Legal layer – varies by country
Each country decides for itself which authority is responsible, what fines apply, and what reporting obligations are in force. Anyone selling in multiple markets has to deal with multiple sets of laws.
Compliance
European Accessibility Act (EAA) — the EU directive for accessibility
The EAA harmonises accessibility across the EU and applies since 28 June 2025. What it requires, who it affects — and how national laws implement it.
What is the European Accessibility Act?
The European Accessibility Act (EAA) is EU Directive (EU) 2019/882, adopted on 17 April 2019. It sets uniform accessibility requirements across the EU for certain products and services and builds on the UN Convention on the Rights of Persons with Disabilities. Its aim is to replace a patchwork of national rules with a common standard — which makes trade across the single market easier and secures equal access for around 87 million people with disabilities in the EU.
Key Data
2019
Adopted – Directive (EU) 2019/882, adopted on 17 April 2019, in force since 28 June 2019.
28.06.2022
Implementation deadline – the date by which all EU member states had to transpose the EAA into national law.
28.06.2025
Anwendung – seit diesem Stichtag müssen erfasste Produkte und Dienste die Anforderungen erfüllen.
The EAA sets the objective; it becomes binding through the Member States' national implementing laws.
One law, many national implementations.
Because the EAA is a directive, each Member State implements it via its own national law—with its own authority, penalties, and deadlines. Yet, they all rely on the same technical standard.
At the top: the European Accessibility Act (Directive (EU) 2019/882)—it sets only the objective.
Transposed into national law: Germany (BFSG, fines up to €100,000), Austria (BaFG), France, Italy, Spain, and 22 other EU states—each with its own law, authority, and penalties.
All based on the same technical standard: EN 301 549 in conjunction with WCAG—identical in every country.
Scope of application
To whom does the EAA apply?
The EAA covers a defined list of consumer products and services. Online retail is explicitly included—and the directive also applies to providers outside the EU that sell to EU consumers.
Technical layer – uniform across the EU
Practical implementation is measured everywhere against EN 301 549 and, by extension, the WCAG. A website that meets these criteria complies with them in every EU country.
The legal layer varies by country. The technical layer is the same everywhere. You fix the issues once—and you’re on track across the entire EU.
Scope of application
To whom does the EAA apply?
The EAA covers a defined list of consumer products and services. Online retail is explicitly included—and the directive also applies to providers outside the EU that sell to EU consumers.
Consumer hardware
The entire online retail sector for consumers falls under the directive – from online stores to apps.
Banking & Telecommunications
Computers, notebooks, tablets, and smartphones, including operating systems, as well as payment and self-service terminals.
Banking & Telecommunications
Consumer banking services, electronic communications services, and access to audiovisual media.
E-books & E-readers
Electronic books and their reading devices also fall within the scope of application.
Passenger Transport & Ticketing
Certain elements of transport services – such as interactive self-service terminals and real-time travel information.
Also providers outside the EU
Anyone selling to consumers in the EU from abroad is also subject to the requirements.
The exemption for micro-enterprises – and its limits
Micro-enterprises are exempt in the case of services: those with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. Both thresholds must be met (i.e., the figures must be below these limits).
This exemption does not apply to products covered by the EAA. Purely B2B offerings with no consumer connection are not included.
Note: This page provides an accessible overview and does not constitute legal advice. The decisive factor is the national implementing legislation of the country where you offer your services or products.
Consequences
Enforcement – regulated on a country-by-country basis.
Since each state carries out its own enforcement, the specific consequences depend on the market. In Germany, the BFSG and its market surveillance authorities set the framework.
Fines per Member State
In Germany, Section 37 of the BFSG provides for fines of up to €100,000, or up to €10,000 in less serious cases. Other countries have their own penalty frameworks.
Enforcement per market
Any national market surveillance authority can order the rectification of defects and, in extreme cases, prohibit the product from being made available—in every country where you offer it.
Risk of competition-related legal challenges and cease-and-desist letters
In several countries—including Germany—violations can also be challenged under competition law.
The honest part
What it does not do
An accessibility widget is a useful component—but it doesn't ensure EN 301 549 compliance for you. Here is the honest difference.
Hiding the problems
- It does not fix errors in the code: missing alt text, insufficient contrast, and broken keyboard navigation remain.
- It does not automatically comply with EN 301 549 / WCAG – and, on its own, does not protect against fines in EU markets.
- It can even be disruptive for screen reader users if it overwrites the page instead of resolving the underlying issues.
What an overlay does
- Lowers barriers for many visitors – font size, contrast, text-to-speech function, accessibility features.
- Give your users control over the display – instantly and without programming.
- Helps make your efforts visible and document them.
You will only achieve compliance once the underlying problems have been resolved. That is exactly what a scanner is for—not for hiding things.
In 5 steps
Implement once – EU-compliant.
Since EN 301 549 and WCAG serve as the benchmark in every country, the rule is simple: issues you resolve properly count across all EU markets. Welcoma supports you at every step.
Clarify Scope of Impact & Markets
Check whether your offering falls within the scope of the EAA – and in which countries you offer it, thereby determining which national laws apply.
Scan real-time status
The Welcoma scanner identifies issues based on WCAG 2.1/2.2, prioritizes them by severity, and points to the specific location in the code—the single standard that counts across the EU.
Troubleshoot problems
Work through the prioritized list – alt text, contrast, keyboard navigation, structure. The control menu further lowers barriers for your visitors.
Create an accessibility statement
The statement generator creates your statement—including a feedback mechanism that allows users to report barriers.
Continuous monitoring
Keep an eye on your status and use usage analytics to see which accessibility features your visitors actually use.
FAQ
European Accessibility Act — frequently asked questions
What’s the difference between the EAA and national laws like the BFSG?
The EAA is the EU directive; national laws such as Germany’s BFSG implement it. Which one applies to you depends on the markets you serve.
Since when does the EAA apply?
The EAA has applied across the EU since 28 June 2025. The transposition deadline for EU member states was 28 June 2022.
Does the EAA also apply to businesses outside the EU?
Yes. It applies to anyone offering covered products or services to consumers in the EU market, regardless of where the business is based.
Which areas does the EAA cover?
Among others: e-commerce, banking services, electronic communications, passenger transport, e-books and audiovisual services, plus certain devices.
Which technical standard applies?
The WCAG, via the EN 301 549 standard — currently WCAG 2.1 Level AA, with an upcoming move to WCAG 2.2.
Does an accessibility widget make my site EAA-compliant?
No. It supports usability, but compliance only comes from fixing the underlying issues in the code.
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