With the EAA coming into force in June 2025, many organizations are asking a lot of questions. In this blog, we will discover top critical concerns.
1. What products and services do the EAA actually cover?
Article 2(1): “This Directive applies to the following products placed on the market after 28 June 2025: (a) consumer general purpose computer hardware systems and operating systems for those hardware systems; (b) the following self-service terminals: (i) payment terminals; (ii) the following self-service terminals dedicated to the provision of services covered by this Directive: — automated teller machines; — ticketing machines; — check-in machines; — interactive self-service terminals providing information”
Article 2(2): “This Directive applies to the following services provided to consumers after 28 June 2025: (a) electronic communications services; (b) services providing access to audiovisual media services; (c) [passenger transport services]; (d) consumer banking services; (e) e-books and dedicated software; and (f) e-commerce services.”
This means that, if you sell, distribute or make available below kinds of products, accessibility is a must:
- Consumer general-purpose computer hardware & OS. Example: Laptops, desktops, Tablets, Smartphones, Operating systems (Windows, macOS, Android, iOS)
- Self-service terminals: These are public-facing machines people must use without assistance.
- Payment terminals, for example: POS card readers, Contactless payment machines …
- Service terminals, for example: ATMs, Ticketing machines, Check-in kiosks, Interactive information kiosks …
For services, below is the list:
- Telecommunications services. Example: Mobile phone services, Internet services, Messaging platforms …
- Services providing access to audiovisual media. Example: Streaming platforms, Media players, …
- Passenger transport services. Example: Booking websites, mobile application, e-ticket, …
- Consumer banking services. Example: Online banking, mobile application, customer portals, …
- E-books and dedicated software. Example: e-book readers, reading applications, …
- E-commerce services. Example: online shop, booking and ordering platforms, …
2. What if making something accessible would fundamentally change it or cost too much?
Article 14(1): “The accessibility requirements referred to in Article 4 shall apply only to the extent that compliance: (a) does not require a significant change in a product or service that results in the fundamental alteration of its basic nature; and (b) does not result in the imposition of a disproportionate burden on the economic operators concerned.”
Article 14(2): “Economic operators shall carry out an assessment of whether compliance with the accessibility requirements referred to in Article 4 would introduce a fundamental alteration or, based on the relevant criteria set out in Annex VI, impose a disproportionate burden”.
There are 2 allowed exceptions:
Does NOT cause a fundamental alteration
You are not required to make an accessibility change if it would: Change the core purpose, destroy the essential function or turn the product/service into something else.
Examples:
- Turning a real-time competitive game into a turn-based game
- Removing essential visual content from a visual art experience
- Eliminating security mechanisms in banking “because screen readers struggle”
What is NOT a fundamental alteration?
Common misconceptions:
- “Our UI would look different” ❌
- “It’s expensive” ❌
- “We didn’t design for this originally” ❌
- “It’s technically hard” ❌
👉 Changing how something is accessed ≠ changing what it is
Does NOT impose a disproportionate burden
You are not required to comply if the cost/effort is objectively unreasonable for your organization. But this is relative, not absolute, for example, unreasonable for a start-up with 2 members but reasonable for a bank.
“Disproportionate” depends on: Company size, Financial resources, Market reach, Nature of the product/service.
But you cannot just claim exemption. You must assess and document it.
3. How do we prove our services meet the requirements?
Article 13(2): “Service providers shall prepare the necessary information in accordance with Annex V and shall explain how the services meet the applicable accessibility requirements. The information shall be made available to the public in written and oral format, including in a manner which is accessible to persons with disabilities. Service providers shall keep that information for as long as the service is in operation.”
Article 13(3): “Service providers shall ensure that procedures are in place so that the provision of services remains in conformity with the applicable accessibility requirements.”
Article 13 says two things: You must publicly explain how your service is accessible AND You must keep it accessible over time, not just at launch.
Service providers must:
- Create accessibility information
- Explain how the service meets accessibility requirements
- Make that information: public, accessible and available for as long as the service exists
What “in accordance with Annex V” means? Annex V defines what must be described, for example:
- Which accessibility standards are used (e.g. WCAG / EN 301 549)
- Which features support accessibility
- Known limitations or exceptions
- How users can get help or report accessibility issues.
In real life, this becomes an Accessibility Statement.
This means that this statement must be in accessible way in an easy to find, not hidden or “available on request only” both in written format, for example on website page, in accessible PDF or on app info page, and in oral format such as customer support phone line or voice-based assistance.
4. What technical standards should we follow?
Article 15(1): “Products and services which are in conformity with harmonised standards or parts thereof the references of which have been published in the Official Journal of the European Union, shall be presumed to be in conformity with the accessibility requirements of this Directive in so far as those standards or parts thereof cover those requirements.”
Article 15(2): “The Commission shall, in accordance with Article 10 of Regulation (EU) No 1025/2012, request one or more European standardisation organisations to draft harmonised standards for the product accessibility requirements set out in Annex I.”
While waiting for specific EAA standards, many organizations follow WCAG 2.1 AA or WCAG 2.2 AA for digital accessibility, as these align with the Directive’s functional requirements.
5. Do we need to update products and services already on the market?
Article 2(1): “This Directive applies to the following products placed on the market after 28 June 2025”.
Article 2(2): “This Directive applies to the following services provided to consumers after 28 June 2025”.
Article 7(4): “Changes in product design or characteristics and changes in the harmonised standards, or in technical specifications, by reference to which conformity of a product is declared shall be adequately taken into account.”
These three articles together define when the EAA applies and what happens when things change. In short, new products and services must be accessible from 28 June 2025 onward, and compliance must stay aligned when designs or standards change. Please note that services are continuous, no legacy exemption, so website launched in 2020 but still operating in 2026 must comply.