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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

The European Accessibility Act has applied across the EU since 28 June 2025. It usually gets 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 line of work you are in. It is whether you sell one of the listed things to consumers.

The services it covers

For services sold to consumers after 28 June 2025: online shops; consumer banking; e-books and the software that reads them; electronic communications services, apart from machine-to-machine traffic; services giving access to TV and video on demand; and certain parts of air, bus, rail and ferry travel — websites, apps, electronic ticketing, travel information and self-service machines in the EU.

The first three are the ones that catch people. Any business selling to consumers online is providing an online shop, whatever else it does for a living.

And the products

For products put on the market after 28 June 2025: consumer computers and their operating systems; payment terminals; cash machines, ticket machines, check-in machines and interactive information terminals; consumer equipment used for phone, internet or TV services; and e-readers. The rules also apply to answering emergency calls to 112.

What is left out

The exclusions take a lot of old material out of scope, and they are worth reading before anyone budgets for a fix-it project. Out of scope:

  • recorded audio and video, and office file formats, published before 28 June 2025;

  • online maps, as long as the essential information for finding your way is available in an accessible form some other way;

  • third-party content you did not pay for, did not develop and do not control;

  • website or app content that counts as an archive — meaning it has not been updated or edited since 28 June 2025.

The last one has a catch worth knowing: edit archived content after that date and it is no longer archived.

The small-business exemption, and where it stops

Microenterprises that provide services are exempt from the accessibility requirements for services, and from the duties that go with them. A microenterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million.

Two limits on that. The exemption is written for services, so a microenterprise that puts a covered product on the market is not exempt. And crossing either threshold ends it, which makes it a poor thing for a growing business to build plans around.

The transition periods, which do run out

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

  • Equipment already lawfully in use by a service provider before that date can stay in use until 28 June 2030.

  • Self-service machines lawfully in use before 28 June 2025 can, where the country allows it, run to the end of their useful life and in any event no longer than 20 years from when they were first used.

So a fleet of payment terminals does not have to be replaced all at once, and a contract signed in May 2025 buys you time. But 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 yes, you are covered, and the microenterprise exemption is the only way out.

Put dates on your content. The exclusions turn on what was published or last edited before 28 June 2025, which makes this an audit question before it is a design question. And content you pay for, develop or control is yours, wherever it happens to be hosted.

This comes from an EU directive, so the detailed requirements, the supervising authority and the penalties come from the Latvian law that implements it rather than from anything above — worth confirming 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