The European Accessibility Act is a dense and complicated 46 page document.
It will also completely transform your ability to do business in the European Union. So, to save you the effort, we decided to trawl through it ourselves and pick out the details that everyone else might have missed. Here’s our deep dive into the European Accessibility Act:
The basics
For those unfamiliar, the European Accessibility Act will come into effect on June 28th 2025. It will apply to a wide range of goods and services sold within the EU, and aims to ensure a greater level of accessibility for end users and consumers across Europe. The act will consolidate different accessibility standards across the EU into a unified code, with the specific requirements varying based on the products or services at hand.
European Act, global effects
One surprising element of the EAA is that it applies to all goods and services sold within the EU, not just those produced by EU firms. This means that for foreign businesses to continue to sell to the EU market, they must comply with EU accessibility policy. Even if a company wishes to host an EU website to promote goods sold outside of the EU, that website itself must be EAA compliant. To put it simply, if you want to do business in the EU, you need to consider the full regulations of the EAA.
Read the label
When the EAA applies to a product, it applies to all of that product. This means that instruction manuals, packaging, website help pages, and chatbots must be as accessible as the core product itself. This includes all documentation related to a product, including PDFs and other files available online. In fact, in some industries, the EAA will be stricter on these pieces of documentation than the actual product they are provided alongside. Complex physical products are understandably hard to rebuild, but digital and printed goods have no excuse for not being accessible.
See European Accessibility Act, Annex I, Section II.
The grandfather problem
A common misconception of the EAA is that all goods will be “grandfathered” into the act. This refers to the practice of only applying the EAA to goods entering the market, and leaving older products free of these new regulations.
Under the EAA, only physical goods which undergo no design changes and are not essential to the lives of their consumers will be “grandfathered”. Goods which are deemed essential (typically those associated with banking, transport and government services) will need to be updated immediately, as will all digital goods and services. And any design changes (including rebrands or packaging changes) will mandate the entire product becoming EAA compliant.
See European Accessibility Act, Article 32.
Disproportionate burden
Many firms will be hoping to find ways to slip through EAA regulations. However, the EAA has been designed to be as universally binding as possible. Micro-enterprises (defined as firms with less than 10 employees and less than 2 million euro in turnover) will be excluded, as will any firm for whom EAA compliance represents a “disproportionate burden”. This burden must be proven to require a “fundamental alteration” of the product’s nature in order to allow an exclusion.
In practice, this means that almost all digital products and services will be fully eligible for the act, and must be compliant by June 28th. For the most part, only complex physical products will be able to argue for an exemption.
See European Accessibility Act, Article 14.
How to prepare
There are good reasons to be concerned about the EAA. However, compliance doesn’t need to be a nightmare. By taking a proactive, careful approach, AccessPoint can identify and address any issues within your digital solution. Better yet, this may not require a full redesign, and can improve your overall user experience in the process.
If you want to begin your journey towards EAA compliance, or even just check if the act will apply to you, then get in touch with our team today.