EU regulation
European Accessibility Act: product requirements and evidence
Overview
Short answer
The European Accessibility Act, Directive (EU) 2019/882, sets accessibility requirements for specified products and services. It does not cover all electronics. Start with the product category, your role and the date of placing on the market. Products within scope require technical documentation, an EU declaration and CE marking. Art. 2, 7, 16-18.
Legal status
Law in force
Directive (EU) 2019/882 is in force. National implementing provisions apply from 28 June 2025, subject to specific transitional provisions. This EU overview does not replace checking national rules.
Part 1
Which products are covered?
The list includes consumer computers and their operating systems, payment terminals, certain other self-service terminals, certain interactive consumer terminal equipment and e-readers. Product provisions cover products placed on the market after 28 June 2025. Having a screen or internet connection does not by itself determine whether a product is covered. Art. 2.1.
Part 2
Separate product and service responsibilities
The manufacturer is responsible for product conformity assessment. Importers and distributors have their own verification duties. A service provider instead explains how the covered service meets accessibility requirements. One business may hold several roles. An online shop and a product sold through it therefore need not be covered on the same basis. Art. 7, 9-10, 13.
Part 3
Start with how the product is used
Annex I addresses information, instructions, user interfaces and interaction with assistive technologies. The applicable parts depend on the product. A practical approach is to examine how users perceive information, make choices and receive feedback. Record both implemented solutions and gaps that still require action. Art. 4; Annex I.
Part 4
Use the correct basis for exemptions
Microenterprises providing services are exempt under Article 4(5). There is no equivalent blanket product exemption. Fundamental alteration and disproportionate burden require assessment under Article 14. Documentation is the general rule; microenterprises dealing with products have a specific exemption from documenting the Article 14 assessment but must provide relevant facts when requested. Art. 4.5, 14.
Part 5
Build an understandable evidence trail
Technical documentation must allow assessment against the applicable accessibility requirements. Describe the product, adopted solutions and standards or technical specifications used. The manufacturer applies internal production control under Annex IV. Keep test results and change decisions clearly linked to the product version covered by the declaration. Art. 7; Annex IV.
Part 6
Transitions are not a blanket extension
Article 32 provides specific transitions for service providers using existing products and for existing service contracts. It does not let all new products wait until 2030. First identify the situation actually covered, then check how the relevant Member State has implemented the provision before relying on a transition. Art. 2, 31-32.
Checklist
Key takeaways
- Assess the product and the service separately.
- The main rules have applied since 28 June 2025.
- The microenterprise service exemption is not a general product exemption.
- Connect each applicable requirement to a solution and evidence.
Questions and answers
Frequently asked questions
Does the EAA cover all electronics?
No. Assess the product against the express list in Article 2(1). Art. 2.1.
Does a service receive CE marking?
The Directive’s CE provisions apply to products. Services have separate information and compliance duties. Art. 13,16-18.
Is a website check sufficient?
Not for a product assessment. Relevant hardware, interfaces and product information must also be covered. Annex I.
Can every older product be used until 2030?
There is no blanket rule. The transition covers specified service situations and must be read with its conditions. Art. 32.
How Verca helps
How Verca can support the process
Verca can connect product structure and documentation to the correct product version. This provides a shared place for the evidence behind an assessment and makes changes easier to follow. The company remains responsible for identifying applicable requirements, evaluating evidence and making product decisions. Verca platform description.