What is The European Accessibility Act 2025 And How to Prepare?

The European Accessibility Act (EAA) introduces a unified set of requirements that, from 28 June 2025, will apply to every company offering specified products and services in the European Union — from computer hardware to digital sales channels and retail banking. Its purpose is to remove barriers that hinder people with diverse functional needs from using technology, while ensuring regulatory consistency across the single market. In practice, this means adapting design processes, technical documentation, supply chains and customer service to clearly defined functional criteria linked to EN 301 549 and WCAG 2.1 AA.

Meeting those obligations may seem costly, yet the benefits extend far beyond avoiding administrative penalties. Accessibility opens the door to a larger audience—over one hundred million consumers in Europe alone — enhances brand reputation and reduces the long-term costs of maintaining and supporting digital services.

Directive (EU) 2019/882 (European Accessibility Act) is a harmonising measure: it removes divergences between national laws by introducing common minimum functional requirements for selected products and private commercial services. In Poland it is transposed by the Act on Ensuring the Accessibility of Certain Products and Services (Polish Accessibility Act), adopted in April 2024 and applicable from 28 June 2025.

• 28 June 2022 – EU Member States had to transpose the Directive into national law.
• 28 June 2025 – all new products and services within scope must be designed and supplied in line with the accessibility requirements.
• Until 28 June 2030 – services may continue to be provided with legacy products that were lawfully used before 2025, under the five-year clause.
• Until 2045 – self-service terminals (ATMs, ticket machines, check-in kiosks) installed before 2025 may remain in use until end of economic life or for a maximum of 20 years.

Annex I lists, among others:

• computers, operating systems and smartphones,
• digital TV sets and set-top boxes,
• e-book readers and software,
• ATMs, ticketing machines, self-service check-in machines,
• payment terminals and POS devices.

Manufacturer, importer and distributor of each listed product are responsible both for meeting the technical criteria and for issuing appropriate documentation (declaration of conformity, instructions in alternative formats) .

In terms of services, the Directive imposes requirements on:

• telephone and data transmission services,
• retail banking (including online and mobile banking),
• e-commerce (webshops, marketplaces),
• e-books and dedicated reading software,
• digital passenger information systems for public transport,
• access to audiovisual media services,
• emergency communications to the 112 number.

Service providers must ensure that every interaction stage—from information display to finalising a transaction—can be operated via assistive technologies, keyboard input, sensory alternatives and clear error messages.

Service-sector micro-enterprises (up to 10 employees and €2 million turnover) are formally exempt, although the European Commission encourages voluntary adoption—an opportunity to reach new customers and partners.

Products and services whose modification would impose a “disproportionate burden” may rely on an exemption after documenting the cost analysis, alternatives and user impact. The document must remain public for at least five years.

National authorities supervise enforcement (in Poland: UOKiK and specialised inspectorates).

• Administrative fines: from a few thousand euros for single breaches up to six- or seven-figure sums for persistent violations .
• Criminal liability: in some jurisdictions (e.g., Ireland) fines of €60 000 or up to 18 months in prison for accessibility offences .
• Withdrawal orders: authorities may prohibit sale or provision until non-conformities are remedied.
• Reputational damage: published decisions can erode customer and partner trust.

While the Directive does not mandate a single standard, the de-facto “gold standard” for ICT is EN 301 549 v4.1.1, which embeds WCAG success criteria and universal-design principles. Conforming to a harmonised standard gives a presumption of conformity.

For websites and mobile apps the recommended threshold is WCAG 2.1 Level AA—especially in e-commerce, missing this level creates immediate sanction risk from 28 June 2025.

1. Stakeholder mapping – identify business lines, products and teams falling within scope.
2. Accessibility audit – combine expert reviews and user testing with people who have functional limitations.
3. Gap analysis – compare Directive requirements with current state; prioritise critical gaps (e.g., missing audio-video alternatives).
4. Implementation plan – define timeline, budget, KPIs and accountability for each obligation.
5. Universal design – build “from first sketch” to avoid costly late-stage fixes.
6. Staff training – cover developers, content creators and procurement teams.
7. Supply-chain management – embed EAA clauses into contracts for hardware, software and content providers.
8. Acceptance testing – before launch or update, run WCAG/EN 301 549 tests, including keyboard control and screen-reader compatibility.
9. Declaration of conformity – prepare and publish CE/DOC in national language(s) and English, available digitally.
10. Monitoring and remediation – after go-live, conduct continuous automated scans, manual tests and respond to customer complaints.

European Commission studies indicate that more than 100 million consumers in the EU require accessible solutions, with a combined purchasing power exceeding €2 trillion annually. Companies investing in accessibility report lower customer-support costs, better SEO and higher user loyalty. In Poland, businesses may apply for grants from a €240 million fund dedicated to accessibility projects.

The European Accessibility Act is not an “optional extra” — from 28 June 2025 it becomes daily reality for manufacturers, service providers and retailers operating across digital and physical channels. The deadline is close, but by following a structured plan and leveraging established standards (WCAG, EN 301 549), organisations can not only avoid fines but also build sustainable competitive edge and an inclusive brand reputation. Accessibility ceases to be a cost and becomes an investment in growth.