European Accessibility Act: what it asks of online shops and of the devices you sell, applying since 28 June 2025

The European Accessibility Act is Directive (EU) 2019/882Directive (EU) 2019/882, European Accessibility ActThe whole regulationClick opens the law on the EU Publications Office.. It sets one set of accessibility requirements for certain products and services across the EU, so that a person with a disability can use them (Art. 1Directive (EU) 2019/882, European Accessibility ActArticle 1Click opens the article on EUR-Lex.). Each EU country wrote it into its own law. Those national laws are what an authority enforces against you.

What an e-commerce service must meet

Two lists apply to a shop. Art. 4(3)Directive (EU) 2019/882, European Accessibility ActArticle 4, paragraph 3Click opens the article on EUR-Lex. puts every service, other than urban, suburban and regional transport, under Section III of Annex I. It puts every service under Section IV, whose point (g) names e-commerce. The two lists together:

The four words, perceivable, operable, understandable and robust, are the four principles of the accessibility of websites and mobile applications that Directive (EU) 2016/2102 uses and that the Act says are relevant to it (recital 47). Two obligations sit on top of the list:

• A statement in your terms. The service provider describes how the service meets the requirements, in the general terms and conditions or an equivalent document. The description covers the applicable requirements and, as far as relevant, the design and operation of the service. It is in addition to the consumer information duties of Directive 2011/83/EUDirective 2011/83/EU, Consumer Rights Directive (consolidated text of 27 September 2026)The whole regulationClick opens the law on the EU Publications Office.. It gives a general description of the service in accessible formats, the explanations needed to understand how it works, and a description of how Annex I is met. It is public, in written and oral format, including in a form accessible to persons with disabilities, and stays available for as long as the service runs (Art. 13(2)Directive (EU) 2019/882, European Accessibility ActArticle 13, paragraph 2Click opens the article on EUR-Lex., Annex V, point 1).
• Keeping it accessible. The provider has procedures so the service stays in conformity, takes account of changes to the service, the requirements and the standards, takes corrective measures on a non-conformity, and tells the authorities of each EU country where the service is provided, with details, when the service does not comply (Art. 13(3)Directive (EU) 2019/882, European Accessibility ActArticle 13, paragraph 3Click opens the article on EUR-Lex., Art. 13(4)Directive (EU) 2019/882, European Accessibility ActArticle 13, paragraph 4Click opens the article on EUR-Lex.). On a reasoned request it supplies the information the authority needs and cooperates (Art. 13(5)Directive (EU) 2019/882, European Accessibility ActArticle 13, paragraph 5Click opens the article on EUR-Lex.).

Some content is outside the Act: pre-recorded time-based media and office file formats published before 28 June 2025, online maps whose essential navigation information is available in an accessible digital form, content from third parties that you neither fund, develop nor control, and archives that are not updated or edited after 28 June 2025 (Art. 2(4)Directive (EU) 2019/882, European Accessibility ActArticle 2, paragraph 4Click opens the article on EUR-Lex.).

Who is exempt

Three things take a business or a part of its work out of the duty.

