The European Accessibility Act requires specified consumer products and services to be accessible to people with disabilities. It applies to covered products placed on the market and covered services provided to consumers after 28 June 2025.
For a software company, the decisive question is not simply whether it has a website or mobile app. The Act covers listed consumer services—including e-commerce, consumer banking, electronic communications, e-books, audiovisual-media access and specified passenger-transport interfaces—and the digital channels used to provide them. A strictly business-to-business SaaS service does not become an EAA e-commerce service merely because it has a public marketing website.
Key dates
| Date | Milestone |
|---|---|
| 28 June 2022 | EU Member States' transposition deadline. |
| 28 June 2025 | The EAA began to apply to covered services provided to consumers and covered products placed on the market. Sweden's implementing law also entered into force. |
| 28 June 2030 | Long-stop date for qualifying pre-28 June 2025 service contracts to continue unchanged. It is also the end of the general transition for services using products lawfully used before application. |
Sweden implemented the directive through Lag (2023:254) om vissa produkters och tjänsters tillgänglighet, commonly called the accessibility law or LPTT, and Förordning (2023:676). PTS issued complementary rules for covered products and services.
Which services are covered?
The EAA applies to these services when they are provided to consumers after 28 June 2025:
Electronic communications services, except transmission services used for machine-to-machine services
Services providing access to audiovisual media services
Websites, mobile apps, e-tickets, ticketing and travel-information elements of specified air, bus, rail and water passenger transport
Consumer banking services
E-books and dedicated software
E-commerce services
It also covers answering emergency communications to the European emergency number 112.
An e-commerce service is a service provided at a distance, through websites or mobile-device services, electronically and at the individual request of a consumer, with a view to concluding a consumer contract. A brochure-style website, documentation site or B2B lead form is not automatically an e-commerce service. A consumer checkout, subscription purchase, booking flow or comparable contract journey can bring the relevant digital service into scope.
The legal assessment should identify both the listed service and the consumer relationship. Calling a product “SaaS”, “platform” or “marketplace” does not answer either question.
Which products are covered?
The product rules apply to specified consumer products placed on the market after 28 June 2025:
General-purpose consumer computer hardware systems and their operating systems
Payment terminals
ATMs, ticketing machines, check-in machines and interactive information terminals used for covered services
Consumer terminal equipment with interactive computing capability used for electronic communications
Consumer terminal equipment used to access audiovisual media services
E-readers
Manufacturers, authorised representatives, importers and distributors have role-specific duties. Product conformity includes technical documentation, an EU declaration of conformity and CE marking. The microenterprise service exemption does not remove product duties.
What must an accessible digital service do?
The EAA's detailed requirements are in Annex I and in national implementing measures. For covered digital services, the design and operating model should address at least:
Accessible information. Information about the service and how it works must be available through more than one sensory channel, be understandable and perceivable, and use appropriate text, contrast, spacing and alternatives for non-text content.
Accessible websites and apps. Digital interfaces must be perceivable, operable, understandable and robust, including when used with assistive technologies.
Accessible support. Help desks, call centres, technical support, relay services and training services offered with the covered service must provide accessibility information and communicate accessibly.
Accessible transactions. E-commerce services must make identification, security, payment and electronic-signature functions perceivable, operable, understandable and robust.
Product information in commerce. E-commerce providers must surface available accessibility information supplied by the responsible economic operator for products and services they sell.
Ongoing conformity. Providers must account for changes to the service, the applicable requirements and any standards or technical specifications used to demonstrate conformity.
The requirements are functional and extend beyond visual web-page checks. Keyboard operation, screen-reader semantics, focus behavior, error identification, authentication, payment, documents, support channels and the accessibility of the complete consumer journey all matter.
What information must a service provider publish?
Article 13 and Annex V require a provider to explain how its covered service meets the applicable accessibility requirements. The information must:
Describe the service in accessible formats
Include explanations needed to understand how it operates
Describe how the applicable Annex I requirements are met
Be available to the public in written and oral form, including in an accessible manner
Be retained for as long as the service operates
The directive anticipates this conformity information appearing in the general terms and conditions or an equivalent document. This is more than a generic commitment to accessibility: it should describe the covered service and the measures used to meet its applicable requirements.
If a service becomes non-conforming, the provider must take corrective action and immediately inform the competent authorities in the Member States where the service is provided, including details of the non-conformity and corrective measures.
Does WCAG compliance prove EAA compliance?
Not by itself.
WCAG is an important engineering baseline for web content, and EN 301 549 contains broader ICT accessibility requirements that draw heavily on WCAG. However, EN 301 549 v3.2.1 is harmonised for the Web Accessibility Directive, which covers public-sector websites and apps. It was being revised under the EAA standardisation mandate and, as of 15 August 2026, should not be presented as an EAA-specific harmonised standard that automatically confers the Article 15 presumption of conformity.
An EAA presumption of conformity attaches only to the extent a product or service follows a harmonised standard or technical specification whose reference has been published for the directive in the Official Journal of the EU. Until an applicable reference covers the requirement, the economic operator must demonstrate conformity directly against the directive and national implementing rules.
