Europe has been known to have some of the strictest and widest range of accessibility…
The European Accessibility Act (EAA): What US Businesses Need to Know
The European Accessibility Act (EAA) is a directive of the European Union that took effect in April 2019, aiming to improve trade between EU members for accessible products and services by removing country-specific rules. With the June 28, 2025, compliance deadline rapidly approaching, many US businesses remain dangerously unaware of how these regulations will impact their operations.
This is not just an EU concern. Any US company that sells products or provides services to European consumers through physical presence, e-commerce platforms, digital content streaming, or online services must comply with these stringent new accessibility requirements. Failure to prepare for these changes could result in significant penalties, market exclusion, and reputational damage.
The urgency for US businesses to understand and implement these requirements cannot be overstated. Companies that ignore these regulations risk not only legal consequences but also losing access to a market of approximately 450 million consumers, including 135 million people with disabilities.
What is the European Accessibility Act, (EAA)?
The European Accessibility Act (EAA), represents a significant shift in how businesses approach accessibility in the European market. Previously, each EU member state had different accessibility standards for products and services, resulting in poor selection, expensive products for consumers, and fragmented markets. The EAA aims to provide equitable access to various online and digital services and products, including websites, e-commerce, e-banking, e-books, ticketing systems, ATMs, and more.
Key Implementation Timeline
- April 2019: The EAA took effect after approval
- June 28, 2022: Deadline for EU member states to transpose the EAA into national legislation
- June 28, 2025: The Act will come into full effect, marking a significant shift in the EU market
- June 28, 2030: End of the five-year grace period for products and services that existed before 2025
Products and Services Covered
The EAA broadly applies to providers of products and services primarily consumer-focused. It includes electronic communication services, services providing access to audio-visual content, some aspects of transportation services, consumer banking services, and e-book and e-commerce services.
Products covered include consumer electronics (TVs, smartphones, computers, gaming consoles), ticketing and vending machines, websites, and mobile apps. For a comprehensive list, visit the European Commission’s official EAA page.
Implications for US Businesses
Service providers do not necessarily have to be present in the European Union for the EAA to apply to them. For example, a U.S.-based social media service accessible in France may be subject to the EAA’s provisions. This makes the EAA relevant for many US companies operating in global markets.
Exemptions
Some businesses and scenarios are exempt from compliance:
The act exempts “micro-enterprises,” companies with less than 10 employees and an annual balance sheet total not exceeding €2 million.
Additional exemptions include:
- Pre-recorded time-based media (e.g., videos) published before June 2025
- Third-party content that is not funded, developed, or under the control of an organization that must be compliant
- Archived content that won’t be updated after June 2025
Technical Requirements
To comply with the EAA, businesses must meet accessibility requirements that align with internationally recognized standards like WCAG 2.1 Level AA for digital accessibility and EN 301 549, which provides detailed technical guidance for accessible information and communications technology in the European context.
Media, Online Video, and Audio Accessibility Requirements
The EAA has significant implications for US companies that produce, distribute, or stream media content to European audiences. These requirements apply to streaming platforms, video-on-demand services, digital broadcasters, and businesses incorporating audio or video content into their digital experiences.
Key Media Accessibility Requirements
The EAA mandates accessibility for content distributed over the internet. This includes websites, apps, media players, products that use video, kiosks, e-commerce platforms, streaming services, and connected TV services.
To comply with the EAA, media content must be made accessible through:
- Closed Captions: Text versions of spoken dialogue and critical sound effects must be provided for people with hearing impairments.
- Audio Descriptions: Narration describing critical visual elements for people with visual impairments.
- Sign Language Interpretation: Where applicable, particularly for critical content.
- Accessible Navigation: Media players must have accessible controls that work with assistive technologies.
Timeline Considerations for Media
Article 32 of the EAA allows a five-year transitional period for audiovisual media services to make content published before June 2025 accessible, giving services until 2030 to ensure compliance for older content. However, any new content published after June 28, 2025, must be accessible immediately.
Language Requirements
Suppose you publish content in a specific language for a given market (e.g., an Italian version of an English video for Italy). In that case, the accessibility features must be in the same language. This means providing Italian captions and audio descriptions for content intended for Italian audiences.
Technical Standards
Media platforms must ensure their digital properties conform to EN 301 549 standards, incorporating WCAG 2.1 Level AA requirements. This includes keyboard accessibility, screen reader compatibility, and sufficient color contrast in player interfaces.
