EU Accessibility Act: June 2025 Deadline plus Five Years to Comply

From 28 June 2025 onward, all newly placed products and newly provided services covered by the EU Accessibility Act must conform to the harmonised requirements of EN 301 549. This includes hardware (smartphones, ATMs, ticketing machines), software (desktop apps, mobile apps, cloud services) and services (public-transport booking, audiovisual media).

Key Milestone: 28 June 2025

• Mandatory Compliance Date
  Any new offering must be designed, tested and documented for usability by persons with disabilities (and, by extension, older users and those with temporary impairments).
• CE Marking & Declaration
  Manufacturers and service providers must draw up an EU Declaration of Conformity attesting adherence to EN 301 549—backed by self-assessment or, for higher-risk products, a third-party conformity assessment.

Grace Periods & Legacy Items (Until 28 June 2030)

• Existing Products: Items lawfully placed on the market before 28 June 2025 may continue to be sold and serviced until 28 June 2030.
• Existing Services: Contracts signed before the deadline may run to natural expiry, but no later than five years after 28 June 2025.
• Exemptions: Claims of “fundamental changes” or “disproportionate burden” must be justified to—and approved by—the relevant national authority.

Five-Year Roadmap for Businesses (2025–2030)

1. Gap Analysis & Audits
   Commission an accessibility audit—via a certified consultant (e.g., IAAP CPACC/WAS) or a Notified Body—to benchmark against EN 301 549.
2. Accessibility-By-Design
   Embed both automated and manual testing, and involve users with disabilities from project inception.
3. Training & Governance
   Appoint internal “accessibility champions,” deliver WCAG/EN 301 549 training, and update procurement policies.
4. Accessible Documentation & Support
   Provide manuals, packaging and customer support in alternative formats (Braille, large-print, screen-reader-friendly).
5. Supplier Oversight
   Enforce accessibility clauses in vendor contracts and require proof of third-party compliance.

Authorised Representative Requirements

Non-EU providers of covered hardware or software must appoint an EU-based Authorised Representative (AR) before placing products or services on the Single Market. A formal written mandate must empower the AR to:

• Hold all technical documentation (including EN 301 549 test reports)
• Liaise with market-surveillance authorities
• Manage compliance actions

The AR’s full name and EU address must appear in the EU Declaration of Conformity and on the product’s CE marking or packaging—or, for digital offerings, in the app’s “About” section, download page or accompanying documentation.

Ensuring Ongoing Compliance

To stay compliant, organisations should:

• Maintain Documentation: Update test reports and the technical file regularly.
• Monitor Updates: Track revisions to EN 301 549 and related standards.
• Conduct Periodic Audits: Schedule annual or biennial accessibility reviews.
• Engage Stakeholders: Keep dialogue open with end-users, accessibility experts and regulatory bodies.

By treating mid-2025 as the start of a continuous improvement cycle—backed by robust auditing, clear governance and a designated EU contact—businesses will not only meet their legal obligations but also gain a competitive edge through genuine inclusivity.By treating the period from mid-2025 to mid-2030 as a rolling roadmap—combining compliance audits, design overhaul, staff training and continuous supplier oversight—businesses will not only meet legal obligations but also unlock broader market opportunities and demonstrate genuine inclusivity.