• A microenterprise providing services. It is exempt from the requirements that apply to services and from any obligation tied to complying with them (Art. 4(5)Directive (EU) 2019/882, European Accessibility ActArticle 4, paragraph 5Click opens the article on EUR-Lex.). A microenterprise is an enterprise with fewer than 10 persons and an annual turnover not above EUR 2 million or an annual balance sheet total not above EUR 2 million (Art. 3(23)Directive (EU) 2019/882, European Accessibility ActArticle 3, point 23Click opens the article on EUR-Lex.). The text says “or”: meeting either money limit with fewer than 10 persons is enough. The exemption is for services. A microenterprise dealing with products is not exempt; its duties are lighter. It need not document the fundamental-alteration or disproportionate-burden assessment, and it need not send the information about it to the authorities. If a market surveillance authority asks, and the microenterprise relies on the limit, it must give the authority the facts relevant to the assessment (Art. 14(4)Directive (EU) 2019/882, European Accessibility ActArticle 14, paragraph 4Click opens the article on EUR-Lex., Art. 14(8)Directive (EU) 2019/882, European Accessibility ActArticle 14, paragraph 8Click opens the article on EUR-Lex., recital 71). The Act asks each EU country to give microenterprises guidelines and tools (Art. 4(6)Directive (EU) 2019/882, European Accessibility ActArticle 4, paragraph 6Click opens the article on EUR-Lex.).
• A change that would fundamentally alter the product or service, or impose a disproportionate burden. The requirements apply only to the extent compliance needs no significant change that fundamentally alters the basic nature of the product or service and imposes no disproportionate burden on the operator (Art. 14(1)Directive (EU) 2019/882, European Accessibility ActArticle 14, paragraph 1Click opens the article on EUR-Lex.). The operator assesses it using the criteria of Annex VI, among them the ratio of the net costs of compliance to the operator’s overall costs, and the ratio of those net costs to its net turnover. It documents the assessment, keeps the results for five years from the last time the product was made available or the service was provided, gives a copy to an authority on request, and sends the information to the authorities of the EU country where the product is placed on the market or the service is provided (Art. 14(2)Directive (EU) 2019/882, European Accessibility ActArticle 14, paragraph 2Click opens the article on EUR-Lex., Art. 14(3)Directive (EU) 2019/882, European Accessibility ActArticle 14, paragraph 3Click opens the article on EUR-Lex., Art. 14(8)Directive (EU) 2019/882, European Accessibility ActArticle 14, paragraph 8Click opens the article on EUR-Lex.). A service provider that relies on the disproportionate-burden limit renews the assessment for each category of service when the service changes, when an authority asks, and at least every five years (Art. 14(5)Directive (EU) 2019/882, European Accessibility ActArticle 14, paragraph 5Click opens the article on EUR-Lex.). An operator that received public or private funding to improve accessibility cannot rely on the disproportionate-burden limb (Art. 14(6)Directive (EU) 2019/882, European Accessibility ActArticle 14, paragraph 6Click opens the article on EUR-Lex.). Authorities check that the assessment was done and review its results (Art. 19(2)Directive (EU) 2019/882, European Accessibility ActArticle 19, paragraph 2Click opens the article on EUR-Lex., Art. 23(1)Directive (EU) 2019/882, European Accessibility ActArticle 23, paragraph 1Click opens the article on EUR-Lex.).
• A sale to a business, and content outside the Act. The Act covers services provided to consumers (Art. 2(2)Directive (EU) 2019/882, European Accessibility ActArticle 2, paragraph 2Click opens the article on EUR-Lex.), and the content listed above is outside it (Art. 2(4)Directive (EU) 2019/882, European Accessibility ActArticle 2, paragraph 4Click opens the article on EUR-Lex.).

Which dates apply

The Act does not say how a product is counted as “placed on the market” beyond “the first making available of a product on the Union market” (Art. 3(16)Directive (EU) 2019/882, European Accessibility ActArticle 3, point 16Click opens the article on EUR-Lex.). Stock that you first made available in the EU before 28 June 2025 is outside the product rules by the text of Art. 2(1)Directive (EU) 2019/882, European Accessibility ActArticle 2, paragraph 1Click opens the article on EUR-Lex.. Whether units of one model are counted one by one is not said in the Directive. We found no official guidance on it (Commission EAA page, 5 October 2026).

What manufacturers, importers and distributors owe

These duties apply to the products in the first table, not to a general online shop. They follow the usual CE marking pattern: documentation, a declaration, the mark. The conformity assessment is internal production control, with no notified body (Art. 7(2)Directive (EU) 2019/882, European Accessibility ActArticle 7, paragraph 2Click opens the article on EUR-Lex., Annex IV).

The declaration states that the applicable accessibility requirements were met, and names any requirement covered by the fundamental-alteration or disproportionate-burden limit. Where a product falls under several EU laws that need a declaration, one declaration covers them all (Art. 16(1)Directive (EU) 2019/882, European Accessibility ActArticle 16, paragraph 1Click opens the article on EUR-Lex., Art. 16(3)Directive (EU) 2019/882, European Accessibility ActArticle 16, paragraph 3Click opens the article on EUR-Lex.). The CE marking goes on the product or its data plate, or on the packaging and the documents where that is not possible or warranted, before the product is placed on the market (Art. 18Directive (EU) 2019/882, European Accessibility ActArticle 18Click opens the article on EUR-Lex.). CE marking explains how the mark is drawn, and the declaration of conformity what the declaration holds. A phone is also radio equipment; the Radio Equipment Directive adds its own requirements.

The accessibility requirements for products themselves, in Annex I, Sections I and II, cover the information on the product, the instructions, the user interface and functionality, support services, and accessible packaging (for products other than self-service terminals). E-readers must provide text-to-speech technology (Annex I, Section I, point 2(o)(ii)).

How a shop outside the EU is reached

For a service, the text turns on the market, not on where the provider sits. A “service provider” is “any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union”, and the “economic operator” includes the service provider (Art. 3(4)Directive (EU) 2019/882, European Accessibility ActArticle 3, point 4Click opens the article on EUR-Lex., Art. 3(21)Directive (EU) 2019/882, European Accessibility ActArticle 3, point 21Click opens the article on EUR-Lex.). The text has no place-of-establishment test. It does not define when an offer is made to consumers in the Union. In our reading, a shop that takes orders from consumers in the EU is making such an offer. Germany’s law has a matching definition (BFSG § 2, No. 4).

