Directive (EU) 2019/882
The European Accessibility Act — complete text of all 32 articles and 6 annexes. Plain-English explanations shown by default; click "Read verbatim text" to see the exact legal wording.
Articles 1–32
Article 1 — Subject matter
This article explains what the European Accessibility Act is trying to achieve. Its main goal is to make the EU single market work better by ensuring that accessibility requirements for products and services are consistent across all EU member states. When every country has the same rules, businesses only need to comply once and can sell across borders without facing different national accessibility laws. This also benefits disabled people, who can expect the same level of access to products and services wherever they are in the EU.
Article 2 — Scope
This article defines which products and services the EAA actually applies to. It covers a specific list of consumer-facing digital products (computers, self-service terminals like ATMs and ticket machines, phones and tablets used for communications, TV equipment) and services (electronic communications, audio-visual media services, passenger transport, banking, e-books, and e-commerce). Importantly, it also defines who is exempt: microenterprises providing services (fewer than 10 employees and annual turnover below €2 million) do not have to comply with service accessibility requirements, though product manufacturers of any size must still comply.
Article 3 — Definitions
This article contains the official legal definitions for all the key terms used throughout the directive. Understanding these is important for compliance: 'accessibility requirements' means what products and services must do; 'manufacturer' means the company that makes the product (which has the strictest obligations); 'service provider' means the company that offers the service; 'microenterprise' means fewer than 10 employees with annual turnover or balance sheet below €2 million; 'disproportionate burden' is an exemption that can apply when the cost of making something accessible would be genuinely unreasonable given the organisation's size and resources.
Article 4 — Accessibility requirements for products and services
This is the core obligation article. It states that all products and services within scope must meet the accessibility requirements set out in Annex I. Member states cannot block compliant products from being sold or compliant services from being provided across their borders. It also addresses the built environment — physical spaces used by customers of covered services (such as bank branches) must also meet accessibility standards set in Annex I. However, the built environment obligations only apply from 28 June 2030 and only where a fundamental alteration would not be required.
Article 5 — Obligations of manufacturers
Manufacturers are companies that make physical products covered by the EAA (computers, ATMs, payment terminals, e-readers, etc.). This article sets out their responsibilities: they must design and manufacture their products to meet the accessibility requirements, draw up technical documentation to prove it, carry out a conformity assessment, sign an EU Declaration of Conformity, and affix the CE marking. They must also keep records for 5 years after a product is placed on the market, and if they have reason to believe their product is not compliant, they must take corrective action immediately.
Article 6 — Authorised representatives
If a manufacturer is based outside the EU, they can appoint an authorised representative inside the EU to act on their behalf. This article defines what that relationship must look like: the mandate must be in writing and must specify the tasks the representative is authorised to carry out. The representative acts as the primary point of contact for EU authorities and takes on the manufacturer's obligations for the tasks specified.
Article 7 — Obligations of importers
Importers are companies that bring products from outside the EU into the EU market. This article requires importers to check that manufacturers have done their job properly before the importer sells the product. The importer must verify that the manufacturer has carried out the conformity assessment, drawn up the technical documentation, and affixed the CE marking. If an importer has reason to believe a product doesn't comply, they must not place it on the market until it is brought into compliance.
Article 8 — Obligations of distributors
Distributors are retailers and wholesalers — companies that sell products that others have manufactured or imported. This article requires distributors to act with due care to ensure the products they sell actually comply with the EAA. Before making a product available, a distributor must check that it bears the CE marking, has the required documents, and that the manufacturer and importer have met their obligations. If a distributor finds a product is not compliant, they must not sell it.
Article 9 — Cases where obligations of manufacturers apply to importers and distributors
This article closes a potential loophole. If an importer or distributor places a product on the market under their own name or trademark, or modifies a product already on the market, they become treated as the manufacturer and take on all the manufacturer's legal obligations — including technical documentation, conformity assessment, and CE marking.
Article 10 — Identification of economic operators
Market surveillance authorities need to be able to trace products back through the supply chain when investigating compliance issues. This article requires manufacturers, importers, and distributors to be able to identify who supplied a product to them and who they supplied it to, for a period of five years after placing it on the market. This traceability requirement means businesses must keep adequate records of their supply chains.
Article 11 — Presumption of conformity of products and services
Products and services that comply with harmonised European standards (EN standards) or with common technical specifications published by the European Commission are presumed to meet the EAA accessibility requirements covered by those standards. This is a safe harbour: if a harmonised standard exists for your product type and you comply with it, regulators presume your product meets the law without needing further proof.
Article 12 — Common technical specifications
Where no harmonised standard exists, the European Commission can publish common technical specifications (CTS) — essentially official technical rules that define how to meet the accessibility requirements. Products and services that comply with a CTS are also presumed to meet the EAA accessibility requirements covered by it. The EN 301 549 standard is the primary harmonised standard referenced for most EAA requirements.
Article 13 — European accessibility standard for built environment
This article instructs the European Commission to ask European standardisation bodies (like CEN/CENELEC) to develop a harmonised standard for the accessibility of the built environment — the physical spaces used by customers of covered services, such as bank branches. Until such a standard is available, member states can use their own national standards.
