is applied through court precedent and settlements.

Private sector by default

The EAA applies to any business selling covered products or services (per Article 2) to EU consumers. The ADA's explicit digital rules (Title II) currently only cover government entities, while Title III coverage is established through litigation.

Accessibility information required

Under EAA Article 13 and Annex V § 1, service providers must publish accessibility information in their general terms and conditions or an equivalent document, in an accessible format. A dedicated public statement page is the cleanest implementation but is not statutorily required at a fixed URL (that mandate comes from the older Web Accessibility Directive 2016/2102 for the public sector). The ADA does not require any equivalent, though publishing one is best practice.

Extraterritorial reach

The EAA applies to non-EU companies that sell into the EU market. A US-based e-commerce site shipping to EU customers must comply.

Getting Compliant

If you serve EU customers, the path to EAA compliance is straightforward:

Audit your web properties against WCAG 2.1 AA using automated and manual testing.
Prioritize and fix violations, starting with the highest-severity issues.
Publish an accessibility statement documenting your conformance level, known issues, and a contact mechanism.
Establish ongoing monitoring to catch regressions from content updates and new features.

See where your site stands against EAA requirements. Try SweepHound's free scan for an automated WCAG scan with actionable remediation guidance and recommended manual follow-up.

Frequently asked questions

Does the EAA apply if I sell to EU customers from outside the EU?: Yes. The EAA covers any economic operator that places covered products or services on the EU market, regardless of headquarters. A US-based ecommerce site shipping to EU consumers is in scope unless it qualifies for the micro-enterprise exemption.
What is the micro-enterprise exemption?: Businesses with fewer than 10 employees AND less than €2 million annual turnover or balance sheet total may be exempt from EAA service obligations. The exemption is narrow and is generally interpreted strictly; companies that are part of a larger group typically do not qualify.
I have an existing service from before June 28, 2025 — when do I need to comply?: Article 32 of Directive 2019/882 is narrower than a blanket grace period. It provides three transitional carve-outs: (i) Member States may allow service providers to continue using *products* lawfully used to deliver similar services before June 28, 2025 until June 28, 2030; (ii) service contracts agreed before June 28, 2025 may continue without alteration until they expire, but no longer than 5 years from that date; (iii) self-service terminals lawfully used before June 28, 2025 may continue to be used for up to 20 years from their entry into use. There is no statutory clause saying "websites already live before June 28, 2025 have until 2030." Plan for the June 28, 2025 compliance date; do not assume your existing site benefits from the 2030 transition unless one of the Article 32 carve-outs actually applies.
Where do I publish my EAA accessibility statement?: Annex V §1 says the information should be included in the general terms and conditions or an equivalent document, made available to the public in written and oral format, in a manner accessible to persons with disabilities. The cleanest and most discoverable implementation is a dedicated public page (e.g. at /accessibility, linked from the global footer), and most operators do this — but the directive does not prescribe a specific URL or page name. The “publish a statement on the website” model with a fixed location comes from the Web Accessibility Directive 2016/2102 (public sector), not the EAA.