For products, a brand owner outside the EU that markets a product under its own name is the manufacturer (Art. 3(17)Directive (EU) 2019/882, European Accessibility ActArticle 3, point 17Click opens the article on EUR-Lex.). An importer must be established in the EU (Art. 3(19)Directive (EU) 2019/882, European Accessibility ActArticle 3, point 19Click opens the article on EUR-Lex.). The Directive has no rule of its own for a manufacturer that sells online directly to EU consumers with no importer in between, but the gap is closed in practice. Under Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex. and Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office., a product subject to Directive 2014/30/EUDirective 2014/30/EU, Electromagnetic Compatibility Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office. (electromagnetic compatibility), 2014/35/EU (low voltage), 2014/53/EU (radio equipment) or 2011/65/EU (hazardous substances) may be placed on the market only if an economic operator is based in the EU. In our reading, a covered device almost always falls under at least one of them. The distance-sales rule of Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click opens the article on EUR-Lex. does not itself reach this Directive: that Regulation applies the rule to the laws in its Annex I, and Directive (EU) 2019/882Directive (EU) 2019/882, European Accessibility ActThe whole regulationClick opens the law on the EU Publications Office. is not on the list in the consolidated text of 12 August 2026.

Two points stay open:

• No representative for a service provider. The Act lets a manufacturer appoint an authorised representative (Art. 8Directive (EU) 2019/882, European Accessibility ActArticle 8Click opens the article on EUR-Lex.). It names none for a service provider, and says nothing on how a national authority reaches a provider outside the EU. We found no official guidance on it (Commission EAA page, 5 October 2026).
• A seller on a marketplace. The Act defines the e-commerce service by the website or app through which a consumer concludes the contract. It does not say how its duties divide between a marketplace and a seller whose offers sit on the marketplace’s pages. We found no official guidance on it (Commission EAA page, 5 October 2026). The pages and apps you run yourself are covered. For what you supply to a listing, Annex I, Section III, point (b)(vi), asks for “an alternative presentation” of non-textual content in the service. Which of the two carries that duty is the open point.

EN 301 549 and the presumption of conformity

A product or service that meets a harmonised standard whose reference is published in the Official Journal is presumed to meet the requirements that standard covers (Art. 15(1)Directive (EU) 2019/882, European Accessibility ActArticle 15, paragraph 1Click opens the article on EUR-Lex.). The Commission was to ask the European standardisation bodies for such standards for the product requirements, with a first draft request due by 28 June 2021 (Art. 15(2)Directive (EU) 2019/882, European Accessibility ActArticle 15, paragraph 2Click opens the article on EUR-Lex.). Under the conditions of Art. 15(3)Directive (EU) 2019/882, European Accessibility ActArticle 15, paragraph 3Click opens the article on EUR-Lex., the Commission may set technical specifications by implementing act where no reference is published.

On 5 October 2026 the Commission’s index of harmonised standards had one entry under Accessibility: websites and mobile applications of public sector bodies, under Directive (EU) 2016/2102. It lists none for Directive (EU) 2019/882Directive (EU) 2019/882, European Accessibility ActThe whole regulationClick opens the law on the EU Publications Office.. That entry is Implementing Decision (EU) 2018/2048, amended by Implementing Decision (EU) 2021/1339, which publishes EN 301 549 V3.2.1 (2021-03). That Directive covers public sector bodies, and the Decision says the standard’s mappings “provide the presumption of conformity with Directive (EU) 2016/2102” (recital 3). It gives no presumption under this Directive. See harmonised standards for how the presumption works in general.

The standard is still a working yardstick, and this is our reading. Its scope covers web and non-web technologies, software and hardware, and services, and its web clause 9 sets out that conformance with WCAG 2.1 Level AA is equivalent to meeting all of clauses 9.1 to 9.4 and the conformance requirements of clause 9.6 (EN 301 549 V3.2.1, clauses 1 and 9.0). The Directive itself names the same four principles of perceivability, operability, understandability and robustness (Annex I, Section III, point (c); recital 47). Germany’s regulation asks, in § 3, for the state of the art, and has a federal centre publish the standards to watch (BFSGV § 3(1), § 3(2)).

National laws and their penalties

The Directive leaves the penalties to each EU country. They must be effective, proportionate and dissuasive, and weigh the extent and seriousness of the non-compliance, the number of units or services concerned and the number of persons affected (Art. 30(1)Directive (EU) 2019/882, European Accessibility ActArticle 30, paragraph 1Click opens the article on EUR-Lex., Art. 30(2)Directive (EU) 2019/882, European Accessibility ActArticle 30, paragraph 2Click opens the article on EUR-Lex., Art. 30(4)Directive (EU) 2019/882, European Accessibility ActArticle 30, paragraph 4Click opens the article on EUR-Lex.). The table shows three EU countries.

