Accessibility for everyone: European Accessibility Act (EAA)

The EAA will apply to digital products and services such as computers, smartphones, operating software, e-books, e-commerce companies, webshops, telecommunications services, audiovisual media services (such as Netflix), financial services (such as online banking and random readers), and transport-related services.

Not all organizations will be fully subject to the EAA. There are exceptions for:

• Micro-enterprises (< 10 employees and annual turnover < €2 million).
• Organizations for which compliance with accessibility requirements imposes a 'disproportionate burden' (for example, when
• costs are disproportionate to the benefits for consumers) or where applying the guidelines fundamentally changes the service.
• Certain content of online products and services (such as media published before June 28, 2025, archives, and online maps and
• mapping services for navigation where essential information is provided in an accessible manner).
• Business-to-business services.

In short, the EAA describes the following four accessibility requirements for online products and services:

• Operable (a website must be operable in multiple ways, such as with a mouse, keyboard, screen reader, and voice control);
• Perceivable (a website must be readable, even for the blind or visually impaired, using text size, font, and contrast);
• Understandable (relevant information must be easily findable and presented in a comprehensible writing style);
• Robust (the content of a website must be reliably interpretable using various technologies).

The content of the EAA is not entirely new as it essentially codifies the European accessibility standard (EN 301 549), which is further elaborated in the Web Content Accessibility Guidelines (WCAG) (It is mandatory to comply with version 2.1 level AA and recommended to comply with version 2.2). Additionally, legal digital accessibility requirements have long been in place for (semi-)government institutions based on the Temporary Decree on Digital Accessibility of Government.

Organizations offering online products and services are required to prepare and make available an accessibility statement (readable in various ways). This accessibility statement must explain how the online product/service works, how it is accessible, and how its accessibility is ensured. Additionally, organizations must establish internal procedures to ensure compliance with accessibility requirements and train staff accordingly. Furthermore, it is important that supporting products and services, such as customer service, also provide accessible information.

Online products, services, and service contracts offered/replaced/concluded/modified from June 28, 2025, must immediately comply with the EAA. Products, services, and service contracts already in use before June 28, 2025, may continue to be used/continue unchanged until June 28, 2030.

Five different regulators will oversee compliance with the EAA, namely: the Authority for Consumers and Markets (ACM), the Digital Infrastructure Inspectorate (RDI), the Media Authority (CvdM), the Human Environment and Transport Inspectorate (ILT), and the Financial Markets Authority (AFM). Which regulator is relevant for an organization depends on the sector in which it operates.

If you are starting with the implementation of the EAA, be sure to read the next blog where I will provide practical tips and links for implementing the EAA.

For questions about the EAA, contact Michelle Wijnant, attorney-at-law IT, Privacy & Cybersecurity.

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