The European Accessibility Act (“EAA”) takes effect across the European Union on June 28, 2025, for new products and services in the EU market. Products and services already on the market have a longer transitional period until June 28, 2030, but compliance planning should begin now. If your business sells or distributes products or services in the EU, the EAA may apply to you, even if you are based outside the EU.
The Act establishes accessibility requirements (such as font size and spacing on product instructions) for a wide range of products and services with the goal of improving access for people with disabilities. It requires EU member states to implement the EAA into their national legislation. As a result, specific national regulations and enforcement may vary by country. Businesses need to take a careful approach to compliance, as those who do not comply may face severe penalties.
Scope of the Act
The EAA applies to numerous product and service categories that must be accessible to people with disabilities. While many of the product categories focus on digital devices such as computers and self-service terminals (such as check-out machines and ATMs), the Act also covers service categories relevant to consumer packaged goods, including websites and mobile apps conducting online sales. Brands that sell direct to consumers online may be subject to the EAA.
The Act requires these products and services to be designed and delivered in a way that ensures accessibility. Requirements are specific to the product or service and may include accessible fonts, readable formats, text alternatives for images, compatibility with assistive devices, etc.
Entities Subject to Compliance
The EAA applies to economic operators involved in the supply chain, including manufacturers, importers, distributors and service providers offering covered products or services in the EU.
Enforcement
Each EU member state is responsible for establishing penalties for non-compliance, which are to be “effective, proportionate and dissuasive.” As the penalties will vary from country to country, businesses should be wary of the potentially severe consequences that may be associated with non-compliance (for example, fines in Spain may range between €30,000 to €600,000 (approximately $34,000 to $685,000) per violation and a ban from market participation for repeat infractions).
Next Steps
Affected businesses should conduct product and service audits to assess accessibility gaps and quickly address any deficiencies that may be discovered.
