European Accessibility Act Requirements: Does the EAA Apply to Your Documents?
The European Accessibility Act requirements apply to specific consumer products and services, not to every company. If you make or sell computers, smartphones, payment or ticketing terminals or e-readers, or provide banking, e-commerce, e-book, telecoms or passenger transport services to consumers, your instructions, product information, websites and customer PDFs must be accessible. DEMA Solutions helps companies make those documents accessible in every language.
Who this guide is for
This article is for the people who have to turn a piece of legislation into a list of documents to fix: compliance and quality managers, heads of technical documentation, product managers, and the marketing and web teams who publish customer-facing content at manufacturers, online retailers, banks and insurers, publishers and transport operators. Many of them also have a colleague in sales asking a simpler question: “Does this apply to us at all?”
That question deserves an honest answer, because the Act is narrower than many summaries suggest. The legal text, Directive (EU) 2019/882, is short enough to check any point yourself. This guide is general information, not legal advice.
What the European Accessibility Act is and when it applies
The European Accessibility Act (EAA) is Directive (EU) 2019/882 on the accessibility requirements for products and services. Member States had to transpose it by 28 June 2022, and the national rules have applied since 28 June 2025. Since then, products in scope placed on the EU market and services in scope provided to consumers must meet the accessibility requirements in Annex I of the Directive.
The aim is a common EU baseline extending accessibility obligations to private companies for a defined list of everyday products and services. Because it is a directive, the obligations reach companies through national laws: the Barrierefreiheitsstärkungsgesetz in Germany, Decreto Legislativo 82/2022 in Italy, Ley 11/2023 in Spain. The core content is the same everywhere; authorities and penalties differ.
Who is covered: products, services and the economic operator roles
The Act works with a closed list. Article 2 names the products and services in scope, and if yours are not on it, the EAA does not apply to them, however good an idea accessibility might be.
- Products placed on the market after 28 June 2025: consumer general purpose computer hardware and their operating systems; self-service terminals such as payment terminals, ATMs, ticketing machines, check-in machines and interactive information terminals; consumer terminal equipment with interactive computing capability used for electronic communications or for accessing audiovisual media services, such as smartphones, tablets and smart TVs; and e-readers.
- Services provided to consumers after 28 June 2025: electronic communications services; services providing access to audiovisual media services; websites, mobile apps, electronic tickets, travel information and self-service terminals of air, bus, rail and waterborne passenger transport; consumer banking services; e-books and dedicated software; and e-commerce services.
The obligations are spread across what the Directive calls economic operators: the manufacturer, the authorised representative, the importer, the distributor and the service provider. The manufacturer designs the product to meet the requirements, draws up the technical documentation, issues the EU declaration of conformity, affixes the CE marking and supplies instructions and safety information in a language easily understood by consumers and other end users, as determined by the Member State concerned. Importers and distributors check this before they sell the product, so missing accessible instructions can stop a shipment. Service providers answer for the accessibility of their service and the information about it, even when parts of it, such as an app, come from a third party.
European Accessibility Act requirements for documents and information
Most discussions of the EAA focus on websites, but a large share of the Annex I requirements is about information: what the user is told, in what form, and whether they can actually perceive and understand it.
Information on the product itself. Labelling, instructions and warnings on the product must be available through more than one sensory channel, understandable, perceivable, and set in fonts of adequate size and shape, with sufficient contrast and adjustable spacing.
Instructions not on the product. Instructions provided through the product or elsewhere, such as a website, must be publicly available when the product is placed on the market and follow the same principles. Their content must be in text formats that can generate alternative assistive formats, non-text content needs an alternative presentation, and they must describe the user interface, the functionality and accessibility features, and how the product works with assistive devices. A user manual published as a scanned, image-only PDF no longer works for a product in scope.
Information about a service. Service providers must explain how the service works and, where products are used to deliver it, how it links to them and what their accessibility characteristics are, following the same principles. Under Article 13 and Annex V, they must also describe how the service meets the accessibility requirements, in their general terms and conditions or an equivalent document, in written and oral format and in an accessible way.
Websites, apps and the documents on them. Websites, related online applications and mobile services must be perceivable, operable, understandable and robust. The PDFs, forms and office documents on an in-scope website are part of it: a data sheet in an online shop or a policy summary in a banking portal has to work with a screen reader, not just look right. In practice that means tagged structure, a logical reading order, alternative text and the correct language settings, which our guide to making PDF documents accessible covers step by step.
Sector-specific requirements. For consumer banking, information must not exceed the complexity of level B2 (upper intermediate) of the Council of Europe’s Common European Framework of Reference for Languages, effectively a plain-language requirement written into law. E-books must keep their navigation, structure and reading order usable by assistive technology.
The Directive describes outcomes rather than techniques. To turn them into checks, most organisations use EN 301 549, the European standard that incorporates WCAG 2.1 level AA, together with PDF/UA (ISO 14289) for PDF files.