Article 14 — Obligations of service providers
Service providers (companies offering services covered by the EAA — banking, e-commerce, transport, communications, media) must ensure their services meet the accessibility requirements in Annex I. They must prepare the necessary information explaining how their services meet the requirements and make this information publicly available. If a service doesn't fully comply, they must provide accessible alternatives where possible. The information about accessibility must be provided in writing and in a manner accessible to persons with disabilities.
Article 15 — Fundamental alteration and disproportionate burden
This article provides two types of exemption. First, a 'fundamental alteration' exemption: if meeting an accessibility requirement would fundamentally change the nature of a product or service, that requirement doesn't apply. Second, a 'disproportionate burden' exemption: if the cost of complying with a specific requirement is disproportionate to its benefit given the organisation's size and resources, that specific requirement may be waived. Crucially, this is not a blanket exemption — it must be assessed requirement by requirement, documented formally, reviewed annually, and notified to the relevant national authority. The burden must be genuinely disproportionate, not merely inconvenient.
Article 16 — EU declaration of conformity for products
The EU Declaration of Conformity (DoC) is the formal legal document in which a manufacturer states that their product meets all applicable EU requirements, including EAA accessibility requirements. This article defines what it must contain: identification of the product, references to the applicable standards or technical specifications, the manufacturer's name and address, and a signature by a named person with legal authority. The declaration must be available in the language(s) of the countries where the product is sold.
Article 17 — CE marking
The CE marking (the letters CE) is the mark that a manufacturer places on a product to declare that it meets all applicable EU requirements, including accessibility requirements. This article establishes that CE marking applies to physical products covered by the EAA. It must be affixed by the manufacturer before the product is placed on the market, must be visible and legible, and must not be misleading. Only manufacturers may affix the CE marking; it cannot be awarded by third parties.
Article 18 — Conformity assessment procedures for products
This article defines how manufacturers must demonstrate that their product meets the EAA accessibility requirements. For most EAA-covered products, the conformity assessment is carried out by the manufacturer themselves (this is called a 'Module A' self-assessment — described in Annex III). There is no requirement for an independent third-party certification body to be involved, unlike some other EU directives.
Article 19 — Technical documentation
The Technical File (or Technical Documentation) is the dossier of evidence that proves a product meets the EAA requirements. This article defines what must be in it: a general description of the product, the accessibility requirements it must meet, the design solutions used to meet them, the harmonised standards applied, and the results of the conformity assessment. The Technical File must be available for at least five years after the product is placed on the market.
Article 20 — Requirements for technical documentation for services
Service providers (not manufacturers) must also maintain documentation demonstrating how their service meets EAA accessibility requirements. This is the service equivalent of the manufacturer's Technical File. The documentation must describe the service, the applicable accessibility requirements, how those requirements are met, and any disproportionate burden assessments.
Article 21 — Notification of conformity assessment bodies
Although most EAA conformity assessments are self-assessments by the manufacturer, some product types may require assessment by an approved third-party body. This article requires member states to designate and notify to the European Commission any conformity assessment bodies they authorise to operate. This notification process ensures that such bodies are competent, independent, and publicly accountable.
Article 22 — Notification procedure
This article sets out the formal process by which member states notify the European Commission of their designated conformity assessment bodies. It establishes the technical system (the NANDO database) and the information that must be provided about each notified body, including its scope of competence and accreditation evidence.
Article 23 — Requirements for notified bodies
Notified bodies — the third-party organisations authorised to carry out conformity assessments — must meet strict independence and competence requirements. This article sets those out: they must be independent of the manufacturers they assess, their staff must be technically competent, they must be impartial, and they must carry professional liability insurance. They cannot carry out activities that would compromise their independence.
Article 24 — Subsidiaries and subcontracting by notified bodies
Notified bodies may subcontract specific technical tasks or use subsidiaries, but they remain fully responsible for the overall conformity assessment. If a notified body subcontracts, it must ensure the subcontractor is competent, inform the client in advance, and take full legal responsibility for the outcome.
Article 25 — Changes to notifications
If anything changes about a notified body — its scope, its competence, or the types of conformity assessment it is authorised to carry out — it must update its notification with the relevant national authority, which in turn updates the European Commission. Member states can also suspend or withdraw a notification if a notified body no longer meets the requirements.
Article 26 — Challenge of the competence of notified bodies
The European Commission has the power to investigate whether a notified body actually meets the required standards. If the Commission has concerns, it can ask the member state to investigate and take corrective action. This ensures there is EU-level oversight of national conformity assessment systems.
Article 27 — Operational obligations of notified bodies
Notified bodies must carry out conformity assessments in a consistent, proportionate, and non-discriminatory way. They must maintain records of all assessments and keep them available for regulatory inspection for ten years. They must cooperate with market surveillance authorities and with other notified bodies to ensure consistent application of assessment standards across the EU.
