Directive 2019/882: covered products and services have been in scope since 28 June 2025. Some service-side use of older products may continue until 28 June 2030.
Directive (EU) 2019/882 — the European Accessibility Act — harmonises accessibility requirements for specified products and consumer services. For products placed on the market after 28 June 2025, and for covered services provided to consumers after that date, the requirements are in application. National market surveillance and consumer enforcement are no longer theoretical.
The product list includes consumer computers and operating systems, self-service terminals, terminal equipment for electronic communications and audiovisual services, and e-readers. The service list includes electronic communications, access to audiovisual media, elements of passenger transport information and ticketing, consumer banking, e-books, and e-commerce — the online sale of any product or service to an EU consumer, including the wider customer journey.
Microenterprises providing services have a specific exemption. Most other economic operators in the chain — manufacturers, importers, distributors and service providers — have duties to design, assess, document and not place non-compliant offerings on the market.
After launch
Accessibility is not a single score. Products need conformity assessment, technical documentation and CE marking where the Act requires it. Services need to meet the Annex I requirements in use: websites, apps, documents, checkout, support and the terminals that deliver the service.
Services already on the market had to meet the requirements from 28 June 2025. Some transitional rules run to 28 June 2030 — for example, service providers may continue using certain products they already used to deliver a service — but that is not a delay of the service obligation itself. Existing contracts can run their course up to that date; new provision cannot treat 2030 as the start of accessibility.
The evidence is spread across design systems, code, content, third-party widgets, vendor platforms and support scripts. A sample audit at launch does not speak for the next release, the next campaign page or the next payment provider.
Where it breaks
- Scope: which products, journeys and third parties are covered — including e-commerce surfaces that sit outside the “accessibility team”.
- Evidence: test results, exceptions, vendor attestations and technical documentation attached to the version actually in market.
- Remediation: who accepts a finding, who fixes it, and how recurrence is prevented when the product moves on.
What we build
Ongoing tests, owners for findings and exceptions, and evidence attached to the version actually in market.
Primary text
This field note is general information, not legal advice. Product and service scope, microenterprise treatment and national enforcement should be checked in the law applicable to each operator.