The European Accessibility Act

More than 87 million people in Europe, i. e. one in five Europeans, live with some form of physical, mental, intellectual or sensory disability. The European legislator therefore considered it important to establish EU-wide minimum requirements for accessibility to a range of products and services in order to contribute to the smooth functioning of the internal market and increase the social participation of people with disabilities in both the public and private sectors. This led to the adoption of the European Accessibility Act (Directive (EU) 2019/822, "EAA") which will have to be complied with starting 28 June 2025.

As an EU-Directive, the EAA has to be implemented by each Member State in its own legal system, leading to potential deviations between the applicable provisions throughout the Member States. A lot of businesses do not only operate in one European country but are active world- or Europe-wide. For such businesses, knowing about the differences in the Member States in the context of the implementation of EU-Directives usually represent a major challenge and a key aspect to achieve compliance.

Fieldfisher therefore founded the Fieldfisher EAA-Desk, connecting Fieldfisher experts across the European Union and the UK to provide cross-border advice on the EAA implementation. Our EAA-Desk includes the following dedicated team members from our jurisdictions:

Netherlands: Merel van Aar & Joanne Uiterwijk
Germany: Susanne Weckbach & Patrick Born
Luxembourg: Ingrid Dubourdieu & Eugenio Mancini
Italy: Diego Rigatti & Carolina Sutter
France: Marguerite Brac de la Perrière
United Kingdom: John Brunning & Aonghus Heatley
Spain: Carlos Perez Sans & Sonia Gracia
Belgium: Tim van Canneyt
Austria: Philipp Reinisch & Veronika Wolfbauer
Ireland: Feilim O'Caoimh

With this pan-European team, we are uniquely positioned to support our clients in navigating the diverse legal landscapes of EAA implementation.

Why choose our lawyers?

Our legal experts help businesses navigate the complexities of the EAA, ensuring compliance while optimising business potential. We assist clients with the analysis and implementation and advise on how to comply with the legal requirements of the EAA.

With our legal expertise and experience, we offer solutions that not only serve to ensure legal compliance and avoid sanctions, but also strengthen market perception. In doing so, we also draw on the expertise of our lawyers in other practice areas to provide comprehensive and holistic legal advice. In addition, we work with well-known service providers to advise on IT and design implementation.

Key contacts

Dr Susanne Weckbach

Partner, Commercial
Munich, Germany +49 (0)89 620 306 259 Email Dr Susanne

Automotive & Mobility

Chemicals

Commercial

Commercial and Distribution
Dr Patrick Viktor Born

Associate, Commercial
Munich, Germany +49 (0)89 620 306 240 Email Dr Patrick Viktor

Commercial

Commercial and Distribution
Merel van Aar

Associate, Data
Amsterdam, Netherlands +31202252225 Email Merel

Data and Privacy

Technology and Outsourcing

Technology and Privacy
Joanne Uiterwijk

Associate
Amsterdam, Netherlands +31615639028 Email Joanne

Dispute Resolution

Litigation

What companies need to watch out for:

Scope of application: Effective from 28 June 2025 for certain (consumer terminal) products (e.g. operating systems, payment terminals, ATMs, smartphones, tablets) and services, if provided B2C (e.g. telecommunications services, passenger transport services, banking services and e-commerce). There are transition periods in some cases.

Accessibility requirements: Products and services must be accessible and usable for people with disabilities with no external assistance. This means, for example, that information must be accessible via at least two senses (in particular hearing and sight).

Presumption of conformity: Companies should ensure that their products and services comply with harmonised standards and technical specifications, such as European harmonised standards. A presumption of conformity will then apply.

Exceptions: Micro-enterprises (less than 10 employees and less than EUR 2 million annual turnover/balance sheet) that provide services are exempt from the requirements. Further exemptions are possible in cases of disproportionality or if fundamental changes to the product/service would be necessary.