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.
A directive can set accessibility requirements. It cannot keep a live product or service inside those requirements as it changes.
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.
A launch check is not the operating test
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.
The risk is not only a failed first test. It is operating a changing service with no register of issues, no owner for remediation, and no file that shows what was tested, found, fixed or accepted.
Where readiness 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 that remain 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.
These are connected decisions. Treating accessibility as a design standard, a legal opinion or a one-off test leaves the organisation to reconstruct compliance when surveillance or a complaint arrives.
What Ontzi builds
Ontzi turns the obligation into a continuous operating model. We connect testing to issue management, make remediation and exceptions visible, and keep the evidence that a product or service still meets the requirements after the last release.
The immediate output is a defensible current state. The durable value is a repeatable capability: the organisation knows what is in scope, what failed, who owns the fix and what can be shown.
The Act is the requirement. The operating model is what keeps it true in production.
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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.