| name | eaa-compliance |
| description | Use when auditing digital products or services for European Accessibility Act (EAA) compliance, checking EN 301 549 conformance, or advising on EU Web Accessibility Directive obligations. |
EAA Compliance
Overview
Guides compliance with the European Accessibility Act (EU Directive 2019/882) and the underlying technical standard EN 301 549. Covers scope, deadlines, exemptions, and enforcement across EU member states.
Instructions
When conducting an EAA/EN 301 549 compliance review:
-
Determine which law applies:
- Web Accessibility Directive (WAD) — public sector websites and mobile apps (already in force since 2020/2021)
- European Accessibility Act (EAA) — private sector products and services (enforced from 28 June 2025)
-
Identify if the product/service is in scope (see Products and Services section)
-
Evaluate against EN 301 549 v3.2.1, which incorporates WCAG 2.1 AA for web content (Clause 9) and extends to:
- Non-web documents (Clause 10)
- Non-web software / mobile apps (Clause 11)
- Hardware and self-service terminals (Clause 12-13)
-
Check exemptions — microenterprises, disproportionate burden, fundamental alteration
-
Provide remediation guidance with reference to specific EN 301 549 clauses
-
Recommend accessibility statement — required under both WAD and EAA
Products and Services in Scope (EAA)
Products
- Computers and operating systems
- Smartphones and tablets
- TV equipment and related services
- E-readers
- Self-service terminals (ATMs, ticket machines, check-in kiosks, payment terminals)
- Consumer telecommunication equipment
Services
- E-commerce websites and mobile apps
- Banking services (online and ATMs)
- E-books and dedicated software
- Audiovisual media services
- Transport services (websites, apps, ticketing, real-time travel info)
- Telephony and messaging services
EN 301 549 Structure
| Clause | Scope | Key Requirements |
|---|
| 5 | Generic requirements | Closed functionality, biometrics, preservation of accessibility |
| 6 | ICT with two-way voice communication | Real-time text (RTT), caller ID, video communication |
| 7 | ICT with video capabilities | Captions, audio description, player controls |
| 8 | Hardware | Physical dimensions, connections, keypads, biometrics |
| 9 | Web content | WCAG 2.1 Level AA (all success criteria) |
| 10 | Non-web documents | WCAG 2.1 AA applied to documents (PDFs, Word, spreadsheets) |
| 11 | Non-web software | WCAG 2.1 AA adapted for native apps and desktop software |
| 12 | Documentation and support | Accessible docs, help desk, support services |
| 13 | ICT providing relay or emergency services | Relay services, 112 emergency access |
Who Must Comply
| Law | Sector | Scope |
|---|
| Web Accessibility Directive (2016/2102) | Public sector | All EU public sector websites and mobile apps |
| European Accessibility Act (2019/882) | Private + public | Manufacturers, service providers, importers, distributors offering in-scope products/services in EU |
Territorial reach: Any organization offering in-scope services to EU consumers, regardless of where the organization is headquartered.
Deadlines
| Obligation | Date |
|---|
| WAD — Public sector websites | 23 September 2020 |
| WAD — Public sector mobile apps | 23 June 2021 |
| EAA — All in-scope products and services | 28 June 2025 |
| EAA — Products placed on market before June 2025 | Grace period until 28 June 2030 |
| EN 301 549 v4.1.1 (planned, includes WCAG 2.2) | Expected 2026 |
Exemptions
- Microenterprises — fewer than 10 employees AND annual turnover ≤ €2 million (EAA only)
- Disproportionate burden — documented assessment required; does not exempt from all requirements
- Fundamental alteration — compliance would change the nature of the product/service
- Third-party content — not funded, developed, or controlled by the economic operator
- Archived content — not updated after 28 June 2025
Penalties
Enforcement is per member state. Examples:
| Country | Penalty |
|---|
| General range | Up to €500,000 in fines |
| Some states | Product removal from market |
| At least one state | Criminal penalties possible |
Penalties must be "effective, proportionate, and dissuasive."
Presumption of Conformity
Products/services conforming to harmonised European standards (notably EN 301 549) benefit from a "presumption of conformity" — they are presumed to meet EAA requirements without further proof.
Accessibility Statement
Both WAD and EAA require publishing an accessibility statement that includes:
- Scope of content covered
- Standard used (EN 301 549)
- Level of conformance achieved
- Known limitations with rationale
- Contact mechanism for reporting barriers
- Link to enforcement procedure
Examples
Example: E-commerce Audit
Input: "Our online store sells to EU customers, what do we need?"
Response approach:
- Confirm the store is in scope (e-commerce service)
- Check for microenterprise exemption
- Audit website against EN 301 549 Clause 9 (= WCAG 2.1 AA)
- Audit mobile app against Clause 11 if applicable
- Check self-service terminals (kiosks) against Clause 8 if applicable
- Verify accessibility statement is published
Example: SaaS Product
Input: "We're a US company with EU customers, does EAA apply?"
Response approach:
- Yes — EAA applies to any organization offering in-scope services to EU consumers
- Determine which product/service categories apply
- Audit against EN 301 549 (not just WCAG)
- Note that EN 301 549 covers software (Clause 11), not just web content
Guidelines
- Always determine WAD vs EAA applicability first — different obligations and history
- Reference EN 301 549 clause numbers, not just WCAG criteria, when reporting issues
- EN 301 549 is broader than WCAG — covers hardware, RTT, biometrics, documentation
- Note that EN 301 549 v4.1.1 (expected 2026) will incorporate WCAG 2.2
- Microenterprise exemption applies only to EAA, not to WAD
- Never recommend overlay widgets as a compliance solution
References
