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The European Accessibility Act: Who It Actually Catches

IT Law 3 min read Sviridenko & Partners

In application since June 2025, and filed by most businesses under someone else's problem. It covers e-commerce services, consumer banking and e-books sold to consumers, with a microenterprise exemption that only covers services and transitional periods that run out in 2030.

In force since June 2025, and wider than it looks

Directive (EU) 2019/882, the European Accessibility Act, had to be transposed by 28 June 2022, and Member States have applied those measures since 28 June 2025. It is usually filed under disability policy. In practice it is a compliance regime that catches businesses who do not think of themselves as technology companies at all.

The question is not what you do. It is whether you sell one of the listed things to consumers.

The services covered

For services provided to consumers after 28 June 2025: e-commerce services; consumer banking services; e-books and dedicated software; electronic communications services other than machine-to-machine transmission; services giving access to audiovisual media; and defined elements of air, bus, rail and waterborne passenger transport — websites, mobile applications, electronic ticketing, travel information and interactive self-service terminals in the Union.

The first three catch people. Any business selling to consumers online is providing an e-commerce service, whatever its trade.

And the products

For products placed on the market after 28 June 2025: consumer computers and their operating systems; payment terminals; ATMs, ticketing and check-in machines and interactive information terminals; consumer terminal equipment used for electronic communications or for audiovisual media; and e-readers. The Directive also applies to answering emergency calls to 112.

What is carved out

The exclusions remove a good deal of legacy content, and are worth reading before anyone budgets a remediation project. Out of scope: pre-recorded time-based media and office file formats published before 28 June 2025; online maps, where essential navigational information is provided accessibly by other means; third-party content neither funded nor developed by, nor under the control of, the operator; and website or application content qualifying as an archive, meaning content not updated or edited after 28 June 2025.

That last one has a catch: editing archived content after that date takes it out of the exclusion.

The microenterprise exemption, and its limit

Microenterprises providing services are exempt from the accessibility requirements for services and the obligations attached to them. A microenterprise employs fewer than 10 persons and has an annual turnover or balance sheet total not over EUR 2 million.

Two limits. The exemption is written for services — a microenterprise placing a covered product on the market is not exempted by it. And crossing either threshold ends it, which makes it a poor thing for a growing business to plan around.

The transitional periods, which are finite

  • Service contracts agreed before 28 June 2025 may run unaltered until they expire, but no longer than five years from that date.

  • Products lawfully used by a service provider before that date may continue in use until 28 June 2030.

  • Self-service terminals in lawful use before 28 June 2025 may, where the Member State so provides, run to the end of their economically useful life and in any event no longer than 20 years from entering use.

So a payment terminal estate need not be replaced at once, and a contract signed in May 2025 buys time. Both clocks are running.

Two things worth doing

Answer the scope question in writing. Do you sell to consumers online, offer consumer banking, or publish e-books? If so you are in scope, and the microenterprise exemption is the only way out of it.

Date your content. The exclusions turn on what was published or last edited before 28 June 2025 — an audit question before it is a design question — and content you fund, develop or control is yours wherever it is hosted.

This is a Directive, so the detailed requirements, the supervising authority and the penalties come from the Latvian transposing law rather than from the text above, and that is the part to confirm locally.

Discuss your matter with our team.

Tell us what you are planning and we will tell you what the regulator is likely to ask.

Contact the team