European Accessibility Act (EAA)

Purpose: The purpose of the EU Accessibility Directive is to harmonize the requirements for accessibility and universal design of certain products, and to give people with disabilities equal access to these products and services in the EU. This harmonization will reduce obstacles to the free movement of accessible products and services in the EU and improve framework conditions for businesses, while it also ensures that stakeholders are in line with their obligations under the UN Convention on the Rights of Persons with Disabilities, related to products and services.

Scope: The directive applies to manufacturers, importers, distributors, or service providers of a range of products and services offered within the EU. The products covered by the directive include, among others:

• General-purpose computer hardware and operating systems
• Self-service terminals, e.g. ATMs
• Smart devices

The obligations under the directive apply only to products placed on the market after 28 June 2025. There is a transitional period until 28 June 2030, during which suppliers may continue to offer products that were lawfully placed on the market before that date.

The directive also applies to the following services offered to consumers after 28 June 2025:

• Electronic communication services
• Transport services, such aselectronic ticketing services
• Banking services
• E-commerce

Microenterprises (fewer than ten employees and balance/turnover under EUR 2 million) are exempt from the requirements of the directive.

Core obligations: The directive sets forth several requirements for the aforementioned actors. The obligations include:

• Preparing declarations of conformity for products
• CE marking products that meet the requirements
• Ensuring that the product is in an accessible format by designing the user interface and overall design in a way that allows people with disabilities to access, operate, understand, and control the product
• Ensuring that the product’s packaging provides information on opening, closing, use, and the product’s accessibility features
• Providing information about the functionality of the service in an accessible manner
• Ensuring that websites and apps are accessible

If the obligations would result in a substantial modification of the characteristics of the product or service, or impose a disproportionate burden on the business, exemptions from the directive may apply.