The European Union (EU) European Accessibility Act (Directive 2019/882) 2019, hereinafter referred to as the EAA, was adopted in April 2019 and entered into force on 28 June 2019. The EAA is a landmark piece of EU legislation designed to improve the accessibility of key products and services across the Union for people with disabilities and older adults. It seeks to create a more inclusive digital and built environment by removing existing barriers and preventing new ones, especially in areas like digital banking, transport, e-commerce, and communications technology. By doing so, the EAA aims not only to support independent living and equal participation but also to harmonise accessibility standards within the EU’s Single Market.
The Directive stipulated that the necessary legal and administrative changes among EU Member States to comply with the EAA must have been made by 28th June 2022. Three years later, as of 28th June 2025, the requirements of the EAA must now be fully implemented for relevant products and services. The three-year period between 2022 and 2025 has allowed Member States and industry stakeholders to prepare for full compliance. It aims to provide legislative authority at an EU level to enhance the functioning of the European Single Market and support the creation of accessible products and services for people with disabilities and older adults while removing many of the barriers of different national policies and rules among Member States, a mission that aligns with the goals of the ALL Institute. This is not a straightforward task and, oftentimes, legislative reforms and tangible real-world transformation can experience a significant disconnect from one another. As such, to mark this important milestone, this blogpost briefly explores the EAA and discusses its strengths and limitations.
The EAA was developed to remove barriers in the internal market and complement the Web Accessibility Directive (Directive 2016/2102) (WAD) 2016 which intended to make public sector websites, apps and organisations more accessible for people with disabilities. The EAA builds on the achievement of the WAD by extending accessibility requirements to the private sector. Specifically, it aims to harmonise requirements for certain products and services, including ATMs, ticket machines, e-books, banking services and public sector websites. Instead of prescribing specific technical solutions, the EAA emphasises a functional performance approach to accessibility and focuses on how products and services should be designed to enable users to perceive, operate and understand them. Compliance with the EAA is supported through the Harmonised European Standards such as EN 301 549 on ‘Accessibility Requirements for ICT Products and Services’ incorporating aspects of the Web Content Accessibility Guidelines (WCAG). The EAA is, assertedly, a social and market driven directive, embodying the principles of the EU’s Social Market Economy, by seeking to promote social inclusion while boosting economic potential by fostering the development of accessible goods and services on an interoperable and harmonised scale throughout Member States.
To illustrate what such change might look like in practice, consider an e-book platform: under the EAA, it must now offer text-to-speech functionality and navigable chapter structures, allowing visually impaired users to access literature independently. In the transport sector, a ticketing machine in a train station must be operable through tactile buttons and audible instructions, enabling a person with vision loss to purchase a ticket without assistance. These changes, though small in isolation, can dramatically shift daily experiences for people with disabilities.
However, efforts to achieve common accessibility in practice have been variable throughout the EU, and the challenge of creating an inclusive array of digital products and services that can be utilised across the spectrum of disability is undeniably significant. The EAA represents an important step in opening up digital accessibility, but this journey is far from over. Many more such steps of equal significance will need to be taken to build an accessible society, both in the built-environment and online, to accommodate and meet the hugely diverse array of needs of people with disabilities. As such, a particular criticism of the EAA is that it risks encouraging a compliance culture where the minimum legal requirements are met without engaging with the lived experiences and realities of service users. Indeed, the EAA entails a focus on mainstream market products and services, leaving people with disabilities who require specialist technologies at a disadvantage.
The European Disability Forum (EDF) and the European Network on Independent Living (ENIL) have expressed concerns that the EAA does not go far enough in improving general accessibility in areas of life such as buildings and public transport. To this end, in the absence of meaningful consultation with service users, companies might not feel a strong impulsion to do anything other than adopting minimum legal requirements for accessibility. Moreover, EU Member States have discretion in enforcement, and companies can invoke the “disproportionate burden” exemption if compliance is deemed to be too difficult or costly. This has raised concerns over the possibility for inconsistent implementation of the EAA throughout the EU.
While there can be no ‘one-size-fits-all’ solution to accessibility, it is clear that the EAA does not try to constitute itself as a silver bullet to all accessibility challenges. Rather, the EAA arguably represents an important legislative step forwards at the EU-wide level to shift baseline expectations in industry and government; incorporating and aligning the drive for accessible products and services with the principles of the European Social Market Economy. By integrating harmonised and interoperable accessibility standards throughout the EU and thereby raising the profile and public visibility of accessible designs in the built environment and in online platforms, it is hopeful that a cultural shift will occur in how accessibility is perceived and understood by society. Further, this shift in awareness may reinforce the willingness of public and private bodies to engage with people with disabilities as service users and listen to their guidance and feedback in the design and implementation of accessible products and services.
In summary, the EAA represents a welcome, necessary and long-overdue development as a stepping stone to a more inclusive society. While there are shortcomings and nuanced complexities that are inherent to the EAA, it incorporates an amalgam of legal authority and symbolic weight, arguably marking a historical turning point for accessibility standards for persons with disabilities in the EU. However, this will ultimately be determined by the effectiveness of its implementation, monitoring and evaluation in relation to real-world impact. The EAA must not be seen as an end in itself, but rather as a legal starting point for an accessible future that will hopefully lead to further improvements in accessibility. To avoid a situation where products and services incorporate minimal legal accessibility requirements only to render them technically accessible but practically exclusive, research bodies such as the ALL Institute, civil society and people with disabilities as leaders of change, must continue to play their role and monitor the implementation of the EAA to make note of successes and shortcomings, and build towards an accessible future for all.
Author: Matthew McKenna, PhD Researcher at Maynooth University’s Assisting Living and Learning (ALL) Institute, Research Funded through the Science Foundation of Ireland (SFI) Centre for Research Training in Advanced Networks for Sustainable Societies (ADVANCE CRT)
