Does the European Accessibility Act apply to US companies?

It can, and where it does it is because of the market rather than the office. Directive (EU) 2019/882 reaches products placed on the EU market and services provided to consumers in the EU, whoever places or provides them. A US company running a checkout that a consumer in Ireland or Germany can complete is providing an e-commerce service in that member state. Being outside the EU changes who enforces against you and how quickly, not whether the duty attached.

What is the deadline?

28 June 2025, and it has passed. The Act entered into force in 2019 with a six-year transposition and application runway, so the requirements have been applicable since that date. Two transitional periods survive it: service contracts concluded before 28 June 2025 may run unchanged until they expire but no later than 28 June 2030, and self-service terminals lawfully in use before that date may continue for the end of their economic life, capped at twenty years from first use.

We only sell online — does the EAA reach us?

Almost certainly yes, through Annex I Section VII. E-commerce is an in-scope service, and the definition catches the selling surface rather than the thing being sold. It does not matter whether you ship trainers, sell software or take bookings; if a consumer concludes the contract on your website or app, the website or app is the regulated service. This is the limb that catches companies who read the rest of Annex I, saw ATMs and e-readers, and concluded the Act was for somebody else.

Does the microenterprise exemption cover us?

Only if you are providing services, and only if both limbs of the test hold at the same time: fewer than ten persons employed and an annual turnover or annual balance-sheet total not exceeding €2 million. Article 4(5) is a services exemption. A microenterprise that manufactures an Annex I product — a payment terminal, an e-reader, consumer computing hardware — keeps every conformity-assessment, technical-documentation and CE-marking duty in full. The exemption is also self-assessed, which means you are the one who has to be able to evidence the figures you relied on, and you have to re-run the test as the business grows.

What standard do we have to meet?

Article 15 gives you a presumption of conformity if you meet a harmonised standard published in the Official Journal. For websites, mobile apps and software that is EN 301 549. Its clause 9 adopts WCAG 2.1 level AA in full for web content, clause 11 does the equivalent for non-web software including native mobile apps, and clause 10 reaches the documents you deliver through the service — a PDF is not out of scope because it is a PDF. The Directive itself states functional requirements in Annex I; EN 301 549 is the route that makes them testable.

What has to exist in writing?

For services, the Annex V information — a description of the service, of how it meets the accessibility requirements, and of the requirements met — published with your general terms and conditions, in an accessible format, and kept current for as long as the service is offered. For products, the Annex IV technical documentation, an EU declaration of conformity, and CE marking, with the documentation retained for five years after the last unit is placed on the market. If you intend to rely on the disproportionate-burden exception in Article 14, the Annex VI assessment has to exist before you rely on it, be retained for five years, and be re-run at least every five years or whenever the offering changes.

What are the penalties?

There is no EU-wide figure, and anyone quoting one is quoting something that does not exist. Article 31 requires each member state to lay down penalties that are effective, proportionate and dissuasive, so the amount, the authority and the cure period are all national. Article 29 also requires each state to give consumers a route to take non-compliance to a court or a competent authority, which is why the realistic first contact is a regulator's letter rather than a lawsuit. The practical consequence is that your exposure is a function of which member states you actually sell into.

How is this different from the Web Accessibility Directive?

Different targets. Directive (EU) 2016/2102, the Web Accessibility Directive, binds public-sector bodies and has done since 2019-2021. The European Accessibility Act binds private economic operators across the Annex I list. An organisation can be caught by both — a state-owned transport operator, for instance — and the technical test converges on EN 301 549 either way, but the scope articles, the statement requirements and the enforcement routes are separate and you cannot discharge one by pointing at the other.

Does this replace legal advice?

No. This is a reading of the published text of Directive (EU) 2019/882 and of the harmonised standard it points at, mapped to the answers you gave. Member-state transpositions differ, particularly on penalties and on the complaint route. It is a starting checklist, not an opinion on your facts.

Does the European Accessibility Act apply to you?

Three questions about what you sell, who can buy it and how big you are. You get back the duties that attach under Directive (EU) 2019/882 — Annex I scope, the Article 4(5) microenterprise exemption, the Annex V statement, the product conformity route, and the EN 301 549 obligation that resolves to WCAG 2.1 level AA — each with the documents it demands and the date it applies from.

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1 · What you put on the market

Annex I is a closed list. Pick every line that describes something you sell — most companies are caught by the last one rather than by the obvious ones.

2 · Can a consumer in the EU buy it

The Act follows the market, not the head office. Answer by where the customer is.

3 · How big you are

Article 4(5) exempts microenterprises — but only for services, and only if both limbs of the test hold at once.

Pick at least one line above, or “None of these”.

The deadline is behind you, not ahead of you

Nearly every accessibility rule an English-language reader meets is either a litigation risk with no fixed date, like ADA Title III, or a date still to come, like the ADA Title II web rule. The EAA is neither. It has been applicable since 28 June 2025. Companies still describing it as an upcoming requirement are describing a deadline that expired, and the two transitional periods that survive it are narrow: pre-existing service contracts run to 28 June 2030 at the latest, and self-service terminals already in use get the end of their economic life to a twenty-year ceiling. Neither of those covers a website you are still redesigning.

