Harmonised Standards under the European Accessibility Act: An Introduction
Locations
Austria, Belgium, France, Germany, Ireland, Italy, Luxembourg, Netherlands, Spain
As of 28 June 2025, certain digital products placed on the market and/or digital services provided to consumers must comply with the European Accessibility Act (EAA). Non-compliance could lead to severe consequences, such as hefty fines, recalls, prohibitions, legal action and/or reputational damage. Read more about the specific consequences of non-compliance in several EU member states via the following link.
The million-dollar question in this respect is: how do economic operators, such as manufacturers and service providers, become EAA-compliant? The EAA sets out the accessibility requirements for digital products and services in Annex I and provides examples of possible solutions in meeting the accessibility requirement in Annex II. It does not, however, provide for a standard to determine whether economic operators are compliant. Instead, the EAA stipulates that products and services that are in conformity with harmonised standards shall be presumed to be in conformance with the accessibility requirements under the EAA.
Harmonised standards in general
Harmonised standards are European standards developed by recognised European Standards Organisation (i.e. CEN, CENELEC, or ETSI) following a request from the European Commission. Economic operators may use these harmonised standards to show that their services and products are compliant with relevant EU legislation. Applying these standards is, however, voluntary, meaning that economic operators may choose other technical solutions to show compliance with the mandatory legal requirements.
Relevant standards for the EAA
The European Commission requested the establishment of 3 new harmonised standards in support of the EAA: (i) harmonised standard(s) setting up requirements on the accessibility of non-digital information related to products; (ii) harmonised standard for the accessibility of support services related to products and services; and (iii) harmonised standard for the accessibility and interoperability of emergency communications and for the answering of emergency communications by the public safety answering point.
It also requested the revision of 3 existing harmonised standards: (i) EN 301 549 Accessibility requirements for ICT products and services; (ii) EN 17161:2019 Design for All - Accessibility following a Design for All approach in products, goods and services - Extending the range of users; and (iii) EN 17210 Accessibility and usability of the built environment - Functional requirements. In the following, we will take a brief look at EN 301 549.
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Subscribe nowRevision of EN 301 549
The EN 301 549 standard is a harmonised standard developed in relation to EU legislation concerning the accessibility of websites and mobile applications of public sector bodies. This standard incorporates the Web Content Accessibility Guidelines (WCAG) – a guideline that specifically focuses on the accessibility of web and mobile content (i.e. information such as text, images and sounds, but also code). The WCAG has three levels of success criteria for determining conformance: level A, level AA and level AAA and is based on the following 4 principles:
- Perceivable – Ensure that users can see and hear the content of your website, for example by providing images with text alternatives or subtitles for deaf people.
- Operable – Enable users to operate the website with aids other than a mouse, e.g. by ensuring that the entire website can be operated using a keyboard.
- Understandable – Make information on your website understandable for people and software, for instance by ensuring that the website has a consistent structure.
- Robust – Build the website in such a way that it is compatible with different devices and assistive technologies.
The EN 301 549 standard is, however, broader than web and mobile content and can be applied to software, hardware and any combinations thereof. As mentioned, it is currently being revised to cater to the EAA.
Deadlines standards
The initial deadlines for the adoption of the harmonised standards mentioned above are as follows:
- Harmonised standard(s) setting up requirements on the accessibility of non-digital information related to products – 15 March 2026.
- Harmonised standard for the accessibility of support services related to products and services – 15 March 2026.
- Harmonised standard for the accessibility and interoperability of emergency communications and for the answering of emergency communications by the public safety answering point – 15 January 2027.
- EN 301 549 Accessibility requirements for ICT products and services – 15 September 2025.
- EN 17161:2019 Design for All - Accessibility following a Design for All approach in products, goods and services - Extending the range of users – 15 September 2025.
- EN 17210 Accessibility and usability of the built environment - Functional requirements – 15 September 2025.
These deadlines show that, even though the EAA becomes effective starting 28 June 2025, the harmonised standards which can be used to demonstrate conformity are not even close to crossing the finish line. In addition, it has already become clear that, for example, the EN 301 549 standard will only be finalised somewhere in 2026, leaving economic operators in uncertainty for quite some time.
If you would like to discuss navigating the EAA landscape (prior to the adoption of the harmonised standards) and how our specialists could help, please contact Joanne Uiterwijk, Patrick Born or your usual Fieldfisher representative. We'd be delighted to help.
More general information about the EAA can be found via the following landing page.