Germany. A service that breaks the rules is not left to a fine alone. The authority first sets a deadline for corrective measures. It then repeats the order under the threat of a prohibition. It may then order the offer or provision of the service to stop (BFSG § 29). A consumer who cannot use a product or service can apply to the federal conciliation body (BFSG § 34(1)). The German transition (BFSG § 38(1)) shelters two things: products a service provider already used before 28 June 2025 to provide this or similar services, which it may keep using until 27 June 2030, and service contracts concluded before that date, which may continue unaltered until they expire but no longer than 27 June 2030. It says nothing of a website, and in our reading a website is not a product.

How German authorities check a shop is written into the law, and they may check without a specific reason (BFSG § 28(2)). The method follows the four principles and tests every step of a process in the order an ordinary user takes it, forms, controls, dialogs, confirmations and error messages included. The sample of pages holds the home page, login, site map, contact, help and legal pages, at least one page for each type of service and for the search, the page with the accessibility information, example pages that look clearly different, at least one downloadable document per type of service, other pages the authority finds relevant, and at least 10 percent more picked at random (BFSG Annex 1, Nos. 1 and 2).

Ireland. A director, manager or other officer of a body corporate is liable too, where the offence was committed with their consent, connivance or approval or is due to their wilful neglect (Regulation 33). It is a defence to prove due diligence and all reasonable precautions (Regulation 34).

Spain. The specific example in the disability law is a failure to comply with the accessibility rules for products and services available to the public that obstructs or limits their regular use by persons with disabilities. It is a serious infraction (Real Decreto Legislativo 1/2013, article 95(3)(e)).

What happens if you do nothing

An authority that has sufficient reason to believe a product does not comply evaluates it against the whole Directive. It requires corrective action within a reasonable period, and requires withdrawal only if the operator fails to act. If the operator still does not, the authority prohibits, restricts or withdraws the product (Art. 20(1)Directive (EU) 2019/882, European Accessibility ActArticle 20, paragraph 1Click opens the article on EUR-Lex., Art. 20(4)Directive (EU) 2019/882, European Accessibility ActArticle 20, paragraph 4Click opens the article on EUR-Lex.). Missing CE marking, a missing or wrong declaration, missing technical documentation or missing contact details must be put right, or the product is restricted or withdrawn (Art. 22Directive (EU) 2019/882, European Accessibility ActArticle 22Click opens the article on EUR-Lex.).

For services, each EU country sets up procedures to check the compliance of services, to follow up complaints and to verify that the operator took corrective action (Art. 23(1)Directive (EU) 2019/882, European Accessibility ActArticle 23, paragraph 1Click opens the article on EUR-Lex.). Consumers can act before the courts or the competent administrative bodies, and so can public bodies or associations with a legitimate interest, on behalf of or in support of a complainant (Art. 29(2)Directive (EU) 2019/882, European Accessibility ActArticle 29, paragraph 2Click opens the article on EUR-Lex.). A consumer can ask the authority for what it holds on an operator’s compliance and on the operator’s assessment under Art. 14Directive (EU) 2019/882, European Accessibility ActArticle 14Click opens the article on EUR-Lex., in an accessible format (Art. 19(3)Directive (EU) 2019/882, European Accessibility ActArticle 19, paragraph 3Click opens the article on EUR-Lex., which is written for products; Germany applies the same right to services, BFSG § 28(4)). Then the national penalties above apply.

What the law leaves open

• A standard to build to. The Commission lists no harmonised standard for the Act (the section above). Meanwhile, test against EN 301 549 and WCAG 2.1 Level AA, and keep the report.
• What “provide the information concerning accessibility” means for a reseller. Annex I, Section IV, point (g)(i), asks for that information “when this information is provided by the responsible economic operator”. The text does not require the shop to produce information it does not have. Meanwhile, show what the manufacturer of a covered product publishes, as it publishes it.
• How a seller on a marketplace and the marketplace share the duty. See the section on shops outside the EU.
• How an authority reaches a provider with no EU presence. See the same section.
• Whether units of one model are counted one by one for the “placed on the market” date. See the dates section.

What you can skip

The Act is one rule among the others in EU consumer law. Its information duty sits beside the consumer information requirements of Directive 2011/83/EUDirective 2011/83/EU, Consumer Rights Directive (consolidated text of 27 September 2026)The whole regulationClick opens the law on the EU Publications Office., which Annex V names.