Who is in scope of the EAA

Directive (EU) 2019/882 applies to products and services offered to consumers in the EU, and became enforceable on 28 June 2025. The service categories most product teams encounter are:

E-commerce — any website or app selling goods or services to consumers
Consumer banking services, including online banking and payment terminals
Electronic communications services
Services providing access to audiovisual media
Passenger transport: websites, apps, ticketing and real-time travel information
E-books and dedicated reading software

Microenterprises providing services — fewer than 10 people and under €2 million annual turnover — are exempt from the service obligations. That exemption is narrower than most people assume, and it does not extend to products. Establishing which side of the line you sit on is the first deliverable of the programme.

An important caveat

The EAA is a directive, so what binds you is your national implementing law. Deadlines, enforcement bodies and penalties differ by Member State. We report technical conformance against the harmonised standard; we do not give legal advice. Have your counsel read our output alongside your national statute.

Phase 1 — Scoping (week 1)

We inventory your consumer-facing digital services, map each against the Annex I service categories, and produce a written scope determination. Where a service is arguably out of scope, we document the reasoning rather than leaving a gap that someone has to reconstruct later.

Phase 2 — Conformance assessment (weeks 2 to 4)

A full WCAG 2.2 AA audit of everything in scope, extended with the EN 301 549 clauses that go beyond WCAG: clause 5 generic requirements, clause 11 software, clause 12 documentation and support services, and clause 13 where ICT relay or emergency services apply. The output is a clause-by-clause table of supported / partially supported / not supported, which is the format enterprise procurement teams and enforcement bodies expect.

Phase 3 — Remediation planning (week 4)

We sequence the gaps into a plan your team can actually run: blockers first, grouped so that a single component fix closes several findings at once. Where you intend to claim disproportionate burden for a specific requirement, we help structure the assessment the directive requires — it is a documented, reasoned position, not a checkbox, and an undocumented claim is worse than none.

Phase 4 — Statement and verification (weeks 5 to 6)

We draft your accessibility statement in the EU model structure: conformance status, non-accessible content with reasons, feedback mechanism, and enforcement procedure. Then we retest to verify the remediation actually landed, so the statement you publish is accurate on the day it goes live.

An overstated statement is a compliance risk in its own right. We would rather publish “partially conformant, with these gaps and this timetable” and have it be true.

What you can show a regulator

At the end you hold: the scope determination, the conformance assessment with evidence, the remediation plan with dates, the disproportionate burden assessments if any, the verification retest, and the published statement. That is a complete record showing you identified your obligations and acted on them — which is the thing enforcement bodies actually ask for first.

EAA compliance programme

Included

Not included