Reed Smith In-depth

Key takeaways

  • The EU Accessibility Act (the EAA) is an EU directive that mandates member states to implement local laws requiring certain consumer-focused products or services meet a minimum accessibility threshold.
  • The EAA acts as a legal floor. Individual member states may choose to impose stronger requirements than required under the EAA. Providers should therefore consult local laws to account for any enhanced accessibility obligations.
  • Two key dates to remember: from 28 June 2025, in-scope products and services released thereafter must comply with local requirements, and from 28 June 2030, all in-scope products and services must be compliant, regardless of when they were released.
  • Providers should therefore assess whether their products or services that may fall within the scope of the EAA meet local accessibility requirements and, where any fall short, update them accordingly.
  • Annex 1 of the EAA provides an illustrative list of accessibility features that providers should consult when determining whether their in-scope products and services are accessible for individuals with diverse disabilities.
  • Penalties for non-compliance will vary from member state to member state. Penalties can range from fines to criminal sentences.
  • Providers may be exempt where their company has fewer than 10 employees and a global turnover not exceeding €2 million, or where compliance would impose an undue burden on the economic actor involved.


If you’ve been living under a rock for the last few years, you might not be aware that the regulation of digital services has undergone widespread transformation globally, with consumers and governments alike becoming increasingly aware of the need to make those services accessible to as many of us as possible.

The situation in Europe is no different, with the introduction of the EU Accessibility Act taking place almost 10 years ago – an EU directive aiming to make certain products and services across the EU more accessible by breaking down (and preventing future) barriers which currently exist due to differing accessibility requirements across the EU.

Although the EAA started its legislative journey back in 2015, its regulatory position was solidified on 27 June 2019, when it entered into force following publication in the Official Journal of the EU without much fanfare. Below, we take a look at who the EAA applies (or will apply) to, what it applies to, and how it applies, as well as the progress made so far.