Videos, captions and subtitles
Video is the part of the EAA that documentation teams forget most easily. Product tutorials, onboarding videos for banking apps and installation clips on an e-commerce product page are part of an in-scope service, and for them to be perceivable, people who cannot hear the soundtrack need captions, as the WCAG criteria inside EN 301 549 expect for pre-recorded video. Video published before 28 June 2025 is excluded from the website requirements, so the obligation applies to new and updated content. For audiovisual media services, access services such as subtitles for the deaf and hard of hearing must also be transmitted in full and with adequate quality. If you publish video in several languages, plan subtitles for the d/Deaf and hard of hearing (SDH) alongside the translated versions, because SDH also carries speaker identification and relevant sound cues that a standard translated subtitle track leaves out.
Does the European Accessibility Act apply to B2B companies?
This is where many manufacturers get conflicting advice, so it is worth being precise. The EAA is built around consumers. The product list refers to consumer equipment, the services list refers to services provided to consumers, and the Directive defines a consumer as a natural person acting outside their trade, business, craft or profession.
As a result, a manufacturer of industrial machinery that sells only to other businesses is generally outside the European Accessibility Act. A packaging line, a CNC machine or an industrial chiller is not on the product list, and its operating manual does not become subject to the EAA because it is a PDF. For such equipment, the rules that matter are product safety rules, notably the Machinery Regulation (EU) 2023/1230 and its rules on translated instructions, which applies from 20 January 2027.
The B2B picture changes in three situations. First, some products sold business to business are in scope because consumers use them: payment terminals, ATMs, ticket machines and check-in kiosks are sold to banks, retailers and airports, but they are on the list, so their instructions and interfaces must comply. Second, a B2B company may also sell to consumers, for example through an online shop for spare parts or accessories, which is an e-commerce service. Third, customers who must comply, such as banks or transport operators, often ask their suppliers for accessible components, documentation and content, and public buyers ask for accessibility in tenders under separate procurement rules.
So check your products against Article 2, check whether any channel sells to consumers, and check what your customers’ contracts ask for. If all three answers are no, the EAA is not your main concern, although accessible documents remain good practice. Device makers should also remember that medical devices follow their own rules on labeling and instructions under the MDR.
Exemptions and limits: microenterprises, disproportionate burden and older content
Microenterprises providing services are exempt. A microenterprise is an enterprise with fewer than 10 employees and an annual turnover or balance sheet total not exceeding EUR 2 million. If such a company provides an in-scope service, for example a small online shop, it does not have to meet the accessibility requirements for that service. Microenterprises that make or sell in-scope products are not exempt, but they do not need to document a disproportionate burden assessment, and the Commission and Member States provide guidance to help them.
Disproportionate burden and fundamental alteration. Under Article 14, an economic operator can argue that a specific requirement would fundamentally alter the product or service or impose a disproportionate burden. This is not a blanket opt-out: the assessment must follow the criteria in Annex VI and be documented, and for products the market surveillance authorities must be informed. Cost alone, without that assessment, is not an exemption.
Content published before the deadline. For websites and mobile applications, the Directive excludes pre-recorded time-based media and office file formats published before 28 June 2025, third-party content the company neither funds, develops nor controls, and archives not updated after that date. An old PDF left untouched in an archive can stay as it is; a PDF you revise or republish today is new content.
National laws: Italy, Germany and Spain
Italy. The Directive was transposed by Decreto Legislativo 27 May 2022, no. 82. The Agency for Digital Italy (AgID) is the supervisory authority for the services in scope, and products fall under market surveillance. The decree is separate from the Legge Stanca (Law 4/2004), which governs the accessibility of websites and apps of public administrations and certain large private companies. A company can be subject to one, both or neither, so it is worth checking each channel separately.
Germany. The Barrierefreiheitsstärkungsgesetz (BFSG) and its implementing regulation (BFSGV) transpose the Directive. The BFSG exempts microenterprises that provide services, provides fines of up to EUR 100,000 for the most serious infringements, and allows services to use products already in use until 27 June 2030. For self-service terminals already in use, Germany set a maximum of fifteen years after they were put into service, shorter than the twenty years the Directive allows. Market surveillance authorities of the federal states enforce it, and consumers and associations can ask them to act.
Spain. Ley 11/2023, of 8 May, transposes the Directive with the same scope and the same date of 28 June 2025, within the broader Spanish framework on the rights of persons with disabilities, which also governs inspection and penalties.
If you sell in several countries, the requirements for your documents are the same; the authority, the penalty scale and some transition periods differ.
Deadlines, transition periods and fines
Since 28 June 2025, new products in scope must comply when placed on the market and services in scope must comply when provided. Service providers may keep using products they lawfully used before that date until 28 June 2030; service contracts agreed before then may continue unchanged until they expire, for no more than five years; and Member States may allow existing self-service terminals to stay in use for up to twenty years after they entered into use. These transitions concern the hardware used to deliver a service, not your documentation: new instructions, web content and PDFs fall under the requirements now.
