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EAA: which products and services are covered

Adopted 2026-06-29 · ≈ 2 min read · Dirk Baaijen

Directive (EU) 2019/882 (European Accessibility Act) imposes accessibility requirements on five product categories and six service categories; micro-enterprises providing services are fully exempt, and self-service terminals in use before 28 June 2025 may continue operating until end of economic…

Short answer: The EAA applies to products placed on the market and services provided to consumers after 28 June 2025. Five product groups and six service categories are covered. Micro-enterprises providing services (fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million) are fully exempt. Self-service terminals already lawfully in use before 28 June 2025 benefit from a transitional rule but must comply or be decommissioned no later than 20 years from their individual date of entry into use.

Covered products (Article 2(1))

The Directive applies to the following products placed on the market after 28 June 2025:

  • General-purpose consumer computer hardware including the operating systems for those systems.
  • Self-service terminals: payment terminals, automated teller machines (ATMs), ticketing machines, check-in kiosks, and interactive self-service information terminals.
  • Consumer terminal equipment with interactive computing capability used for electronic communications services.
  • Consumer terminal equipment with interactive computing capability used for accessing audiovisual media services (e.g. smart TVs).
  • E-readers.

Covered services (Article 2(2))

The Directive applies to the following services provided to consumers after 28 June 2025:

  • Electronic communications services (excluding transmission services used for machine-to-machine services).
  • Services providing access to audiovisual media services (streaming platforms, catch-up TV, etc.).
  • Air, bus, rail and waterborne passenger transport services — for specific elements: websites, mobile apps, electronic tickets, real-time travel information, and interactive self-service terminals. Note: for urban, suburban and regional transport, only the interactive self-service terminal element applies (Article 2(2)(c)(v)); the other elements are not required for those transport types.
  • Consumer banking services (payment accounts, payment services, consumer credit).
  • E-books and dedicated software.
  • E-commerce services (online retail platforms).

Emergency services 112 (Article 2(3))

Answering emergency communications to the single European emergency number 112 also falls within the scope of the Directive. Member States may defer application of this specific requirement until 28 June 2027 at the latest. National emergency numbers other than 112 are outside the scope.

Micro-enterprise exemption (Article 4(5))

Micro-enterprises providing services — defined as fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million — are fully exempt from compliance. Micro-enterprises manufacturing products face lighter administrative obligations but are not fully exempt.

Transitional rule for self-service terminals (Article 32(2))

Self-service terminals lawfully used by service providers before 28 June 2025 may continue to be used for the provision of similar services until the end of their economically useful life, but no longer than 20 years after their individual entry into use. The clock runs per terminal, not from a common fixed end date. A terminal put into service in 2010 must therefore be replaced or brought into compliance by 2030 at the latest — there is no single EU-wide deadline such as "28 June 2045".

Sources

  1. https://eur-lex.europa.eu/eli/dir/2019/882/oj/eng
    Directive (EU) 2019/882 — official EUR-Lex text (Articles 2 and 32)
  2. https://eur-lex.europa.eu/EN/legal-content/summary/accessibility-of-products-and-services.html
    EUR-Lex summary of EAA scope
  3. https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/disability/union-equality-strategy-rights-persons-disabilities-2021-2030/european-accessibility-act_en
    European Commission — EAA overview page
  4. https://europeanaccessibilityact2025.com/art-2-eaa/
    Analysis of Article 2 EAA (scope)

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Dirk Baaijen

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