EU: What CG&R companies need to know

in short

The European Accessibility Act (EAA) is a directive that aims to improve the accessibility of products and services for people with disabilities across the European Union (EU). It sets out common accessibility requirements for a variety of products and services offered to consumers to ensure that people with disabilities have better access to digital and physical environments, thereby promoting their inclusion and participation in society.

Companies typically have until June 28, 2025 to comply, and that date is coming soon! Sanctions for non-compliance vary from member state to member state and may even result in a prison sentence in some jurisdictions, as well as possible compliance injunctions/orders, fines and, of course, associated reputational harm.

The EAA will apply from June 28, 2025, with a transition period for limited circumstances. Given the lead time for implementing technological changes, we are already helping clients prepare to ensure compliance with the law. We particularly recommend:

• Analyze which of your products and services are in scope
• Assess current accessibility levels of physical products and digital interfaces
• Update e-commerce platform and website functionality (e.g., comply with WCAG standards) and include accessibility disclosures
• Update your store’s self-service and payment terminals
• Establish EAA product design standards
• Implement robust processes, controls and training programs

The European Accessibility Act (Directive 2019/882) is a landmark law requiring certain products and services in the EU to be accessible to people with disabilities. The EAA sets out specific accessibility requirements that must be met by various stakeholders, including manufacturers, authorized representatives, importers, distributors and service providers.

Types of services regulated by the Authority

The scope of the European Accessibility Act is broad and covers a wide range of products and services offered to consumers. These include e-commerce services, electronic communication services (excluding M2M services) and services providing access to audiovisual media. Additionally, EAA covers television devices, smartphones, desktops, laptops, tablets, banking services, e-books, and specialized software. The Authority’s requirements also include elements of passenger services and self-service terminals.

Exceptions

While the EAA sets forth strict accessibility standards, it does allow for certain exceptions. Stakeholders may rely on the fundamental change or disproportionate burden exceptions as long as they conduct a written assessment to justify these claims. However, we do expect that the ability to rely on these exceptions will be relatively limited in practice.

BM infographic

For more information about the legislation and to see a snapshot of where these provisions have been implemented, see the infographic here .

If you have any questions about EAA, please contact us or your usual Baker McKenzie contact.