Impact on US Media Companies
Audiovisual media providers must integrate accessibility features such as closed captions and audio descriptions to ensure that individuals with hearing or visual impairments can fully engage with content. This may require significant adjustments to production workflows and technology stacks.
WHAT YOU NEED TO KNOW: US companies that sell products or provide services to European consumers through physical presence, e-commerce platforms, digital content streaming, or online services must comply with these stringent new accessibility requirements. Failure to prepare for these changes could result in significant penalties, market exclusion, and reputational damage.
Sample Industries Impacted
Impact on US Higher Education
The EAA will generally have a limited direct impact on US higher education institutions unless they specifically operate in or provide services to consumers in the European Union.
Who is Affected
US universities with European campuses, online courses targeted at EU students, or digital products and services sold in the EU would fall under the EAA’s scope. The EAA applies to any organization with at least 10 staff and a turnover above €2 million that trades in the EU.
Digital Education Resources
If a US institution offers online courses, digital learning platforms, e-books, or other digital educational resources to students in the EU, these would need to comply with accessibility standards by June 28, 2025.
Procurement Considerations
Procurement policies are critical for increasing accessibility and inclusion. The EAA highlights the need for accessibility of services provided through devices, not just the devices themselves. US universities purchasing technology in European operations should ensure these products meet EAA requirements.
Exemptions to Consider
There are specific exemptions, including pre-recorded videos published before June 2025, third-party content not under an organization’s control, and archived content that won’t be updated after June 2025. These exemptions could apply to certain university materials.
Research Collaborations and Partnerships
US universities participating in EU-funded research projects or with formal partnerships with European institutions may need to ensure digital research tools and publications meet accessibility requirements when shared with European partners.
Foundation of Existing Compliance
US-based universities are often considered ahead in terms of accessibility compared to their European counterparts. Many US institutions already comply with domestic accessibility laws like the Americans with Disabilities Act (ADA) and Section 508, which may provide a good foundation for EAA compliance.
Impact on E-commerce and Retail
The EAA’s impact on e-commerce and retail businesses will be particularly significant, affecting how these companies design, develop, and maintain their digital presence in the EU market.
Who is Affected
Any provider that offers e-commerce services to consumers in the EU falls under the EAA’s scope, regardless of whether that provider is based in the EU. E-commerce services under the EAA broadly include online sales of any product or service, covering not just retail businesses but any organization that offers a product or service for sale online to an EU consumer. This means most US retailers with European customers will need to comply.
Key Requirements for E-commerce
E-commerce platforms must ensure their websites and mobile applications are:
- Perceivable: Information must be presentable to users in ways they can perceive, regardless of disability.
- Operable: User interface components and navigation must be usable by everyone.
- Understandable: Information and operation of the user interface must be understandable.
- Robust: Content must be robust enough to be reliably interpreted by various user agents, including assistive technologies.
These requirements align with internationally recognized digital accessibility standards such as the Web Content Accessibility Guidelines (WCAG) and EN 301 549. Still, the EAA also introduces additional requirements, such as offline help desk support.
Critical E-commerce Functions
For online retailers, several key functions must be made accessible:
E-commerce sites must ensure that users relying on screen readers can navigate product listings, input payment details, and complete purchases. This extends to auction sites where bidding mechanisms must be accessible, potentially requiring alternative input methods or text-to-speech functionalities.
The EAA also requires businesses to provide information concerning the accessibility of the products being sold and ensure the accessibility of functionality for identification, security, and payment.
Customer Support Requirements
Retailers must ensure support services are accessible. All service options, such as live chat, email support, and phone numbers, should be easy to find, and support staff should be trained to assist users with disabilities.
Physical Retail Considerations
For retailers with physical presence in the EU, self-service kiosks and point-of-sale devices must also comply with accessibility requirements. Staff should be trained to assist customers with disabilities in using accessible features, such as guiding a visually impaired customer through audio-assisted options on a self-service kiosk.
Impact on Financial Services and Banking
Financial institutions, including banks, payment providers, and investment firms based in the US, will face significant compliance challenges if they serve EU customers.
Who is Affected
The EAA specifically addresses consumer banking services, which include credit agreements, banking services for payment transactions, electronic money services, and investment services. US financial institutions providing these services to EU consumers must comply with the accessibility requirements.
Digital Banking Services
Banks must ensure that their digital services are accessible, including using simple language, providing alternative text for non-text content, ensuring readable font sizes and contrast, and offering alternatives to biometric identification methods.
