European Accessibility Act (Directive (EU) 2019/882)
The EU's accessibility law for products and services placed on the market for consumers, published in the Official Journal on 7 June 2019 (OJ L 151, 7.6.2019, p. 70) and in force since 27 June 2019 (the twentieth day after publication, Art. 34). Unlike the Web Accessibility Directive, which binds the public sector's own websites and apps, the EAA binds economic operators — manufacturers, importers, distributors and service providers. Member States had to transpose by 28 June 2022 and apply the measures from 28 June 2025 (Art. 31(1)–(2)), with transitional windows to 2030 for services using pre-existing products and up to 20 years for deployed self-service terminals (Art. 32).
In-scope products include "consumer general purpose computer hardware systems and operating systems for those hardware systems" (Art. 2(1)(a)) and e-readers; in-scope services include "e-commerce services" (Art. 2(2)(f)) and "e-books and dedicated software" (Art. 2(2)(e)). Requirements live in Annex I; conformant products carry CE marking (Arts. 16–18).
Applicability to EdTech
- Whether a headset is in scope turns on the "consumer" definitions. A product is caught as a "consumer general purpose computer hardware system" if it is "characterised by its multipurpose nature, its ability to perform, with the appropriate software, most common computing tasks requested by consumers and intended to be operated by consumers, including personal computers, in particular desktops, notebooks, smartphones and tablets" (Art. 3(39)); its OS is caught by Art. 3(38). Hardware supplied B2B to schools for classroom use, running dedicated rather than general-purpose software, sits outside those words — but the same device marketed to consumers, or a general-purpose OS surface on it, changes the analysis. This is the scope determination flagged in the TODO; the determination itself is product-specific compliance work, downstream of this corpus.
- A consumer-facing web store is an e-commerce service. "Services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract" (Art. 3(30)) must meet Annex I Section III plus the e-commerce-specific requirements in Section IV from 28 June 2025. Sales purely to schools/businesses are not "consumer contracts"; a retail/parent-facing channel is.
- Digital learning content sold as e-books can be caught: "e-books and dedicated software" is an in-scope service (Art. 2(2)(e), defined in Art. 3(41)), with dedicated requirements at Annex I Section IV(f).
- Service providers must publish accessibility information: how the service meets the Art. 4 requirements, in the general terms and conditions or equivalent (Art. 13(2) with Annex V).
- Microenterprises (fewer than 10 persons and ≤ EUR 2m turnover, Art. 3(23)) providing services are exempt (Art. 4(5)); microenterprises dealing in products get lighter documentation only (Art. 14(4)).
- EN 301 549 is again the practical bar: products and services conforming to OJ-listed harmonised standards are presumed conformant (Art. 15(1)) — the same standard family the Web Accessibility Directive uses.
- Even out-of-scope suppliers meet the EAA in procurement: Annex I requirements can be used to define accessibility criteria in Union-law procurement contexts (Art. 24 — not extracted; see scope note below).
Contents
| Document | Covers |
|---|---|
| SCOPE-AND-DEFINITIONS.md | Arts. 1–3 — subject matter, products/services in scope, definitions |
| OPERATOR-OBLIGATIONS.md | Arts. 4, 6, 7, 9, 10, 13; Annex V — the accessibility duty and manufacturer/importer/distributor/service-provider obligations |
| DEROGATIONS.md | Arts. 14, 15; Annex VI — fundamental alteration, disproportionate burden, presumption of conformity |
| CONFORMITY-AND-CE-MARKING.md | Arts. 16–18; Annex IV — EU declaration of conformity, CE marking, internal production control |
| ENFORCEMENT.md | Arts. 19, 20, 22, 23, 29, 30 — market surveillance, compliance of services, enforcement, penalties |
| APPLICATION-TIMELINE.md | Arts. 31, 32, 34, 35 — transposition, application from 28 June 2025, transitional measures |
| ANNEX-I-REQUIREMENTS.md | Annex I — the substantive accessibility requirements, all sections |
Scope note: the passenger-transport carve-outs (Art. 5), authorised representatives (Art. 8), operator identification (Art. 12), the Union safeguard procedure (Art. 21), accessibility under other Union acts (Arts. 24–25), delegation/committee/working-group machinery (Arts. 26–28), report and review (Art. 33), Annex II (indicative examples) and Annex III (built environment) can be added with the same tooling when needed.
Key obligations at a glance
- Products placed on the market after 28 June 2025 must meet Annex I Sections I–II; services provided after that date must meet Section III (plus their Section IV sector-specifics) (Art. 4(2)–(3), Art. 2).
- Manufacturers run the Annex IV conformity procedure, draw up the EU declaration and affix CE marking (Art. 7(1)–(2), Arts. 16–18); importers and distributors must check this happened (Art. 9, Art. 10).
- Service providers design and provide services per Annex I and publish Annex V information in their terms (Art. 13(1)–(2)).
- Requirements apply only to the extent they don't demand a fundamental alteration or impose a disproportionate burden — assessed against Annex VI, documented, kept five years, and (for services) reassessed at least every five years (Art. 14).
- Consumers can go to court or a competent administrative body over non-compliance, and bodies with a legitimate interest can act on their behalf (Art. 29(2)); penalties are national, must be "effective, proportionate and dissuasive" (Art. 30(2)).
Enforcement
Products: national market surveillance authorities under the Regulation (EC) No 765/2008 framework, with a non-compliance procedure and formal-non-compliance backstop (Arts. 19–22). Services: authorities designated by each Member State check compliance and follow up complaints (Art. 23). Member States must provide consumer court/administrative action including representative action (Art. 29) — though Art. 29 does not apply to procurement procedures under Directives 2014/24/EU and 2014/25/EU (Art. 29(3)) — and national penalties accompanied by effective remedial action (Art. 30). There is no EU-level fine regime.
Related
- Web Accessibility Directive — the public-sector companion: WAD binds schools' own websites/apps, the EAA binds what vendors place on the consumer market; both converge on EN 301 549.
- EU GDPR — accessibility information and interfaces regularly process personal data of users with disabilities (special-category in some contexts).
Sources
- EUR-Lex — Directive (EU) 2019/882 (European Accessibility Act), OJ text
- ETSI — EN 301 549 V3.2.1 (2021-03), "Accessibility requirements for ICT products and services" (PDF) — the standard family used for presumption of conformity; at the time of writing no harmonised standard for the EAA has been checked/pinned here — verify the OJ listing when this matters.
- European Commission — European Accessibility Act policy page
Meta
Article and annex text in the content documents is reproduced verbatim from the EUR-Lex OJ text (CELEX 32019L0882) and built/re-verified mechanically — see tools/eur-lex/build_eu_eaa.py (verify mode confirms every source paragraph appears verbatim; do not hand-edit article/annex text). The three corrigenda to the Directive concern the German, Estonian and Finnish language versions only (checked via Cellar RDF, 2026-09-06), so the English OJ text is authoritative. Anchors: official ELI ids ({#art_4}, {#anx_I}, valid as EUR-Lex HTML fragments) plus derived paragraph/point anchors from printed labels; annex points carry a section token because numbering restarts per section ({#anx_I-sIV-f}).