Your guide to EAA compliance: Preparing for Europe’s digital accessibility directive

Introduction

The European Accessibility Act (EAA) is set to take full effect across the European Union (EU) on June 28, 2025. The act requires that many consumer-facing technologies — from websites and mobile apps to ATMs, e-books and e-commerce platforms — be accessible to individuals with disabilities, and takes a strong step forward in creating a more inclusive Europe by promoting equal access to digital products and services.

It’s important to note, however, that the EAA is not a law on its own but, rather, a directive that requires EU member states to incorporate EAA standards into their national laws to align with their existing accessibility requirements. As a result, the EAA has been implemented as 27 national laws across the European Union.

And though there still are some questions surrounding the act, its implications for businesses and what steps member states will take to enforce it, one thing is certain — for companies that operate in or sell to the EU, it’s time to get serious about accessibility compliance.

What is the European Accessibility Act?

Adopted in 2019, the European Accessibility Act — officially Directive (EU) 2019/882 of the European Parliament and of the Council — is an EU-wide directive designed to harmonize accessibility requirements across its member states. Its goal is to remove barriers in technology, transportation, banking and digital services created by different national rules that prevent individuals with disabilities from fully participating in society.

The directive encourages a universal design approach to products and services and sets functional accessibility requirements, meaning it focuses on what needs to be accessible, not how it should be done. It applies to a wide range of products and services and outlines requirements that they be operable, perceivable, understandable and robust for users with disabilities.

What’s covered?

The EAA requires products and services be accessible to individuals with disabilities, ensuring compatibility and usability with assistive technologies without reliance on visual, auditory or fine-motor abilities. Some of the items covered by the EAA include:

Products

• Computers and operating systems, including desktop and laptop computers, tablets and smartphones.
• Self-Service terminals, including ATMs, ticketing machines, check-in machines and interactive kiosks.
• Smartphones and phone equipment, such as mobile phones and devices used for emergency communications.
• E-readers and related devices to access and read e-books.
• Payment terminals, including card readers and point-of-sale machines.
• Consumer banking equipment, such as those used to access personal banking services, including online banking terminals or apps.

Manufacturers are responsible for ensuring that their products comply with EAA requirements. Products must be accessible out of the box, meaning access cannot rely solely on third-party assistive technologies, and must come with instructions, user support and warranties.

Services

• Electronic communications services must support real-time text and conversation services (voice, text and video synchronized) if video is provided.
• Audio-visual media services, including electronic program guides and video-on-demand platforms, must include accessibility features like subtitles, audio description and accessible player controls.
• Passenger transport services (air, bus, rail, water) must provide accessible websites, mobile apps, e-ticketing options and self-service kiosks as well as information on the accessibility of its vehicles and accessible real-time updates on transportation information or service disruptions.
• Consumer banking services, such as online banking and services linked to payment accounts, loans, or electronic money, must be inclusive to all users.
• E-books and reading software should provide, among other things, synchronized audio and text, compatibility with assistive technologies and flexibility in navigation, structure and layout.
• E-commerce services, including websites and apps, must provide access for payment functions and clear accessibility statements.

Transitional exemptions

The directive includes a few “transitional exemptions,” offering “grandfathered” provisions for websites and mobile apps that were available to consumers before the enforcement deadline.

For example, an existing website or app (those publicly available before June 28) can likely operate as-is under the transitional arrangements until June 2030 so long as it does not undergo any significant updates. However, if the website or app is updated after the EAA goes into effect, it must satisfy the new requirements.

Likewise, existing ATM machines and self-service kiosks can remain in use until June 2045 unless they undergo substantial upgrades. ATMs and kiosks must comply with the directive starting from June 2025 for those placed on the market after that date.

What’s required?

Some of the key accessibility requirements outlined by the EAA include:

• Providing alternative text for images and multimedia
• Ensuring compatibility with assistive technologies like screen readers
• Providing subtitles or audio descriptions for video content
• Enabling keyboard navigation across websites and apps
• Ensuring clear and consistent user interfaces
• Making customer support services accessible, including relay and text services

The EAA also includes language around accessibility documentation and the ability for consumers to provide feedback and file complaints if they face accessibility barriers.

How will the EAA impact businesses and member states?

EU leaders say the creation of uniform accessibility rules across the European Union will lead to cost reductions and increased market opportunities for products and services. Officials note that, in the past, fragmented national accessibility laws across member states have hindered the movement of products and services and particularly impacted small- and medium-sized businesses and cross-border trade opportunities. The directive, they say, will standardize requirements, reduce costs and enable economies of scale, innovation and competitiveness.

For businesses, especially those operating online or across borders, EAA requirements mean re-evaluating current digital offerings and workflows. Companies that don’t meet the standards could face not only legal consequences but reputational risks and loss of market share.

On the other hand, enterprises that prioritize accessibility stand to gain new customers and demonstrate their commitment to social responsibility.