Article 30 requires each Member State to set penalties that are effective, proportionate and dissuasive, which is why European Accessibility Act fines vary by country. Germany caps them at EUR 100,000 per infringement for the most serious cases, and authorities everywhere can order corrective action or the withdrawal of non-compliant products. For most companies, the practical risk is less a fine than a blocked product, a lost tender or a customer who cannot use what you sell.
European Accessibility Act and PDF: what an accessible document needs
The EAA does not use the word PDF, but any PDF carrying information about something in scope has to meet the same principles: a tagged structure with correct roles for headings, lists and tables; a reading order that matches the visual order; alternative text for images and diagrams; a defined document language; meaningful links and bookmarks; sufficient contrast; and security settings that do not block assistive technology.
None of this is visible on the printed page, which is why documents that look perfect often fail an accessibility check. A PDF exported without attention to styles or tag structure usually needs PDF remediation to PDF/UA before it works with a screen reader. In multilingual documentation, each language version is a separate file with its own tags, reading order and language settings, and a translated diagram can lose its alternative text, so accessibility has to be checked on the final file in every language.
A practical compliance path for your documents
The companies that handle this well treat it as a documentation project with a clear inventory. In practice, the path has six stages.
Map scope before you touch a file. Compare each product and service with Article 2, and for each in-scope item record the countries where it is sold and the national law that applies. This gives you a short, defensible list instead of a company-wide project.
Build a document inventory. For each in-scope item, list what users receive: labels and warnings, instructions, quick-start guides, product pages and data sheets, terms and conditions, the Annex V accessibility information, customer letters, e-books, forms and videos, with format, source files and languages.
Prioritise by impact and change. Start with what users need to use the product or service safely, then with documents that change often. New and revised content must comply from day one, so fix the production process before you clean up the back catalogue.
Fix the source, not just the output. The cheapest place to build accessibility is the source file: correct heading styles, real tables, alternative text written once and translated with the rest. Our guide to multilingual desktop publishing explains why this pays off in every language.
Make the language accessible too. Instructions must be understandable, and some audiences need simplified versions. A plain language rewrite based on ISO 24495-1 helps general audiences, while Easy-to-Read versions serve people with cognitive or learning disabilities.
Test, document and repeat. Check every file against the agreed requirements in every language, keep the evidence, and build the checks into your change process so each revision is accessible when published. The general principles of translating user manuals for EU markets apply here: language versions must be released together and stay in step.
What to ask a supplier
A few questions separate a supplier who understands accessibility from one who runs an automatic checker and sends back a report. Ask which standards they test against and what evidence they deliver; whether they fix the source files or only patch the final PDF; how they handle alternative text, tables and reading order in translated versions; whether a person reviews the result with assistive technology; and how accessible files stay in step when your documents are updated. The broader questions in our guide to checking a supplier’s quality before you hire them apply as well.
How DEMA Solutions helps you make documents accessible
EAA compliance for documents is rarely one service. Our accessibility and inclusive language services cover the barriers the Act is concerned with: PDF remediation tested against PDF/UA and WCAG requirements, plain language and Easy-to-Read versions, and SDH subtitles and multilingual subtitling for your videos.
Because we also translate and lay out documentation, accessibility can be built into production rather than added afterwards. Our in-house DTP team works in the original source files, and in multilingual projects the accessibility checks are repeated on the final file in each language. Translation follows an ISO 17100 certified process, with a second qualified linguist revising every translation, delivered by our teams in Italy, Serbia and Spain. We remediate and test documents against the requirements agreed with you; whether a product or service is legally in scope is a question for your legal adviser.
Frequently asked questions
They are set out in Annex I of Directive (EU) 2019/882. Products in scope need labelling, instructions and warnings that are perceivable, understandable and available through more than one sensory channel. Services in scope need accessible information and websites, apps and documents that are perceivable, operable, understandable and robust.
The national laws transposing the Directive have applied since 28 June 2025. Products placed on the market and services provided to consumers after that date must comply, with transition periods for products already used to deliver services.
Generally not, if the company sells products that are not on the Article 2 list only to other businesses. It does apply to B2B manufacturers of in-scope products such as payment terminals, ATMs and ticket machines, and to any company that provides an in-scope service, such as e-commerce, to consumers.
Microenterprises with fewer than 10 employees and a turnover or balance sheet total of no more than EUR 2 million are exempt for the services they provide. Microenterprises that make or sell in-scope products must still comply.
PDFs that carry information about an in-scope product or service, or that are published on an in-scope website or app after 28 June 2025, must be accessible. Office files published before that date and archived content that is no longer updated are excluded.
Pre-recorded videos published on in-scope websites and apps after 28 June 2025 should have captions. Subtitles for the deaf and hard of hearing also include speaker identification and relevant sounds.
Each Member State sets its own penalties, which must be effective, proportionate and dissuasive. In Germany, the BFSG sets fines of up to EUR 100,000 for the most serious infringements. Authorities can also require corrective action or the withdrawal of non-compliant products.
Make your documents accessible in every language
If your products or services fall under the European Accessibility Act, or your customers are asking for accessible documentation, tell us which documents and languages you need to make accessible. We will review a sample, explain what needs to change and plan the work around your publishing process.
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