The European Accessibility Act (EAA), Directive (EU) 2019/882, does not automatically apply to every website. It applies to specified products and consumer services, including e-commerce and certain services that use websites or mobile apps. Member States were required to apply their implementing measures from 28 June 2025. Website owners should identify the service they provide, check the law in each relevant country, and verify the requirements and any applicable exemptions before deciding what to do.
Does the EAA apply to your website?
Start with the service the website helps provide, not the fact that the website is online. The EAA covers specified products placed on the market and specified services provided to consumers. A website may be part of a covered service, but owning or operating a website by itself does not establish that the Directive applies.
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E-commerce is expressly included. The Directive also covers defined service categories in which websites or mobile apps may play a role, including certain passenger-transport services. The relevant question is whether the service and the way it is provided meet the Directive’s definitions as implemented in the Member State or States where you operate.
Services listed in the Directive
- Electronic communications services.
- Services providing access to audiovisual media services.
- Specified elements of passenger-transport services.
- Consumer banking services.
- E-books and dedicated software.
- E-commerce services.
- Answering emergency communications to 112.
This list is not a shortcut for deciding the status of a particular site. For example, an online shop is a clear reason to investigate the e-commerce requirements, but the Directive does not make all websites subject to the same rules. Consider what you sell or provide, whether the service is for consumers, and the applicable national definitions.
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What changed on 28 June 2025?
Member States were required to apply their measures implementing the Directive from 28 June 2025. That date is not a general grace period for websites. The Directive has specific transitional provisions for certain circumstances, including some products already lawfully used to provide similar services before that date, generally through 28 June 2030, and a separate potential extended use period for certain self-service terminals, capped at 20 years after they enter into use. Those provisions have defined contexts; they should not be treated as a blanket extension for a website.
What covered service providers need to do
For covered services, the Directive sets accessibility requirements and requires information about the service, its accessibility features and facilities. Its framework also addresses the accessibility of websites and mobile-device-based services, and support systems must be able to provide relevant accessibility information. The applicable functional requirements depend on the service and the rules transposed in the relevant Member State.
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Service providers must make information needed to assess conformity available in general terms and conditions or an equivalent document. Check the applicable national rules for the information to provide and how it must be presented. Do not assume a single technical checklist, automated scan, overlay or accessibility widget establishes compliance: the legal requirements are functional, and a tool alone cannot determine whether the specific service meets them.
Build an assessment around the service
- Describe the service. Record what consumers can do through the site or app, and how the online interface fits into the service you provide.
- Map the relevant markets. Identify the Member States whose implementing laws may apply. A single EU directive does not mean that every national procedure, authority or penalty is identical.
- Check the applicable requirements. Review the national law and authoritative guidance for the service category, including the required accessibility features and service information.
- Document evaluation and remediation. Keep evidence of what was assessed, the barriers found, fixes made and any remaining limitations. Re-test relevant user journeys after changes.
- Check any exception carefully. If you believe an exception applies, document the basis and verify the national implementation rather than relying on a generic claim of exemption.
Exclusions and exemptions are specific
The Directive sets out defined exclusions. They include certain pre-recorded time-based media and office file formats published before 28 June 2025; online maps in the specified circumstance where essential information is provided accessibly; third-party content that is not funded, developed by or under the control of the operator; and archived website or mobile-app content that has not been updated or edited after 28 June 2025.
These exclusions depend on their stated conditions. For example, the third-party-content exclusion is not a general way to disregard content merely because another party created it: funding, development and control matter under the Directive.
Microenterprise exemption
Microenterprises providing services are exempt from the Directive’s accessibility requirements and related obligations. This is a defined exemption for qualifying service providers, not a blanket exemption for every small business and not a general exemption for operators of products. Check the statutory definition and how the relevant Member State has implemented it before relying on the exemption.
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Fundamental alteration or disproportionate burden
The Directive provides for an exception where meeting a requirement would fundamentally alter the basic nature of a product or service or impose a disproportionate burden. It is not an informal opt-out. The Directive includes criteria for assessing the issue and requires relevant assessments and information in applicable cases. Document the reasoning and check the national rules before relying on this provision.
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Member States are responsible for implementing enforcement. The Directive requires effective means to support compliance, including mechanisms for complaints and authority follow-up, and requires national penalties to be effective, proportionate and dissuasive, alongside effective remedial action.
The Directive does not set one EU-wide fine amount for website owners. The competent authority, complaint procedure, available remedies and penalty amounts depend on the relevant Member State’s implementing law. Confirm these details with the current national rules or competent authority rather than applying a figure from another country.
Using screenshots in accessibility work
A screenshot can help a team record how a page appeared during a particular review, but it cannot show whether a site works with a keyboard or assistive technology, and it does not prove legal compliance. If visual records are useful to your process, ScreenshotNeo is a website screenshot API and MCP server. It can remove known consent banners, newsletter popups and chat widgets before capture; those steps can also be turned off. Treat any captured image as one piece of documentation, not as an accessibility assessment or legal determination.
For screenshots, ScreenshotNeo says bot checks or CAPTCHAs, blank pages, timeouts, failed loads and cache hits are not billed, and responses identify the page verdict and billing status. Its MCP server supports AI agents using tools including take_screenshot, get_page_info and capture_pdf. The free plan includes 1,000 shots a month without a card; paid plans start at $5 for 3,000 shots. These features may help with visual records, but they do not replace service-specific evaluation or remediation.
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A practical decision checklist
- Does the website support a service expressly covered by the EAA, such as consumer e-commerce, or form part of another listed service?
- Is the service provided to consumers, and which Member State implementing rules are relevant?
- Have you checked the national requirements for service accessibility and information?
- Does a specific exclusion or microenterprise exemption apply under the applicable definitions and conditions?
- If relying on fundamental alteration or disproportionate burden, have you made and documented the required assessment?
- Do you know the relevant national authority, complaint route and enforcement rules?
Because the answer depends on the service, business circumstances and jurisdiction, this overview is not a determination of whether a particular website is covered or compliant. Use the Directive’s framework together with the current implementing law and competent authority for each relevant market.
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