# Accessibility — European Accessibility Act
Status as at 2026-08-05.
**Directive (EU) 2019/882** (European Accessibility Act). Transposition was due 28.06.2022; **Art 31(2): member states shall apply the measures from 28.06.2025**. It has therefore been live for over a year.
A Directive. Every requirement reaches a business through national law: the enforcement authority, the penalties, the complaint route and parts of the microenterprise regime are national. Do not cite Art 4 EAA at a customer.
## The single most common template error
There are **two** EU accessibility regimes and they impose **different documents**:
| | Directive (EU) 2016/2102 | Directive (EU) 2019/882 (EAA) |
|---|---|---|
| Who | **public sector bodies** | private economic operators, including e-commerce |
| Document | a published **accessibility statement** using the Commission's **model template**, with (a) an explanation of non-accessible content and accessible alternatives, (b) a **feedback mechanism**, (c) a link to the **enforcement procedure** under Art 9 (Art 7(1), (2)) | **no accessibility statement, no model template**. Annex V requires the information assessing how the service meets the Art 4 requirements to be included **in the general terms and conditions or an equivalent document** |
| Standard | EN 301 549 harmonised under this directive, giving a presumption of conformity | **no harmonised standard cited in the OJ** — see below |
A private webshop that publishes a public-sector-style "accessibility statement" with a feedback link and a link to a supervisory enforcement procedure has produced the wrong document under the wrong directive. What it owes is the **Annex V** content in its terms.
**EAA Art 13(2)**: make that information publicly available **in written and oral format**, itself accessible, and keep it for as long as the service is in operation. **Art 13(4)**: on discovering non-conformity, take corrective measures and **immediately inform the competent national authorities of every member state where the service is provided.**
Annex V point 1 content: (a) a general description of the service in accessible formats; (b) the descriptions and explanations necessary to understand how the service operates; (c) a description of how the relevant Annex I requirements are met.
## Scope — Art 2
**Products (Art 2(1))**: (a) consumer general-purpose computer hardware systems and their operating systems; (b) self-service terminals — payment terminals, and ATMs, ticketing machines, check-in machines and interactive information terminals; (c) consumer terminal equipment with interactive computing capability used for electronic communications services; (d) the same for accessing audiovisual media services; (e) **e-readers**.
**Services (Art 2(2))**: (a) electronic communications services, excluding machine-to-machine transmission; (b) services providing access to audiovisual media services; (c) listed elements of air, bus, rail and waterborne passenger transport — websites, mobile apps, electronic tickets and ticketing, travel information including real-time information, and interactive self-service terminals in the Union, with urban, suburban and regional transport covered only for terminals; (d) **consumer banking services**; (e) **e-books and dedicated software**; (f) **e-commerce services**.
**Art 3(30)** defines e-commerce services as "services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract". That definition is what catches an ordinary webshop. A brochure site with no contracting path is not an e-commerce service; a site with a checkout or a booking flow is.
**Art 2(4)** carve-outs for website and app content: pre-recorded time-based media published before 28.06.2025; office file formats published before that date; online maps and mapping services where essential information is provided in an accessible digital manner for navigational maps; **third-party content not funded, developed by, or under the control of the economic operator**; and archived content not updated or edited after 28.06.2025.
## Microenterprise exemption — services only
**Art 4(5)**, verbatim: "Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements."
Art 4(3) is the service-requirements limb, i.e. Annex I Sections III and IV. So a microenterprise **service provider** — including a microenterprise webshop — is exempt.
**There is no product exemption.** A microenterprise placing an in-scope product on the market gets only **Art 14(4)**: relief from *documenting* the disproportionate-burden assessment, while still having to supply the underlying facts to the authority on request.
**Art 3(23) defines microenterprise autonomously**: "an enterprise which employs fewer than 10 persons and which has an annual turnover **not exceeding EUR 2 million or** an annual balance sheet total not exceeding EUR 2 million." It does **not** cross-refer to Recommendation 2003/361/EC, unlike the DSA and P2B, and it uses "or" where the Recommendation uses "and/or". Do not import the Recommendation's consolidation rules into the EAA test without checking the national transposition, which may have done so.
Art 4(6): member states must provide guidelines and tools to microenterprises. National layer.
## Requirements and conformity
Art 4(1)–(3) with **Annex I**: Section I applies to all products; Section II to all products except self-service terminals; Section III to services other than urban, suburban and regional transport; Section IV to all services, with sector-specific rules for e-commerce, banking, e-books and transport.
**Art 15(1) presumption of conformity**: products and services conforming to harmonised standards **whose references have been published in the Official Journal** are presumed to conform, to the extent those standards cover the requirements. Art 15(3)–(4): the Commission may adopt technical specifications by implementing act where no harmonised standard is cited.
