European Accessibility Act: What Businesses Need to Know About EAA Compliance

European Accessibility Act: what businesses need to know

The European Accessibility Act (EAA) creates common accessibility requirements for certain products and services sold in the EU. Businesses that design, make, sell or supply covered products and services must plan for accessibility, test for it, and keep records that show they took reasonable steps.

Which products and services are commonly in scope

The EAA targets categories where accessibility barriers matter for everyday participation. Common examples include:

• computers, laptops and operating systems
• smartphones and telephony
• e-books and e-readers
• television equipment and digital TV systems
• automated teller machines, payment terminals and ticketing machines
• e-commerce platforms and online banking services
• transport passenger information systems and ticketing services

Whether a specific product or service is covered depends on the product specification and how it is supplied. Check national guidance or legal advice for a final view.

Key legal and technical points to understand

Accessibility requirements vs standards

The EAA sets legal accessibility requirements. EU harmonised standards give a presumption of conformity. A frequently used harmonised standard for ICT is EN 301 549, which aligns with WCAG accessibility criteria for digital content. Use harmonised standards where available to show compliance.

Documentation and conformity evidence

For products, keep technical documentation that explains how accessibility was assessed and addressed. For services, keep test reports and records of user feedback and fixes. Documentation should make it straightforward to demonstrate a compliance process to competent authorities or customers.

Accessibility information for users

Businesses should publish clear accessibility information about their product or service. That can include supported accessibility features, known limitations, and how customers can get accessible alternatives or assistance.

Practical compliance checklist for businesses

1. Scope: decide whether your product or service falls under the EAA categories.
2. Map users: list the user groups affected, including people with vision, hearing, motor and cognitive disabilities.
3. Audit: run an accessibility audit using manual and automated testing and real users with disabilities.
4. Standards: identify relevant harmonised standards, such as EN 301 549, and the relevant WCAG level that applies.
5. Remediate: prioritise fixes by user impact and legal risk, then implement.
   • Start with critical journeys like payment, login and booking.
6. Verify: perform independent testing after fixes. Include assistive technology tests.
7. Document: keep a record of tests, defects, fixes, and the accessibility statement for users.
8. Procurement and contracts: add accessibility clauses for suppliers and contractors.
9. Training: teach product, UX and customer teams how to keep accessibility in future releases.
10. Monitor: set a process for user feedback, complaints and ongoing checks.

How to test effectively

Good testing mixes methods. Automated scanning finds some problems fast. Manual review finds keyboard and semantic issues. User testing with people who use assistive technology finds real barriers. Include screen reader tests, keyboard only tests, and trials on small screens and older devices.

What to include in your technical documentation

Keep a concise folder that answers a reviewer quickly. Useful items include:

• product or service description and versions tested
• accessibility requirements referenced (for example EN 301 549 and the WCAG level used)
• test plans and test reports, with dates and tester roles
• list of known accessibility limitations and planned fixes
• accessibility statement and customer support process
• procurement clauses and supplier attestations

Common mistakes businesses make

• Relying only on automated tools. Automated checks miss many issues and can give a false sense of security.
• Treating accessibility as a one-off project. Accessibility must be maintained through updates and releases.
• Outsourcing accessibility testing without internal ownership. The supplier can test, but your business is accountable.
• Failing to document decisions. Lack of records makes it hard to demonstrate compliance later.
• Ignoring non-web products. Accessibility obligations can apply to hardware, kiosks and software products, not just websites.

Decision framework: quick flow to decide if you must act

1. Is the item you supply a product or service in one of the EAA categories?
2. Is it sold or supplied within the EU market?
3. If yes to both, assess applicable standards and perform an accessibility risk assessment.
4. If the assessment finds material barriers, plan remediation, testing and documentation before the next major release or sale.
5. If unsure, seek advice from your national accessibility authority or legal counsel.

Real-world scenario: a software vendor selling SaaS in the EU

A SaaS vendor must check whether their product is a service covered by the EAA. If it is, they should run an accessibility audit for core flows like onboarding, billing and support. They should remediate high-impact failures, add accessibility clauses to reseller contracts, and publish an accessibility statement that explains features and how users can request help.

Next steps and who to contact

Start with an internal scoping exercise and a short accessibility audit of the most used user journeys. Keep records of the audit and your action plan. For legal certainty, contact your national competent authority for accessibility or get specialised legal advice.

Useful standards and guidance to reference

• EN 301 549 for ICT accessibility in Europe
• WCAG success criteria for web content
• WAI-ARIA for dynamic web content and widgets

Accessibility is both a legal risk and a pathway to more customers. Treat it as a product requirement, not an optional extra. Document what you did, keep improving, and make it easy for users to give feedback.