The European Accessibility Act

What is the EAA?

The EAA aims to modernise the legal framework around access to goods and services for individuals with disabilities or other challenges, such as hearing or vision impairments. Products and services must now be designed to ensure access and usability for individuals with disabilities, in a manner as equal as possible to those without disabilities.

As a Directive, implementation may vary across EU Member States. In Ireland, the EAA has been transposed into national law under S.I. No. 636 of 2023. If your organisation operates in multiple EU countries, it is essential to review local regulations for each jurisdiction.

Which businesses are impacted?

The EAA applies to manufacturers of products and providers of services made available in the EU, regardless of the location of their business.

There are exemptions for small businesses with 10 or fewer employees and an annual turnover under €2 million.

Industries particularly affected include:
• Consumer banking
• E-commerce providers (including those hosting third-party commerce platforms)
• Transport services
• Manufacturers of consumer devices — including ATMs, personal computers, and smartphones

What do businesses need to do?

Organisations in scope must ensure their products and services are accessible to all, which may involve technical changes, content changes and providing additional information.  

Services must:

• Provide information about accessibility features and facilities
• Ensure websites, especially e-commerce and banking platforms, are easily accessible (including all digital content)
• Offer accessible support systems, such as help desks, call centres and training resources
• Implement inclusive practices, policies and procedures that address the needs of individuals with disabilities. 

Products must:

• Be designed and produced to maximise usability by individuals with disabilities
• Comply with detailed rules on:
  • Information and instructions
  • User interface and functionality
  • Support services
  • Packaging

Timelines

Although the Act came into force on 28 June 2025, there is a transitional period lasting until 28 June 2030. However, the precise scope of this period is not entirely clear.

Per S.I. No. 636 of 2023 states:

“A service provider may, for the period beginning on the date on which these Regulations apply and ending on 28 June 2030, continue to provide their services using products which were lawfully used by them to provide similar services before 28 June 2025.”

To avoid uncertainty and mitigate compliance risk, it is strongly recommended that organisations begin their EAA compliance journey immediately.

Who is regulating the EAA?

Various market surveillance and compliance authorities are tasked with enforcement. These bodies have powers including:

• Issuing enforcement directions
• Applying to the Circuit Court
• Imposing fines of up to €60,000 and/or 18 months’ imprisonment (in Ireland)

Fines vary by country, with the Netherlands imposing some of the highest fines with a €900,000 upper limit.

Note: It is not only regulators that can take action, consumers may also bring cases before the Circuit Court against non-compliant organisations.

How Forvis Mazars can help

Our team can help you understand how the EAA affects your business, conduct a detailed gap assessment and build a structured roadmap to compliance. Start your accessibility journey today to stay ahead of regulatory obligations and better serve your customers.