The other thing readers underestimate is reach. Annex I looks like a hardware list until you get to Section VII, where e-commerce is an in-scope service and the regulated thing is the selling surface rather than the goods on it. If a consumer in an EU member state can complete a purchase on your site, you are providing an e-commerce service there, wherever your company is registered.

Why the standard question has a short answer

The Directive states functional requirements — perceivable, operable, understandable, robust — and then Article 15 offers a presumption of conformity to anyone meeting a harmonised standard published in the Official Journal. For anything delivered through a screen that standard is EN 301 549, and its clause 9 adopts WCAG 2.1 level AA in full. Clause 11 extends the same success criteria to non-web software, which is how native and hybrid mobile apps are caught, and clause 10 reaches the documents you deliver through the service.

That is worth knowing because it makes one of your obligations testable today. Scope, exemptions and disproportionate burden are judgement calls you will write down and defend. WCAG 2.1 AA conformance is a measurement, and it is the one item on an in-scope result that you can settle this afternoon.

Common questions

Does the European Accessibility Act apply to US companies?: It can, and where it does it is because of the market rather than the office. Directive (EU) 2019/882 reaches products placed on the EU market and services provided to consumers in the EU, whoever places or provides them. A US company running a checkout that a consumer in Ireland or Germany can complete is providing an e-commerce service in that member state. Being outside the EU changes who enforces against you and how quickly, not whether the duty attached.
What is the deadline?: 28 June 2025, and it has passed. The Act entered into force in 2019 with a six-year transposition and application runway, so the requirements have been applicable since that date. Two transitional periods survive it: service contracts concluded before 28 June 2025 may run unchanged until they expire but no later than 28 June 2030, and self-service terminals lawfully in use before that date may continue for the end of their economic life, capped at twenty years from first use.
We only sell online — does the EAA reach us?: Almost certainly yes, through Annex I Section VII. E-commerce is an in-scope service, and the definition catches the selling surface rather than the thing being sold. It does not matter whether you ship trainers, sell software or take bookings; if a consumer concludes the contract on your website or app, the website or app is the regulated service. This is the limb that catches companies who read the rest of Annex I, saw ATMs and e-readers, and concluded the Act was for somebody else.
Does the microenterprise exemption cover us?: Only if you are providing services, and only if both limbs of the test hold at the same time: fewer than ten persons employed and an annual turnover or annual balance-sheet total not exceeding €2 million. Article 4(5) is a services exemption. A microenterprise that manufactures an Annex I product — a payment terminal, an e-reader, consumer computing hardware — keeps every conformity-assessment, technical-documentation and CE-marking duty in full. The exemption is also self-assessed, which means you are the one who has to be able to evidence the figures you relied on, and you have to re-run the test as the business grows.
What standard do we have to meet?: Article 15 gives you a presumption of conformity if you meet a harmonised standard published in the Official Journal. For websites, mobile apps and software that is EN 301 549. Its clause 9 adopts WCAG 2.1 level AA in full for web content, clause 11 does the equivalent for non-web software including native mobile apps, and clause 10 reaches the documents you deliver through the service — a PDF is not out of scope because it is a PDF. The Directive itself states functional requirements in Annex I; EN 301 549 is the route that makes them testable.
What has to exist in writing?: For services, the Annex V information — a description of the service, of how it meets the accessibility requirements, and of the requirements met — published with your general terms and conditions, in an accessible format, and kept current for as long as the service is offered. For products, the Annex IV technical documentation, an EU declaration of conformity, and CE marking, with the documentation retained for five years after the last unit is placed on the market. If you intend to rely on the disproportionate-burden exception in Article 14, the Annex VI assessment has to exist before you rely on it, be retained for five years, and be re-run at least every five years or whenever the offering changes.
What are the penalties?: There is no EU-wide figure, and anyone quoting one is quoting something that does not exist. Article 31 requires each member state to lay down penalties that are effective, proportionate and dissuasive, so the amount, the authority and the cure period are all national. Article 29 also requires each state to give consumers a route to take non-compliance to a court or a competent authority, which is why the realistic first contact is a regulator's letter rather than a lawsuit. The practical consequence is that your exposure is a function of which member states you actually sell into.
How is this different from the Web Accessibility Directive?: Different targets. Directive (EU) 2016/2102, the Web Accessibility Directive, binds public-sector bodies and has done since 2019-2021. The European Accessibility Act binds private economic operators across the Annex I list. An organisation can be caught by both — a state-owned transport operator, for instance — and the technical test converges on EN 301 549 either way, but the scope articles, the statement requirements and the enforcement routes are separate and you cannot discharge one by pointing at the other.
Does this replace legal advice?: No. This is a reading of the published text of Directive (EU) 2019/882 and of the harmonised standard it points at, mapped to the answers you gave. Member-state transpositions differ, particularly on penalties and on the complaint route. It is a starting checklist, not an opinion on your facts.

Does the European Accessibility Act apply to you?

The deadline is behind you, not ahead of you

Why the standard question has a short answer

Common questions

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