OnwynOnwyn › Standards › European Accessibility Act (Directive (EU) 2019/882) and EN 301 549
Regulation · 2019/882, applying from 28 June 2025 — technical baseline EN 301 549 v3.2.1European Accessibility Act (Directive (EU) 2019/882) and EN 301 549
The European Accessibility Act sets accessibility requirements for a defined list of consumer products and services sold into the EU — e-commerce, consumer banking, electronic communications, audiovisual media access, passenger transport, e-books, self-service terminals, computer hardware, e-readers and consumer terminal equipment. It has applied since 28 June 2025 through national transposing laws, and it reaches SMEs: only micro-enterprises providing services (fewer than 10 persons AND turnover or balance sheet total not exceeding EUR 2 million) are exempt, and that exemption does not cover products. There is NO accessibility certificate under this Act and no accreditation body that issues one. Conformity is self-declared: for products through internal production control, an EU declaration of conformity and CE marking; for services through the Annex V information published in your terms and conditions, usually as an accessibility statement. The technical answer to 'what does accessible mean' is EN 301 549, which incorporates WCAG 2.1 level AA by reference for web and software and adds clauses for non-web documents, hardware, two-way voice, video and support services. Note the standards gap honestly: EN 301 549 v3.2.1 is cited in the Official Journal under the Web Accessibility Directive, not yet under this Act, so meeting it is the accepted and expected route but does not yet carry a formal Article 15 presumption of conformity. Compliance can be reduced only through the fundamental-alteration and disproportionate-burden defences, which are real but narrow, must be assessed against the Annex VI criteria, documented, kept for five years, and reassessed at least every five years. This pack is weighted toward what a 10-250 person EU company selling online or providing a digital service actually has to do, and it does not reproduce the several hundred testable clauses of EN 301 549 itself, which must be read from the standard.
What this standard asks for
Every requirement in European Accessibility Act (Directive (EU) 2019/882) and EN 301 549, grouped the way the standard groups them. In the Semantic Compliance Engine each one carries what to do, how to evidence it, what auditors commonly reject, and a button to bring in a consultant if you would rather not work it out alone.
Scope, roles and exemptions
6 requirements
- Art. 2Determine whether the Act applies to your products and services
- Art. 3(22)Test the consumer hinge before concluding you are out of scope
- Art. 4(5)Establish whether the micro-enterprise exemption applies — and to what
- Scope RegisterInventory every in-scope surface, not just the main product
- Ch. III/IVEstablish your role, because the obligations differ by role
- Art. 30-31Identify the national laws, authorities and penalties that actually bind you
Annex I — what accessible actually means
6 requirements
- Annex I §III(b)Make the information about your service accessible, and say what it does
- Annex I §III(c)Make websites and mobile applications accessible, consistently
- Annex I §III(d)Make support services accessible and informed
- Annex I §IV(g)E-commerce: accessible identification, security and payment, and pass on product accessibility information
- Annex I §IVApply the sector additions for your specific service
- Annex I §VIIUse the functional performance criteria where no technical criterion fits
EN 301 549 and the conformity route
7 requirements
- Art. 15Adopt EN 301 549 as the conformity route — and understand the presumption gap
- EN 9Meet EN 301 549 clause 9 — web content at WCAG 2.1 level AA
- EN 11Meet EN 301 549 clause 11 — software, mobile apps and assistive-technology interoperability
- EN 10Meet EN 301 549 clause 10 — non-web documents
- EN 12Meet EN 301 549 clause 12 — documentation and support services
- EN 5-8Apply the generic, voice, video and hardware clauses where they bite
- EN 14Test conformance clause by clause and keep the record
Fundamental alteration and disproportionate burden
4 requirements
- Art. 14(1)Assess fundamental alteration and disproportionate burden before relying on either
- Art. 14(3)Document the assessment, keep it five years, and reassess it
- Art. 14(8)Notify the authority when you rely on the defence
- Art. 14(6)Do not claim disproportionate burden where accessibility funding was received
The accessibility statement and public claims
2 requirements
- Art. 13(2)Publish the Annex V information — the accessibility statement
- ClaimsKeep your public accessibility claims true
Products, technical file and CE marking
3 requirements
- Art. 7Design in-scope products to Annex I and hold the technical documentation
- Art. 16-18Draw up the EU declaration of conformity and affix the CE marking
- Art. 9-12Meet the importer, distributor and traceability duties
Running it: people, procurement and change
4 requirements
- ProcurementBuy accessibility in: suppliers, components and embedded services
- Art. 13(3)Keep the service conforming as it changes
- TrainingTrain the people who build the product and write the content
- GovernanceOwn it: named accountability, a roadmap and a budget
Enforcement, non-conformity and the transition dates
3 requirements
- Art. 13(4)Correct non-conformity, and inform the authorities when a service does not comply
- Art. 19-23 & 29Be ready for market surveillance, compliance checks and consumer complaints
- Art. 31-32Get the dates right: 28 June 2025, and what the transitions actually cover
The documents you will end up with
The recommended document set for European Accessibility Act (Directive (EU) 2019/882) and EN 301 549 — 15 in total. The engine tracks which you have, which are missing, and which of your existing documents already cover a requirement.
Which of your products and services fall under the Act, in which Member States, and in which role — the decision every other document inherits.
The organisation's commitment, the standard it holds itself to, who owns it, and how accessibility survives the next release.
The public explanation of how your service meets the accessibility requirements, published in your terms and conditions or an equivalent document.
The clause-by-clause record of which EN 301 549 requirements apply to each surface, whether they are met, and on what evidence.
How each surface is tested — automated, manual keyboard, screen reader, zoom and contrast — who tested it, when, and what was found.
The open barriers, their user impact, the owner and the target date — the honest version of where you are.
Where you rely on Article 14, the Annex VI reasoning that supports it, kept for five years and reassessed.
The accessibility clauses and evidence you demand from vendors, agencies, embedded widgets and payment providers before they reach your product.
The design, build and release checkpoints that stop new barriers being shipped between audits.
How PDFs, invoices, contracts, statements and downloadable material are produced so they meet the non-web document clauses.
How the help desk, chat, phone line and knowledge base answer users with disabilities, and what they know about your accessibility features.
Who has been trained, on what, and when — designers, developers, content authors, support and procurement.
The accessibility behaviour required of login, identity verification, consent, basket, checkout and payment flows, including third-party components.
For in-scope hardware: the Annex IV internal production control file, the declaration of conformity and the CE marking record.
For each Member State you sell into: the transposing law, the competent authority, the penalty range and any national additions.
Start European Accessibility Act today
Every live framework is included in one subscription — no per-framework pricing. Your first 30 days are free, we ask for no card, and there is nothing to cancel. On any requirement you can bring in a senior consultant for a review, a call, or done-for-you implementation.