Article 28 — Appeal against decisions of notified bodies
Economic operators have the right to appeal against decisions made by notified bodies during the conformity assessment process. Member states must ensure there are accessible appeal procedures available. This is an important safeguard: if a manufacturer disagrees with a notified body's finding that their product doesn't comply, they can challenge it.
Article 29 — Information obligations of notified bodies
Notified bodies must share certain information with their national authorities and with the European Commission. This includes information about refused or withdrawn certificates, details of circumstances where corrective actions were required, and situations where market surveillance authorities have asked for information. This transparency ensures the notification system functions effectively.
Article 30 — Exchange of experience
The European Commission must facilitate the exchange of experience between member states' national authorities on policy and regulatory matters related to the EAA. This coordination ensures consistent enforcement across the EU and allows member states to share lessons learned from their enforcement activities.
Article 31 — Coordination of notified bodies
The European Commission must ensure that appropriate coordination and cooperation between the notified bodies operating under this Directive is put in place and properly run at Union level. Notified bodies must participate in such coordination to ensure consistency in how they apply conformity assessment standards.
Article 32 — Market surveillance, control of products, and safeguard procedures
This article establishes that each EU member state must set up market surveillance — national authorities empowered to check whether products on the market actually meet EAA requirements. These authorities can inspect products, request documentation, order corrective action, and in serious cases require products to be withdrawn from the market. When a member state takes action against a non-compliant product, it must inform the European Commission and other member states through the RAPEX system.
Annexes I–VI
Annex I — Accessibility requirements for products and services
Annex I is the most important part of the EAA. It sets out the actual accessibility requirements that products and services must meet. It is divided into sections: Section I covers general requirements applicable to all products, Section II covers self-service terminals, Section III covers consumer terminal equipment, Section IV covers e-readers, Section V covers services (broken into: general service requirements; electronic communications; audiovisual media; passenger transport; banking; e-books; e-commerce), and Section X covers the built environment. The requirements are expressed as functional outcomes — what users must be able to do — rather than prescriptive technical rules. The EN 301 549 standard provides the technical implementation of these requirements.
Annex II — Indicative non-exhaustive list of products and services
Annex II provides an illustrative (not complete) list of everyday products and services that are expected to benefit from the harmonisation of accessibility requirements under the EAA. It includes examples like computers, smartphones, tablets, ATMs, ticket machines, televisions, e-readers, telephony equipment, banking websites, transport booking services, and streaming platforms. This list helps businesses understand whether they are likely to be in scope, but the definitive scope is defined by Article 2.
Annex III — Conformity assessment procedure (Module A)
Annex III describes the conformity assessment procedure — Module A, or 'internal production control'. This is the process manufacturers must follow to demonstrate that their products comply with EAA accessibility requirements. Unlike some EU product legislation that requires third-party certification, Module A is a self-assessment: the manufacturer themselves conducts the assessment, prepares the technical documentation, signs the EU Declaration of Conformity, and affixes the CE marking. No independent testing body needs to be involved unless the product falls into a category where a stricter conformity procedure is required.
Annex IV — EU Declaration of Conformity
Annex IV provides the official template for the EU Declaration of Conformity — the legal document manufacturers must produce and sign to declare that their product meets EAA requirements. The declaration must include: the product name and model number; the manufacturer's name and address; a statement that the product meets the applicable EAA accessibility requirements; references to any harmonised standards or technical specifications used; and the signature of a named person acting on behalf of the manufacturer. The declaration must be translated into all languages of the countries where the product is sold.
Annex V — Criteria for the assessment of disproportionate burden
Annex V lists the specific factors that must be considered when assessing whether an accessibility requirement would create a 'disproportionate burden'. The assessment must weigh the costs and benefits of compliance, taking into account: the organisation's size and annual turnover; the estimated cost of the accessibility measures; the expected lifespan of the product or service; the benefit to persons with disabilities; and the frequency of use. This is not a free pass — the assessment must be documented formally, be kept on file, and reviewed annually. Claiming disproportionate burden without a documented assessment is not valid.
Annex VI — Quality framework for service providers
Annex VI requires service providers to implement a quality framework to ensure their services remain accessible on an ongoing basis. It is not enough to be compliant at one point in time; accessibility must be maintained as services evolve. The quality framework must include: regular monitoring of accessibility; a process for receiving and responding to feedback from users with disabilities; periodic assessment of whether the service still meets requirements; and continuous staff training on accessibility. This ongoing commitment is what distinguishes genuine accessibility compliance from a one-time audit exercise.
Important Legal Disclaimer
This tool is a self-assessment aid only and does not constitute legal advice or a formally certified compliance assessment. Outputs — including reports, scores, checklists, and accessibility statements — are for internal use and should be reviewed by a qualified legal representative or independent accessibility auditor before being relied upon for regulatory, procurement, or public-disclosure purposes. All assessment risk lies with the internal assessor. accessibilityref, its developers, and staff accept zero liability for losses arising from use of or reliance on these outputs. Always verify against official sources: the W3C WCAG 2.2 Recommendation, the European Accessibility Act (Directive 2019/882), and your national enforcement authority.