The European Accessibility Act: what businesses and app developers need to know
What is the European accessibility act (EAA)?
The European accessibility act (EAA) is European-wide legislation designed to ensure digital products and services are accessible to everyone, including people with disabilities. Unlike earlier accessibility directives targeting public sector organisations, the EAA specifically addresses commercial organisations. The EAA applies to products and services.
Products covered by the EAA include:
Computers and operating systems: for example, general-purpose devices like laptops, tablets, and smartphones, as well as their operating systems such as iOS, Android, Windows, and macOS.
Self-service terminals: for example, ATMs, ticketing machines, and interactive information kiosks
Digital communication devices: for example, smartphones and Voice over Internet Protocol (VoIP) devices used for electronic communication services.
TV and video devices: for example, connected TVs, set-top boxes, streaming devices.
eBook readers: for example, Kindle, Kobo, and similar devices.
Services covered by the EAA include:
Digital communication services: for example, a video call or messaging app used for real-time communication over the internet.
Streaming and media services: for example, a platform used to stream videos, such as films, series, or live content.
Transport services: for example, a digital platform or app used to book tickets or plan travel for air, rail, bus, or water transport.
Financial services: for example, an online banking portal, mobile banking app.
eCommerce platforms: for example, a webshop or online marketplace that allows users to browse, select, and purchase products or services.
Emergency services: for example, digital platforms supporting the EU emergency number (112).
Timeline for compliance
The EAA becomes enforceable on June 28, 2025. From that date, new digital products and services must comply immediately. Existing services have until June 28, 2028, unless they undergo major updates after June 2025, in which case immediate compliance is required.
Small businesses with fewer than 10 employees (FTE) or annual turnover below €2 million are exempt. Exceptions may apply where compliance represents disproportionate burdens.
Enforcement in the Netherlands and across Europe
The European Accessibility Act is a directive, not a regulation. That means each EU member state must translate it into national law, which might lead to differences in enforcement (penalties, inspections, documentation, etc.).
In the Netherlands, existing regulatory bodies have integrated the EAA into national laws, assigning oversight to specific authorities:
Financial services: Authority for financial markets ("Autoriteit Financiële Markten" - AFM);
eCommerce services: Authority for consumers and markets ("Autoriteit Consument en Markt" - ACM);
Transport services: Human environment and transport inspectorate ("Inspectie Leefomgeving en Transport" - ILT);
Media services: Dutch media authority ("Commissariaat voor de Media");
Electronic communication services: Dutch Authority for Digital Infrastructure ("Rijksdienst voor Digitale Infrastructuur" - RDI).
Companies operating in multiple EU countries should closely monitor specific national enforcement practices in order to comply with EAA in different countries.
Accessibility requirements under the EAA
The accessibility requirements under the European Accessibility Act are defined in Annex I of the directive. These are functional requirements, which means they describe the intended outcomes (what a product or service should enable users to do) rather than prescribing how it must be done technically.
Annex I covers both products and services. For products, the requirements include perceivability (e.g. contrast and alternative text), operability (e.g. keyboard and voice control), understandability (e.g. consistent structure and error feedback), and robustness (e.g. compatibility with assistive technologies like screen readers). There are also additional obligations regarding physical components, such as accessible packaging and instructions.
For services, the requirements address the entire user experience. This includes, for example, accessible digital forms, payment processes, confirmation messages, and navigation. Organisations must also provide accessible customer support (such as real-time communication that works with assistive technologies) and offer documentation in accessible formats, such as tagged PDFs or audio instructions.
The EAA does not specify technical standards within the legal text itself. However, compliance can be demonstrated by following harmonised European standards. These standards, once referenced in the Official Journal of the European Union (OJEU), provide a presumption of conformity - meaning that organisations applying these standards are considered to meet the legal requirements of the EAA.
At present, EN 301 549 is the primary harmonised European standard for accessibility of ICT products and services. It includes technical criteria based on WCAG 2.1 Level AA, and applies to a broad range of technologies including websites, mobile applications, software, hardware, and electronic documents.
EN 301 549 is expected to be updated in 2025 (version 4.1.1) to align more closely with the European Accessibility Act and provide improved support for organisations aiming to comply.
Obligations for service providers
Service providers (and also potentially product providers – depending on interpretation) must:
Comply: Develop and maintain services adhering to EAA accessibility standards.
Document: Keep detailed accessibility documentation (oral and written) available as long as services are provided.
Maintain: Implement processes to maintain compliance, updating practices according to changes in services or standards.
Report: Address non-compliance issues promptly, document corrective actions, and report these to authorities when necessary.
EAA and mobile apps: practical steps for compliance
To meet the requirements of the European Accessibility Act (EAA), mobile apps must not only be accessible - they must also be developed and maintained in a way that supports long-term compliance. The EAA outlines four key obligations for service providers: comply, document, maintain, and report.
Step 1: Assess your maturity level
A good starting point is to evaluate where your organisation currently stands. The App Accessibility Maturity Model (AAMM) helps you determine if you're still in a reactive phase or already embedding accessibility across your development lifecycle.
Step 2: Audit and test your app
Conduct a comprehensive audit of your existing app(s) to identify barriers and areas for improvement. A professional accessibility audit provides a clear roadmap and aligns with the comply obligation of the EAA. Practical tips on how to test the accessibility of your app can help structure this process and ensure you address the right issues.
Step 3: Invest in knowledge
Compliance requires understanding. Equip your team with knowledge through training and documentation. Abra Academy provides structured learning resources tailored for mobile development teams. With the right foundation, your team will be able to implement and maintain accessibility improvements more effectively.
Step 4: Integrate accessibility into your processes
Accessibility should be embedded in your day-to-day development. Add accessibility checks to your backlog, test cycles, and QA workflows. Involve product owners and scrum masters to keep it prioritised. The DICTU case study shows how this approach leads to lasting improvements and builds an inclusive mindset.
Step 5: Monitor accessibility continuously
Accessibility is not a one-off task. Manual testing remains valuable, but automated checks help you maintain quality over time. Abra’s automated accessibility testing offers efficient automated feedback loops tailored for mobile apps, supporting the maintain obligation.
Step 6: Document and report accessibility status
To meet the EAA’s document and report obligations, you need to describe your app’s accessibility features, known limitations, and ongoing improvement plans. Make this information available in accessible formats. Good documentation not only supports legal compliance - it also increases user's trust and helps coordinate internal teams.
Beyond compliance: accessibility as competitive advantage
The EAA presents opportunities beyond compliance. Accessible digital products and services improve customer experience, broaden your market reach, and demonstrate corporate responsibility. Companies proactively embracing accessibility standards gain a competitive advantage in today's increasingly inclusive digital market.