In practice, test against WCAG and the relevant parts of EN 301 549, but also maintain an EAA requirement map covering transactions, support services, accessibility information and any product-specific duties. Passing an automated WCAG scanner is not evidence that the complete service conforms.
Are microenterprises exempt?
Microenterprises providing covered services are exempt from the EAA accessibility requirements and the obligations connected to those requirements.
A microenterprise employs fewer than 10 people and has annual turnover or an annual balance-sheet total not exceeding €2 million. Apply the EU SME calculation rules, including linked and partner enterprises where relevant; do not decide the exemption from the headcount of one legal entity alone.
The exemption is service-side. A microenterprise dealing with covered products is not generally exempt. Instead, it receives narrower administrative relief: if it invokes fundamental alteration or disproportionate burden, it does not have to document that assessment in advance, although it must provide relevant facts if the market-surveillance authority requests them.
Reassess status when headcount, finances or group relationships change. Voluntary accessibility remains valuable even where the exemption applies, and other laws—including anti-discrimination rules or public-sector accessibility requirements—may create separate duties.
Can a provider claim disproportionate burden?
Accessibility requirements apply only to the extent that compliance would not fundamentally alter the basic nature of the product or service and would not impose a disproportionate burden.
This is an evidence-based exception, not a general cost defence. An economic operator relying on it must assess the criteria in Annex VI, document the assessment and normally retain the results for five years. It must notify the relevant authority. A service provider relying on disproportionate burden must renew the assessment when the service changes, when the authority requests it, and at least every five years.
The exception cannot be used where the operator receives external public or private funding specifically intended to improve accessibility. Partial burden does not justify abandoning every requirement: comply with the requirements that do not create the established fundamental alteration or disproportionate burden.
What are the transition rules?
The EAA is not a blanket grace period until 2030.
A service contract agreed before 28 June 2025 may continue without alteration until it expires, but no later than 28 June 2030.
During the transition ending 28 June 2030, service providers may continue providing similar services using products they lawfully used before 28 June 2025.
Member States may allow pre-application self-service terminals to remain in use until the end of their economically useful life, capped at 20 years after first use.
New covered services, materially changed contract arrangements and products placed on the market after the application date require a current assessment. Record the contract date, expiry, changes and any legacy equipment relied upon.
Which website and app content is excluded?
The directive excludes specified content from its website and mobile-app rules, including:
Pre-recorded time-based media published before 28 June 2025
Office file formats published before that date
Online maps where essential navigation information is provided accessibly in digital form
Third-party content not funded, developed by or under the control of the economic operator
Genuine archives that are not updated or edited after 28 June 2025
These are content-specific exclusions, not exemptions for the surrounding service. A live transaction, account or support journey remains subject to its applicable requirements.
Swedish enforcement
In Sweden, PTS is the market-surveillance authority for every covered product. It also supervises electronic communications services, banking services and e-commerce services.
Other service authorities include:
| Service area | Swedish authority |
|---|---|
| Access to audiovisual media services | Mediemyndigheten |
| Passenger-transport websites, apps and electronic tickets | Konsumentverket |
| Passenger travel information and interactive self-service terminals | Transportstyrelsen |
| E-books | Myndigheten för tillgängliga medier |
PTS also has a coordination role where a matter crosses supervisory areas. Digg's supervision under the separate DOS law concerns public-sector websites and apps; it should not be confused with LPTT supervision of the listed consumer products and services.
A practical applicability check
Ask these questions in order:
Is the offering one of the listed products or services? Map the exact category rather than assuming every digital business is covered.
Is the service provided to consumers? Record who can contract, buy, subscribe or book and whether a consumer journey exists.
Is there e-commerce? Identify the website or app flow through which a consumer contract is concluded.
Does the date rule apply? Record when the service is provided, the product is placed on the market, and any legacy contract or equipment relied upon.
Is the provider a microenterprise? Calculate employees, turnover or balance sheet, and linked or partner enterprise data.
Which national rules apply? Identify each Member State where the service is provided and the competent authority.
What evidence proves conformity? Map Annex I and national requirements to design, code, manual tests, assistive-technology tests, support processes and public conformity information.
Is an exception claimed? Document fundamental alteration or disproportionate burden against the legal criteria and reassessment timetable.
Digital-service readiness checklist
Inventory every consumer-facing website, app, checkout, account, payment and support journey.
Map each covered service to Annex I and the applicable Swedish rules.
Test with keyboard-only navigation, screen readers, magnification, voice control and high-contrast settings.
Include authentication, security, electronic signatures, payment, errors and recovery in testing.
Test documents, email, chat, telephone and help-centre content, not only web pages.
Publish accessible conformity information describing how the service meets the requirements.
Establish regression gates and manual assistive-technology testing for material releases.
Create a process to report non-conformity and corrective measures to the competent authority.
Record microenterprise calculations and review them when the organisation changes.
Document any transition or burden exception with dates, evidence, scope and re-review triggers.
Related briefings
WCAG overview — technical web criteria and the separate public-sector legal route
B2B SaaS SME profile — a common false-positive archetype and the microenterprise assessment
This briefing explains the official sources reviewed on 15 August 2026. It is not legal advice; confirm product- and service-specific conclusions against the current national rules.