The European Accessibility Act: What Every EU Employer Needs to Know by June 2025
What Is the EAA?
The European Accessibility Act (Directive 2019/882) is an EU directive requiring accessibility of specified products and services placed on the EU market. Member states had until 28 June 2022 to transpose it into national law, with compliance required from 28 June 2025.
While the EAA primarily regulates products and services sold to consumers, it has profound implications for employers because the same products and services are used in workplaces.
What the EAA Covers
Products
Computers and operating systems: All hardware and software must meet accessibility requirementsSmartphones and tablets: Must be usable by people with sensory, cognitive, and motor impairmentsSelf-service terminals: ATMs, ticketing machines, check-in kiosks, and โ critically โ any self-service terminal in a workplace (canteen kiosks, meeting room booking screens, time-clock terminals)E-readers: Must support accessible formatsConsumer equipment for telecommunications: Phones, video calls, messagingServices
E-commerce: Online shops and marketplaces must be accessibleBanking services: Online banking, ATMs, payment terminalsTelecommunications: Phone services, messaging, video callsTransport: Websites, apps, ticketing, real-time informationAudiovisual media services: Streaming platforms, digital TVE-books: Digital publications must support accessibility featuresThe Workplace Connection
Every product and service listed above is used in workplaces:
Employees use computers and smartphones dailyMany workplaces have self-service terminals (canteens, meeting rooms, security)HR and payroll are increasingly e-commerce style platformsInternal banking and expenses processes are digitalWorkplace telecommunications (Teams, Zoom, phone systems) must be accessibleTraining is increasingly delivered as audiovisual/e-learning contentAccessibility Requirements
The EAA specifies functional accessibility requirements based on the European Standard EN 301 549 (which incorporates WCAG 2.1 for web content):
Key Requirements
Perceivable: Information must be presentable in ways all users can perceive - Text alternatives for images
- Captions for audio/video
- Sufficient colour contrast
- Content resizable without loss of function
Operable: Users must be able to operate the interface - Keyboard accessibility (all functions reachable without a mouse)
- Sufficient time to complete tasks
- No content that triggers seizures
- Clear navigation and consistent interfaces
Understandable: Information and interface must be understandable - Readable text (clear language, logical structure)
- Predictable behaviour
- Input assistance (error prevention and correction)
Robust: Content must be compatible with assistive technologies - Screen reader compatibility
- Voice control support
- Alternative input device support
Product-Specific Requirements
Self-service terminals: Must have speech output, tactile indicators, large text options, hearing loop compatibility, and be reachable from a wheelchairComputers: OS must include built-in accessibility features (screen reader, magnification, high contrast, voice control)What Employers Must Do
1. Audit Workplace Technology
By June 2025, assess whether workplace systems comply with EAA requirements:
Self-service terminals: Do canteen kiosks, meeting room screens, and time clocks meet accessibility requirements? (Most currently do not.)HR systems: Can your HRIS, payroll, and benefits platforms be operated by screen reader? Keyboard only? With voice control?Learning platforms: Are e-learning modules captioned? Do they work with assistive technology?Communication tools: Do your video conferencing, messaging, and phone systems support accessibility features?Intranet: Does your corporate intranet meet WCAG 2.1 AA?Document management: Are standard templates accessible? Can documents be read by screen readers?2. Procurement Policy
Update procurement policies to require EAA compliance:
New purchases: All new technology, systems, and services must meet EN 301 549Vendor assessment: Include accessibility requirements in RFPs and vendor evaluation criteriaVPAT/ACR: Request Voluntary Product Accessibility Templates from all technology vendorsContract clauses: Include accessibility compliance as a contractual requirement with remediation obligationsRenewals: When existing contracts renew, add accessibility requirements3. Remediate Existing Systems
For systems that cannot be immediately replaced:
Prioritise by impact: Focus first on systems used daily by many employees (HR, email, intranet)Alternative access: Where a system cannot be made accessible, provide an accessible alternative pathwayTimeline: Create a remediation roadmap โ the EAA allows a transition period for existing products/services until June 2030Budget: Allocate specific budget for accessibility remediation4. Build Internal Capability
Accessibility expertise: Hire or train staff in digital accessibility (IAAP certification available)Developer training: All in-house developers trained in accessible developmentTesting: Regular accessibility testing of workplace systems (automated + manual + user testing)Governance: Assign accountability for workplace accessibility complianceEnforcement
National Market Surveillance
Each member state designates a market surveillance authorityAuthorities can inspect products and services, request evidence of compliance, and take enforcement actionNon-compliant products can be withdrawn from the marketFines: Set by each member state โ expected to be substantialEmployee Rights
The EAA strengthens the case for reasonable accommodation claims: - If accessible technology exists (because the EAA requires it), employers cannot argue that accessibility is "unreasonable"
- "We couldn't find an accessible system" becomes less credible when the EAA mandates accessibility
Combined with the Employment Equality Directive, the EAA creates a powerful framework for workplace accessibilityThe Disproportionate Burden Exception
The EAA includes a "disproportionate burden" exception for micro-enterprises (fewer than 10 employees, turnover under โฌ2 million):
Micro-enterprises may be exempt from some requirementsThis exception is narrow and requires documented justificationMedium and large employers cannot rely on this exceptionTimeline and Preparation
Now (Before June 2025)
Complete workplace technology accessibility auditUpdate procurement policiesBegin remediation of critical systemsTrain IT and HR teamsJune 2025
EAA enters force โ all new products and services must complyNational enforcement beginsStart tracking compliance across workplace systems2025โ2030
Remediate existing systems on priority basisMonitor vendor compliance and escalate non-complianceBuild accessibility into organisational culture (not just compliance)June 2030
All products and services (including those already on the market before 2025) must complyFull enforcement of accessibility requirementsResources
European Commission: European Accessibility Act โ ec.europa.eu/social/accessibilityEN 301 549: European Accessibility Standard โ www.etsi.orgEuropean Disability Forum: EAA implementation trackerWeb Accessibility Initiative (WAI): WCAG 2.1 guidelinesIAAP (International Association of Accessibility Professionals): CertificationFunka: European accessibility consulting and testing