For online banking services, mobile apps should be navigable via screen readers and voice commands. Features like transferring money, checking account balances, and other financial transactions must be fully accessible to customers with disabilities.
Accessible Authentication and Security
Identification methods, electronic signatures, security features, and payment services within consumer banking must also comply with the accessibility principles. This is particularly challenging as security features often involve complex verification steps that may not be accessible to people with certain disabilities.
A bank’s online platform should enable customers with visual impairments to use their assistive technology to navigate authentication steps, electronically sign documents, and authorize transactions securely.
Banking Information and Documentation
The EAA emphasizes that information provided in consumer banking services must be understandable, adhering to a specific language complexity level (Level B2 — upper-intermediate) defined by the Council of Europe’s Common European Framework of Reference for Languages.
This could mean presenting financial product terms and conditions clearly and concisely, avoiding jargon or overly technical language that could be challenging for some users to understand.
ATMs and Self-Service Banking
Physical banking interfaces, such as ATMs and self-service terminals, must be accessible to people with various disabilities. This includes considerations for wheelchair users (appropriate height), blind or low-vision customers (audio guidance, tactile indicators), and those with cognitive disabilities (simplified interfaces).
Benefits for Financial Institutions
Compliance with the EAA standards contributes to the image of a socially responsible organization, aligning with the strategies of many banks. User-friendly digital products mean fewer complaints, fewer calls to customer service, and fewer inquiries to the help desk.
Additionally, with an aging population facing various health challenges, accessible banking products and services enable customers to use them even when physical limitations become burdensome, fostering customer loyalty.
Steps Toward Compliance
For US businesses serving European customers, compliance preparation should begin now:
- Assess applicability if your products and services fall under the EAA’s scope.
- Conduct an accessibility audit to establish your current accessibility levels against required standards.
- Implement accessibility training for employees and develop monitoring systems for ongoing accessibility maintenance.
- Create accessibility statements containing information about functionality, technical specifications, and how products/services meet EAA requirements.
Benefits Beyond Compliance
The European Disability Forum advocates for the EAA, demonstrating its importance in addressing the needs and rights of individuals with disabilities. The EU Commission estimates that differing accessibility requirements cost companies and member states €20 billion in 2020, and the proposed EU action is estimated to reduce that by 45 to 50 percent.
Businesses benefit from having a standard set of rules within the EU, facilitating easier cross-border trade and allowing for a more significant market for companies providing accessible products and services. There should be fewer barriers within the EU and more job opportunities.
Conclusion
For US businesses with European customers, the European Accessibility Act represents both an immediate compliance challenge and a strategic market opportunity. Non-compliance consequences are severe—potential financial penalties, exclusion from EU markets, and damaged brand reputation. However, businesses that embrace these requirements proactively will gain significant advantages.
The 2025 deadline may seem distant, but implementation requires substantial preparation, particularly for companies with complex digital ecosystems or large content libraries. Many organizations underestimate the time needed to audit content, implement technical changes, train staff, create proper documentation, and establish ongoing accessibility monitoring. Research your specific industry by using the resources listed below.
US businesses should view the EAA not merely as a regulatory hurdle but as an opportunity to access an expanded customer base, improve user experiences for all customers, and demonstrate corporate social responsibility. Companies that integrate accessibility into their core business strategy will be well-positioned to thrive in European and global markets as digital accessibility becomes increasingly standardized worldwide.
The message is clear: If your US-based company has any operations, products, or services touching the European market, the time to prepare for EAA compliance is now—not in 2025 when penalties begin to apply.
Note: This article provides general information about the European Accessibility Act and should not be considered legal advice. Consult with legal professionals knowledgeable about EU regulations for guidance specific to your business.
References
Official EU Sources
- European Accessibility Act – European Commission
- The EAA comes into effect in June 2025 – AccessibleEU Centre
- Accessibility Legislation at European Level – European Commission
- Web Accessibility Directive FAQ – European Commission
- Accessibility Statement of EU Website – European Union
- Web Accessibility Policy – European Commission
Additional Resources
- European Accessibility Act – Wikipedia
- European Accessibility Act – Inclusion Europe
- European Accessibility Act: Technical Aspects of Compliance
- EAA Impact on UK Higher Education – Jisc
- EU Accessibility Legislation Guide – Media and Learning Association
- European Accessibility Act 2025: Key Steps for Compliance – Level Access
- EAA Analysis – European Disability Forum
- European Accessibility Act: What Broadcasters Need to Know – AI Media
- What the EAA Means for the Media Industry – Limecraft
