European Accessibility Act for Developers: Who's in Scope and What to Do

Suman SharmaSuman Sharma

The European Accessibility Act (EAA), Directive (EU) 2019/882, has applied since 28 June 2025. If your product serves consumers in the EU, there's a good chance some of it is now in scope. Here's the developer's version.

What's in scope (digital-relevant)

  • E-commerce services: online shops and the checkout flow
  • Consumer banking services: including apps and websites
  • E-books and dedicated reading software
  • Electronic communications services
  • Services related to passenger transport: websites, apps, e-ticketing
  • Access to audiovisual media services
  • Plus hardware like computers, smartphones, ATMs, ticket machines

B2B-only software is generally not the focus. Consumer-facing services are.

The microenterprise exemption

Microenterprises providing services (fewer than 10 staff and ≤ €2 million turnover or balance sheet) are exempt from the service requirements. Many indie products qualify, but don't treat that as a reason to ignore accessibility.

The technical standard

The EAA itself sets functional requirements. In practice, teams use the harmonised standard EN 301 549, which incorporates WCAG success criteria for web content. Aim for WCAG 2.1 AA as the baseline, and WCAG 2.2 AA to be future-proof. My WCAG 2.2 checklist for React covers the implementation side.

What a dev team should do

  1. Determine scope: which products and flows serve EU consumers in covered sectors?
  2. Audit key journeys: sign-up, search, product pages, checkout, account.
  3. Fix the high-impact issues first: forms, focus, contrast, keyboard access.
  4. Publish an accessibility statement describing compliance and how users can report issues.
  5. Build it into the process: lint rules, automated axe checks in CI, manual keyboard tests in QA.
  6. Train designers and devs. Most issues start in design.

How it fits with other EU rules

The EAA joins a growing list of EU rules affecting software teams: the AI Act, sustainability rules like CSRD and EUDR, and GDPR. Accessibility is the one that touches every component you ship.

Frequently asked questions

When did the European Accessibility Act start applying?

The EAA (Directive (EU) 2019/882) has applied since 28 June 2025, through national laws in each EU member state. Some transitional periods apply to existing products and contracts.

Does the EAA apply to non-EU companies?

It applies to products and services placed on the EU market, so non-EU companies selling covered products or services to EU consumers can be in scope.

Is my small business exempt?

Microenterprises (fewer than 10 employees and annual turnover or balance sheet not exceeding €2 million) that provide services are exempt from the service requirements. Check your national implementation.

Contact

Get in Touch

Want to call me? book a call and I'll respond in the available time slot. I will ignore all soliciting.