Does the EAA Apply to My Business? A Complete Guide

The European Accessibility Act (EAA) became enforceable on June 28, 2025. It's the most significant digital accessibility law ever passed in Europe - but figuring out whether it applies to your business isn't straightforward.

This guide walks through who's in scope, who's exempt, and what to do if you're unsure.

What the EAA actually is

The EAA (Directive 2019/882) is an EU directive that requires certain products and services to be accessible to people with disabilities. Unlike a regulation, a directive sets the goal but lets each EU member state write its own national law to implement it. All 27 member states were required to transpose the directive into national law by June 28, 2022, and enforcement began on June 28, 2025.

The directive references EN 301 549 as the technical standard, which in turn maps closely to WCAG 2.1 Level AA for web content.

Which sectors are covered

The EAA covers specific product and service categories. If your business provides any of the following, you're likely in scope:

Products

• - **Computers and operating systems** - desktops, laptops, tablets, smartphones, and their operating systems
• - **Self-service terminals** - ATMs, ticketing machines, check-in kiosks, payment terminals
• - **Consumer equipment for telecommunications** - phones, modems, routers used for telecom services
• - **Consumer equipment for audiovisual media** - set-top boxes, smart TVs used for media access
• - **E-readers** - dedicated e-book reading devices

Services

• - **E-commerce** - any online store selling products or services to consumers
• - **Banking and financial services** - online banking, payment processing, investment platforms
• - **Telecommunications** - phone, internet, and messaging services
• - **Audiovisual media services** - streaming platforms, video on demand
• - **Transport services** - booking and ticketing for air, bus, rail, and waterborne transport (not the vehicles themselves)
• - **E-books and dedicated software** - digital publishing platforms

The key distinction: it's about the service you provide, not the technology you use. If you sell products online, your e-commerce website and app must be accessible - even if you wouldn't describe yourself as a "tech company."

Products vs services: why the distinction matters

The EAA treats products and services differently in several important ways.

For products, accessibility requirements apply to the product itself. A self-service kiosk must have accessible hardware and software. Manufacturers and importers bear responsibility.

For services, the requirements apply to the digital interfaces through which the service is delivered - your website, mobile app, or digital documents. The service provider bears responsibility.

This distinction also matters for the microenterprise exemption. Microenterprises are only exempt from service requirements, not product requirements. If you manufacture self-service terminals, the exemption doesn't apply to you regardless of your size.

Which countries are covered

All 27 EU member states are covered. Each country has transposed the EAA into national law, though the specifics (penalties, enforcement bodies, complaint mechanisms) vary by country.

You can check the specific requirements for each country on our EAA country pages. Countries like Germany, France, and Spain have published detailed national legislation. Others are still refining their enforcement frameworks.

The EEA countries (Norway, Iceland, Liechtenstein) are expected to adopt equivalent requirements. The UK is not covered by the EAA but has its own accessibility regulations under the Equality Act 2010.

Does it apply to non-EU businesses?

Yes. If your business sells covered products or services to consumers in the EU, the EAA applies to you - regardless of where your company is headquartered.

A US-based SaaS company selling subscriptions to EU customers is in scope. A Canadian e-commerce store shipping to EU addresses is in scope. An Australian bank offering services to EU residents is in scope.

The EAA follows the consumer, not the company.

This mirrors how GDPR works: if you serve EU consumers, you must comply with EU rules. Enforcement against non-EU companies is more complex in practice, but the legal obligation is clear.

The microenterprise exemption

Microenterprises - defined as businesses with fewer than 10 employees and either annual turnover or annual balance sheet total not exceeding €2 million - are exempt from the EAA's service requirements.

This is a narrow exemption with important caveats:

• - It only applies to services, not products
• - Both conditions must be met (size **and** revenue)
• - If you grow past either threshold, you lose the exemption
• - Some member states may implement stricter rules

For a deeper dive, read our full guide on the EAA microenterprise exemption.

B2B vs B2C

The EAA primarily targets services provided to consumers (B2C). Pure B2B services with no consumer-facing component are generally not in scope.

However, the boundaries aren't always clear:

• - A B2B platform used by employees of a client company may still need to be accessible under separate employment accessibility laws
• - If your B2B product has any consumer-facing element (a client portal, a public-facing widget), that element may be in scope
• - Public procurement rules in many EU countries already require accessibility for B2B products sold to government

When in doubt, making your product accessible is the safest approach - and it's increasingly expected by enterprise buyers regardless of legal requirements.

How to check if you're in scope

We built a free EAA Scope Checker that walks you through a series of questions to determine whether the EAA applies to your business. It takes about two minutes and gives you a clear answer with an explanation.

The checker covers:

• - Your business sector and service type
• - Your company size and revenue
• - Where your customers are located
• - Whether you sell products, services, or both

What to do if you're in scope

If the EAA applies to your business, here's your action plan:

• **Audit your digital presence** - scan your website, web app, and mobile app for accessibility issues. [Lumi's multi-engine scanner](/) catches issues that single-engine tools miss.
• **Prioritise critical issues** - focus on WCAG 2.1 Level AA conformance, which is what EN 301 549 requires for web content.
• **Fix and verify** - address issues systematically and re-scan to confirm fixes.
• **Document your compliance** - keep records of your accessibility efforts. An [accessibility statement](/tools/accessibility-statement-generator) is a good starting point.
• **Monitor continuously** - accessibility regresses with every code change. Set up ongoing monitoring to catch new issues before your users do.

The penalties for non-compliance vary by country but can be significant - up to €1 million in Spain, with criminal liability in Ireland.

Still not sure?

Start with our EAA Scope Checker. If your situation is complex - for example, you operate in multiple sectors or have a mix of B2B and B2C services - consult an accessibility specialist or legal advisor familiar with the EAA.

The enforcement deadline has passed. If you're in scope, the time to act is now.