Introduction about EAA
As some of you may know, EAA is European Accessibility Act, it is the directive of the European Union that legally require EU members state to follow. It aims to support a wider range of accessibility and provide a standard among members state in EU. The deadline of EAA is nearly to come, are you unsure how to apply? Let’s us give a hand.
EAA scope
EAA covers a wide range of products and services, from personal devices such as computers, smartphones, e-readers to public services such as ATM, public transport services, banking services and e-commerce websites…
You might think EAA affects big giant only, however, it is everywhere. EAA target the producer, the manufacturer, the authorized representative, the importer, the distributor, and the service providers. It is also applied to non-EU based companies but provide/selling product or services in EU.
The timeline
Any products and services in the list above, that is released, updated or changed after 28 June 2025 must fully comply with EAA. Each members state have to adopt and have necessary law to follow EAA. This means that the penalties can be varied from country, such as fine, penalties or market restriction.
The exceptions
There are also some exceptions such as microenterprises (enterprises that have less than 10 employee and annual turnover < 2M EUR) are exempted to comply with EAA or pre-recorded time-based media, archived, certain third-party contents. There are also exception to B2B (business to business) companies, since the directive target the consumers of the products and services. However, implementing accessibility can have many other benefits.
There is also an exception “proportion burden” which means comply with accessibility rule will create a burden, such as cost of compliance is too high. This follows these principles to assessment:
- The ratio of cost to compliance with overal cost
- The estimated cost and the benefits
Of course these are not easy. The entities have to make the assessment themselves and decide. If claiming it is “proportion burden” they have a lot of things to do because there are a lot of requirements to meet this.
What we have to do to comply with EAA
EAA is a directive, not a standard, it also does not refer to any standard and leaves to each country to define a specific standard and conformance level. However, it mentions about four accessibility principles for web and mobile applications: Perceivable, Operable, Understandable and Robust which is clearly specify in WCAG. Currently, most members are implementing EN 301 549 which cites WCAG 2.1 level AA.
So, we have to mention a little about EN 301 549 and WCAG.
EN 301 549 and WCAG
EN 301 549 is an accessibility standard in EU for products and services. It defines accessibility requirement that products and services in information and communication technology (ICT) should meet.
WCAG is Web Content Accessibility Guidelines. Although the name is about web but it’s also applicable to software such as native mobile applications.
Will applying WCAG automatically comply with EAA?
EN 301 549 is currently updated with the aim to publish in 2025 in support for the EAA. We won’t know exactly when and what changes in the new version, however, the current version is a solid reference point. And in the current version, EN 301 549 cites WCAG 2.1 level AA. So, for EAA, WCAG 2.1 AA and potentially 2.2 AA is a worthy reference point.
Summary
To summarize:
EAA is a law that set accessibility requirements for products and services in EU.
EN 301 549 is the technical standard provide details how to make ICT services and products accessible and it is incorporate with WCAG 2.1 AA standard. It is ongoing update to meet with EAA.
Although EN 301 549 hasn’t perfectly aligned with EAA, it is still a good reference point to follow and when the new version is published, it is a guide to comply with EAA.
References
https://portal.etsi.org/eWPM/index.html#/schedule?WKI_ID=64282
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0882
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