European Accessibility Act, slowly moving forward
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Lo European Accessibility Act (EAA) has entered in application starting from from June 28, 2025. Even private organisations operating in the EU will now have to make their digital products and services accessible to people with disabilities.
Beyond the proclamations, accessibility and inclusion remain foreign concepts to the institutions of the Old Continent. Biblical implementation times, application asymmetries in the various member states, and a lack of consideration for essential products and services.
European Accessibility Act, introduction
La directive (EU) 2019/882 - known as European Accessibility Act, EAA – represents a step forward towards the social and economic inclusion of people with disabilities, thanks to the definition of new rights and standards for digital accessibility. This historic legislation, also with regard to biblical times of application:
- It is based on the Directive (EU) 2016/2102 on Web Accessibility, which mainly focused on the public sector, to ensure theaccessibility also in the private sector (so far exempted from the relevant obligations);
- introduces standards and harmonized norms, which the 27 member states of the European Union are required to faithfully implement. This is despite the broad discretion they have already demonstrated regarding the amount of the fines, which vary significantly from country to country.
EEA, scope of application
Responsible parties
The EAA applies to all service providers and retailers of goods and services to consumers in the EU, regardless of where their businesses are based, excluding micro-enterprises (< 10 employees and annual turnover < 2 million euros).
The Italy had already introduced some basic requirements regarding the accessibility of IT and telematic services of public administration and public utilities with the Stanca Law (Law no. 4/2000).
Protected products and services
The scope of the European Accessibility Act includes the following products and services, identified as most important for people with disabilities.
Physical products:
- ATMs and payment terminals;
- ticketing and check-in machines;
- self-service interactive terminals;
- consumer electronics with computing capabilities.
Digital services:
- websites and e-commerce platforms;
- banking services and applications;
- consumer electronics (smartphones, computers, tablets, TVs);
- e-books and e-book readers;
- ticketing and check-in services;
- audiovisual media services.
Telecommunications:
- telephone services and related equipment;
- access to audiovisual media services;
- emergency services (112)
Exemptions
In addition to the exemption provided for microenterprises, some contents are exempt:
- pre-recorded time-based media (e.g., videos) published before June 2025;
- third-party content that is not funded, developed, or controlled by an organization subject to the EAA;
- Archive content not intended for updates after June 2025.
Technical requirements and standards
Key accessibility standards
The technical basis of the EAA is based on accessibility standards internationally recognized:
- 301 549 – European standard that establishes detailed accessibility requirements for theInformation and Communication Technology (ICT). It covers web content, software and mobile applications, hardware (such as computers, ATMs, and self-service kiosks), electronic documents, and telecommunications services.
- WCAG 2.1 Level AA – a direct reference for the accessibility of websites, software, and digital documents. The Web Content Accessibility Guidelines (WCAG) 2.1 are already incorporated into the EN 301 549 standard, which defines the applicable technical requirements. The standard is being updated to support the implementation of the EAA.
Functional accessibility requirements
The main objective of the EAA is remove barriers to access for consumers with disabilities. To achieve this goal, the law outlines functional accessibility requirements, requiring organizations to ensure their digital experiences are perceivable, operable, understandable, and robust.
Key technical implementations include:
- speech synthesis capability;
- keyboard navigation support;
- screen reader compatibility;
- alt text for images;
- subtitles and audio descriptions for videos;
- consistent navigation and layout;
- clear headings and structure;
- sufficient color contrast.
EN 301 549, the additional requirements
While WCAG is primarily intended to support content creation website and furniture, 301 549 addresses accessibility for a wider range of information and communications technology (ICT) products and services.
Companies must evaluate their ICT products and services comprehensively, considering all aspects of EN 301 549, including: hardware design and functionality, accessibility of support services, including i call center, and documentation, including physical product manuals.
EEA, implementation timeline
June 28, 2022: deadline for transposition of Directive (EU) 2019/882 – European Accessibility Act, EAA – in the legal systems of the EU Member States.
June 28, 2025: deadline for the adaptation of all products and services made available on the EU market to the accessibility requirements defined by the directive.
June 28, 2030: deadline by which all products and services falling within the scope of the EAA – including existing ones – must comply with accessibility standards, regardless of their original release date.
Enforcement and sanctions
The European Accessibility Act (EAA) is a directive, whose provisions must be transposed into the national laws of all EU member states, within the established deadlines.
