The European Accessibility Act | Fieldfisher
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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:

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

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.
Consequences
Restriction/prohibition of products/services, product recalls, fines, unfair competition and warranty claims.

By June 28, 2025, companies operating in the EU must comply with new accessibility standards or face legal and reputational risks.

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
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