FAQs: The EU Accessibility Act

The EU Accessibility Act is a European Union law.

It sets common accessibility requirements for certain products and services sold in the EU.

The aim is simple.

People with disabilities must be able to use everyday products and digital services.

The Act also removes differences between national accessibility rules.

This makes it easier for businesses to operate across the EU.

The law applies to both physical products and digital services.

This includes websites, apps, e-commerce and electronic devices.

The Act applies to businesses that place covered products on the EU market.

It also applies to businesses that provide covered services to EU consumers.

This includes:
Manufacturers
Importers
Distributors
Service providers

Location does not matter.

If you sell into the EU, you may be in scope.

Microenterprises are partly exempt.

They are exempt from service requirements only.

They are not exempt from product requirements.

The EU Accessibility Act entered into force in 2019.

The key compliance date is 28 June 2025.

From this date:
New products placed on the market must comply
New services must comply
Substantially modified services must comply

Enforcement is handled by national authorities.

Penalties vary by Member State.

Accessibility means usability for people with disabilities.

This includes visual, hearing, physical and cognitive impairments.

Products and services must be:
Perceivable
Operable
Understandable
Robust

For digital services, this usually means alignment with WCAG standards.

Accessibility must be built in.

It cannot be an afterthought.

The Web Accessibility Directive applies to public bodies only.

It focuses on public sector websites and apps.

The EU Accessibility Act goes further. It applies to private businesses.

It also covers physical products, not just digital content.

In short:
The Directive applies to public bodies
The Accessibility Act applies to the market

The EU Accessibility Act includes transition periods.

Existing products
Products placed on the EU market before 28 June 2025 can continue to be sold.
This is allowed until 28 June 2030.

However:

New versions must comply
Significant changes trigger compliance
Accessibility must not be reduced

Existing services
Services provided before 28 June 2025 may continue unchanged.
This applies until 28 June 2030.

If a service is significantly updated or replaced, it must comply.

Compliance means meeting the accessibility requirements set out in the Act.

For most businesses, this starts at design stage.
Accessibility must be built into products and services from the outset.

For digital services
Websites and mobile applications must be accessible.

This usually means:
Content can be read by screen readers
Pages can be navigated using a keyboard
Text has sufficient contrast
Forms, buttons and controls are usable

In practice, this is typically demonstrated by alignment with WCAG standards.

For products
Products must be usable by people with disabilities.

This includes:
Clear and understandable instructions
Accessible user interfaces
Compatibility with assistive technologies
Accessible packaging and labelling

Accessibility must be consistent. It must not degrade during normal use.

Documentation and evidence
Compliance must be documented.

This may include:
Technical documentation
Accessibility statements
Instructions for use in accessible formats

Authorities may request this information. It must be available on request.

Ongoing obligations
Compliance is not a one-off exercise.

Products and services must remain accessible:
After updates
After repairs
After software changes

If accessibility is reduced, compliance is lost.

Yes, where an Authorised Representative is required, they should hold the compliance documentation.

For products covered by the EU Accessibility Act, documentation must be available to EU authorities on request. This obligation applies even where the manufacturer is based outside the EU.

An Authorised Representative acts as the EU-based contact point. They liaise with market surveillance authorities. They provide access to documentation when requested.

The documentation typically includes:
Technical documentation
Accessibility-related conformity information
Instructions and information in accessible formats

However, responsibility does not transfer.
The manufacturer remains responsible for compliance. The Authorised Representative holds and supplies documentation, but does not create it or certify it unless contractually agreed.

For services, an Authorised Representative is not usually required.

In these cases, the service provider must hold and supply accessibility information themselves.