Member States are responsible for implementing the Directive in both respects:
- appointment of the body responsible for its application and supervision;
- definition of sanctions 'effective, proportionate and dissuasive' for failure to comply with the rules.
Financial sanctions
Penalties vary significantly among EU member states. Some examples follow.
Countries with high sanctions:
- Ireland and Austria. Both countries impose fines of up to €200.000 for non-compliance with the EAA;
- Finland and the Netherlands. Fines can reach €150.000 and €250.000, respectively;
- France. Penalties for non-compliance with French laws, including Référentiel Général d'Accessibilité pour les Administrations (RGAA), can reach 250.000 euros.
Countries with medium sanctions:
- Germany. German accessibility laws, including the BITV and the Disability Equality Act (BGG), provide for fines of up to €100.000;
- Czech Republic. Fines of up to €100.000, with possible additional costs for corrective actions imposed by authorities.
Countries with light sanctions:
- Belgium. Fines range from €1.000 to €50.000, with possible suspension of commercial operations in the event of repeat offenses;
- Croatia. Fines between €2.000 and €50.000. Persistent non-compliance could lead to public warnings and further legal action.
Additional sanctions
Violations of accessibility requirements may also lead, in addition to financial penalties, to additional administrative sanctions Which:
- suspension or blocking of the distribution of products and the provision of services in case of non-compliance, to free the market from inaccessible products and services;
- audit mandatory accessibility;
- public disclosure of the state of non-compliance (name and shame);
- daily fines for continuous violations, up to 1.000 euros per day.
Italy, Legislative Decree 82/2022
Italy has received it European Accessibility Act through Legislative Decree 27 May 2022 n. 82. Its distinctive elements follow.
Supervisory authorities
- AgID (Agency for Digital Italy) is the competent authority for the supervision of digital services and accessibility;
- MIMIT (Ministry of Enterprise and Made in Italy) is the competent authority for product surveillance;
- Coordination between institutionsAgID issues specific guidelines for the implementation of the EAA in Italy.
Temporary time
The Italian legislator has provided for a particularly flexible transitional regime:
- until the 28 June 2030: service providers may continue to provide their services using products that they were legitimately using before 28 June 2025;
- existing contracts: service contracts concluded before 28 June 2025 may continue as they are until 28 June 2030;
- products already on the market may continue to be marketed until June 28, 2030.
Sanctions
Legislative Decree 82/2022 establishes a specific sanctioning system for violations of the EEA:
- administrative fines ranging from 5.000 to 40.000 euros for failure to comply with accessibility requirements;
- additional fines from 2.500 to 30.000 euros for failure to cooperate or failure to comply with the authority's provisions;
- fines up to 5% of turnover for serious violations according to AgID;
- inhibitory measures such as website blocking, app removal from stores, and access to services;
- temporary or permanent ban of access to non-compliant digital services.
Opportunities and missed opportunities
In the European Union 101 million people, that is one in four people, over the age of 16, has a disability (Eurostat). In Italy, there are nearly 13 million people with disabilities, equal to approximately 22% of the Italian population.
The European legislator, however, has excluded from the scope of the European Accessibility Act key sectors such as Health (e.g. medical offices), education, construction and hospitality, means of transportation.
The lack of rules in the aforementioned sectors represents a chasm, rather than a legislative gap, compared to the declared objectives of ensuring afull accessibility across the essential domains of life.
Dario Dongo
References
- Business Disability Forum. (n.d.). The European Accessibility Act (EAA) – what businesses need to know and do. https://businessdisabilityforum.org.uk/resource/the-european-accessibility-act-eaa-what-businesses-need-to-know-and-do/
- Legislative Decree 27 May 2022, no. 82. Implementation of Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2022-05-27;82
- Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services http://data.europa.eu/eli/dir/2019/882/oj
- European Commission. (n.d.). European accessibility act. 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
- Italian Law 9 January 2004, n. 4 (so-called Stanca Law). Provisions to facilitate and simplify access to IT tools for users, particularly those with disabilities. Normattiva, latest update to the document published on 01/07/2022 https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2004-01-09;4!vig
- National Disability Authority. (n.d.). European Accessibility Act. https://nda.ie/accessibility/european-accessibility-act
- WCAG. (2024, November 20). European Accessibility Act (EAA) compliance checklist. https://www.wcag.com/compliance/european-accessibility-act/
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