**As at 05.08.2026 there is no harmonised standard cited in the Official Journal under Directive (EU) 2019/882.** The Commission's harmonised-standards index carries no EAA entry.
**EN 301 549** is harmonised only under the public-sector Directive (EU) 2016/2102, through Commission Implementing Decision (EU) 2018/2048 as amended by **Commission Implementing Decision (EU) 2021/1339**, which inserted **EN 301 549 V3.2.1 (2021-03)**. V3.2.1 maps to **WCAG 2.1 level AA**. **V4.1.0**, which aligns with WCAG 2.2, existed as an enquiry version (12.11.2025) and a vote and approval version (24.06.2026) but is **not published and not cited**.
Practical statement: build an EAA-scope e-commerce site to EN 301 549 V3.2.1 / WCAG 2.1 AA, and to WCAG 2.2 AA where feasible. That is best practice and the evidence a national authority will look for — but it confers **no Art 15 presumption of conformity**, because the standard is not cited in the OJ for the EAA. Say so rather than promising a presumption.
[[UNVERIFIED: whether standardisation request M/587 has produced a draft the Commission intends to cite for the EAA, and any expected citation date — check the Commission standardisation-requests register or the CEN/CENELEC work programme]]
## Transitional provisions — Art 32
- **Art 32(1)**: a transitional period ending **28.06.2030** during which service providers may continue to use products lawfully used to provide services before 28.06.2025. Service contracts agreed before 28.06.2025 may continue unaltered until they expire, but **no longer than five years** from that date.
- **Art 32(2)**: self-service terminals lawfully in use before 28.06.2025 may continue to be used **until the end of their economically useful life, but no longer than 20 years after their entry into use**. Not 2030 — that is Art 32(1).
Art 31(3): the Art 4(8) emergency-communications obligation could be deferred to 28.06.2027.
## Template — Annex V information block
```html
Accessibility of this service
This section forms part of our general terms and conditions and sets out how
[[SERVICE]] meets the accessibility requirements of
[[NATIONAL TRANSPOSITION OF DIRECTIVE (EU) 2019/882]].
Description of the service
[[GENERAL DESCRIPTION IN ACCESSIBLE FORMAT]]
How the service operates
[[EXPLANATIONS NEEDED TO UNDERSTAND OPERATION — navigation, assistive
technology support, alternative routes to complete a purchase]]
How the requirements are met
[[PER REQUIREMENT: measure taken. Reference EN 301 549 V3.2.1 / WCAG 2.1 AA
where used, without claiming a presumption of conformity.]]
[[Where a disproportionate burden is claimed: the assessment under Art 14 and
Annex VI, the elements assessed, and the period for which it is claimed.]]
Accessibility feedback: [[CONTACT]] — we respond within [[PERIOD]].
This information is also available on request in oral form at [[CHANNEL]].
```
## Checkpoints
- [ ] Scope decided against Art 2(2) and the Art 3(30) definition of e-commerce services — is there a contracting path?
- [ ] Microenterprise status assessed against the **EAA's own Art 3(23) definition**, not the Recommendation, and documented
- [ ] If products are placed on the market, the microenterprise exemption is **not** relied on (services only)
- [ ] Annex V information published **in the terms and conditions or an equivalent document**, not as a public-sector-style accessibility statement (Art 13(2))
- [ ] That information available in **written and oral** format and itself accessible (Art 13(2))
- [ ] No feedback-and-enforcement-procedure statement copied from Directive (EU) 2016/2102 unless the body is actually a public sector body
- [ ] No claim of a presumption of conformity from EN 301 549 under the EAA — no standard is cited in the OJ
- [ ] Conformance target stated concretely: EN 301 549 V3.2.1 / WCAG 2.1 AA, plus WCAG 2.2 AA where achieved
- [ ] Keyboard-only walkthrough of registration, search, cart and checkout completed
- [ ] Screen reader walkthrough of the same flows completed
- [ ] Contrast measured, focus visible, form labels programmatically associated, errors described in text
- [ ] Art 2(4) carve-outs applied only where they genuinely fit — third-party content must be neither funded, developed by, nor under the control of the operator
- [ ] Any disproportionate-burden claim assessed under Art 14 and Annex VI and documented; microenterprise product relief under Art 14(4) understood as documentation relief only
- [ ] Procedure in place to notify the competent national authorities on discovering non-conformity (Art 13(4))
- [ ] Art 32 transitional reliance, if any, dated and justified
- [ ] All `[[…]]` placeholders resolved or reported as open