European Accessibility Act Becomes Effective June 28, 2025

Universal Accessible Man on European Flag

According to an article by Seyfarth Shaw, U.S. businesses that provide consumer facing technology such as websites and mobile apps to customers in the European Union should take note that the European Accessibility Act (“EAA”) took effect on June 28, 2025.  The EAA also applies to some consumer technologies such as hardware systems and operating systems, self-service equipment, and e-readers. 

Consumer facing technology can include, but is not limited to,

• Cloud Forms

• Digital Signatures

• Smart Chatbot

• SMS Notifications

• Business Mobile App

• FAQ Kiosk

• VoIP Phone System

• Websites

The purpose of this Directive is to contribute to the proper functioning of the internal market by approximating the laws, regulations and administrative provisions of the Member States regarding accessibility requirements for certain products and services by, in particular, eliminating and preventing barriers to the free movement of products and services covered by this Directive arising from divergent accessibility requirements in the Member States.

Scope

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:

1. payment terminals;

2. 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, excluding terminals installed as integrated parts of vehicles, aircrafts, ships or rolling stock;

(c) consumer terminal equipment with interactive computing capability, used for electronic communications services;

(d) consumer terminal equipment with interactive computing capability, used for accessing audiovisual media services; and

(e) e-readers.

2. Without prejudice to Article 32, this Directive applies to the following services provided to consumers after 28 June 2025:

(a) electronic communications services with the exception of transmission services used for the provision of machine-to-machine services;

(b) services providing access to audiovisual media services;

(c) the following elements of air, bus, rail and waterborne passenger transport services, except for urban, suburban and regional transport services for which only the elements under point (v) apply:

1. websites;

2. mobile device-based services including mobile applications;

3. electronic tickets and electronic ticketing services;

4. delivery of transport service information, including real-time travel information; this shall, with regard to information screens, be limited to interactive screens located within the territory of the Union; and

5. interactive self-service terminals located within the territory of the Union, except those installed as integrated parts of vehicles, aircrafts, ships and rolling stock used in the provision of any part of such passenger transport services;

(d) consumer banking services;

(e) e-books and dedicated software; and

(f) e-commerce services.

Because each member state must set up its own enforcement framework, approach to enforcement will not necessarily be uniform across the EU. However, penalties must take into account the seriousness of the violation, the number of non-complying products or services involved and the number of persons affected. Depending on the country of enforcement, noncompliance may result in a fine and personal liability for officers, directors and managers. In addition, non-compliant websites and mobile apps may be shut down and products may be removed from the market.

SUMMARY

U.S. businesses that place consumer-facing technology products on the EU market or provide services to EU consumers, via e-commerce websites and/or mobile apps should be assessing the EAA’s impact on their business if they have not done so already.