And since each member state enforces the EAA separately, businesses operating in multiple EU countries may need to comply with different national regulators. Additionally, even if a company is headquartered outside of Europe but does business with or serves customers in the EU, it, too, must comply with EAA regulations.

Compliance exemptions

However, small businesses across the EU are subject to slightly different rules. Microenterprises — enterprises with fewer than 10 employees and an annual turnover of less than €2 million — are exempt from some requirements, but the spirit of the law still encourages universal design practices.

Additionally, business operators can claim an exemption if the EAA’s obligations impose a “disproportionate burden,” fundamentally alter their product/service or be unreasonably costly. However, these claims must be documented and re-evaluated every five years.

EAA compliance checklist for businesses

Download our EAA compliance checklist that outlines some of the steps that businesses can take to align with the European Accessibility Act and make their products and services more inclusive.

What are the obligations for member states?

For EU member states, the EAA sets minimum accessibility requirements that must be carried into each country’s national law. Governments also are expected to establish monitoring systems and enforcement mechanisms to ensure EAA compliance, with penalties for non-compliance including fines and potential bans on selling non-accessible products or services in the EU market.

To comply, EU member states must:

• Adopt national laws aligned with the directive.
• Appoint compliance and surveillance authorities responsible for ensuring products and services comply with accessibility requirements.
• Set out penalties for non-compliance.
• Establish a system for users to report access concerns and outline ways to address them.
• Promote training, guidance and support to help businesses adapt to the new rules.

How EU countries are implementing and enforcing the EAA

Austria

The EAA aligned under Austrian laws that cover digital accessibility in both the public and private sectors. The directive will be enforced by the Austrian Federal Economic Chamber and federal market surveillance authorities.

France

France integrated EAA requirements within its national disability laws and consumer codes and built upon the country’s existing accessibility frameworks under the Code de la consommation and Code de la construction et de l’habitation. The directive will be monitored by France’s Directorate-General for Competition, Consumer Affairs and Fraud Control.

Germany

Germany transposed the EAA through its Accessibility Strengthening Act, which covers both public and private sector services. The act — enforced by the German regulatory office and regional authorities — provides guidance on accessibility for, among other things, digital products, e-commerce and transportation information systems. The government also developed a federal checklist and training for businesses.

Ireland

Ireland implemented EAA through amendments to its disability and consumer protection acts, which focus on public and private sector compliance and aligns with the country’s progressive assistive tech policies. The National Disability Authority will take on a central role in monitoring and guidance.

Italy

The EAA integrated with Italy’s Digital Administration Code and other national disability strategies. Its focus includes digital public sector services and integrations with ATMs, Italy’s Carta d’Identità Elettronica (eID), used for authentication in online and offline transactions, and transportation systems. Oversight will be handled in part by Agency for Digital Italy.

The Netherlands

The EAA was integrated into the Netherland’s Accessibility Products and Services Decree and supplements the Dutch Equal Treatment Act. Oversight will be handled by the Dutch Authority for Consumers and Markets.

Poland

Poland’s EAA directives include e-commerce and financial services among the country’s top compliance targets. The Office of Competition and Consumer Protection will oversee enforcement.

Portugal

Portugal’s inclusion of the EAA builds on its national digital accessibility framework and strong emphasis on public awareness and training.

Spain

Spain transposed the EAA within its existing accessibility laws, including those addressing the access of digital products and services, and places a strong emphasis on digital inclusion and transport accessibility. Its Ministry of Social Rights and Agenda 2030 oversees the directive.

Sweden

Sweden aligned the EAA under its national discrimination act, incorporating web and app accessibility for private services. The government created an action plan that includes training modules and enforcement tools, while involving disability organizations in the implementation process. Enforcement will be overseen by the Swedish Consumer Agency.

A more inclusive Europe: Verbit’s role in advancing EAA accessibility

The EAA is not just a compliance obligation — it’s an opportunity to redesign Europe for everyone and ensure that inclusivity, innovation and economic integration go hand in hand.

For member states, the focus now must be on supporting the directive, raising awareness and ensuring enforcement. The reward is a stronger internal market and a more inclusive society where accessibility is no longer the exception but the rule.

Verbit, a leading global provider of AI-power access solutions, is proud to support accessibility and help our partners in the EU and around the world prepare for this new regulatory era. Our AI-powered subtitling, captioning, transcription and audio description services are designed to make content accessible, understandable and inclusive.

Verbit offers accurate captions and subtitles for live and prerecorded videos — including marketing videos, product demos and website media — as well as multi-language translations for EU-wide audiences. Our text transcripts of video and audio files to ensure information is accessible in multiple formats while our audio description solution narrates essential visual content for individuals who are blind or with low vision.

We work with large enterprises and public sector organizations to embed accessibility directly into their workflows and platforms. We provide custom API and platform integrations, scalable solutions for large volumes of content, expert guidance and round-the-clock service.