Among others, the European Accessibility Act requires services to ensure a list of requirements. A non-exhaustive list of them include:

• All services covered by the Act must make their websites and mobile applications accessible and, where applicable, provide accessible support services (like help desks, call centres, relay services, technical support). For example, services will have to provide different means to contact them, not only telephone.
• All the services covered by the Act must provide, in an accessible manner, information about the service as well as information of the accessibility of the products that they use for their provision. For example, banks will have to provide information about their services in an understandable manner and in formats that are accessible to persons with disabilities (electronic files that can be read by screen readers, printing in braille, etc.).
• Services providing access to audiovisual media services, such as websites and mobile apps of TV channels and on-demand platforms, must ensure that access services (like sign language or audio description) are transmitted with adequate quality for accurate display and synchronised with sound and video, while allowing for users’ control of their display and user experience.
• Electronic communication services must provide real time text (RTT) in addition to voice communication.
• Answering emergency communications to the single European emergency number 112 must be responded to using the same communications means as received. That means that if a user calls 112 using real-time-text (RTT), the PSAP must respond using the same method.
• Transport services will have to ensure the accessibility of their websites, mobile applications, ticketing, transport information and self-service terminals
• Banking services must ensure that identification methods, electronic signatures, payment services are accessible and the information is understandable to users.
• E-commerce services will have to provide information concerning the accessibility of the product and services being sold, ensure accessibility of identification and payment methods.

For more, read Annex I of the European Accessibility Act.

Among others, the European Accessibility Act requires services to ensure a list of requirements. A non-exhaustive list of them include:

• All services covered by the Act must make their websites and mobile applications accessible and, where applicable, provide accessible support services (like help desks, call centres, relay services, technical support). For example, services will have to provide different means to contact them, not only telephone.
• All the services covered by the Act must provide, in an accessible manner, information about the service as well as information of the accessibility of the products that they use for their provision. For example, banks will have to provide information about their services in an understandable manner and in formats that are accessible to persons with disabilities (electronic files that can be read by screen readers, printing in braille, etc.).
• Services providing access to audiovisual media services, such as websites and mobile apps of TV channels and on-demand platforms, must ensure that access services (like sign language or audio description) are transmitted with adequate quality for accurate display and synchronised with sound and video, while allowing for users’ control of their display and user experience.
• Electronic communication services must provide real time text (RTT) in addition to voice communication.
• Answering emergency communications to the single European emergency number 112 must be responded to using the same communications means as received. That means that if a user calls 112 using real-time-text (RTT), the PSAP must respond using the same method.
• Transport services will have to ensure the accessibility of their websites, mobile applications, ticketing, transport information and self-service terminals
• Banking services must ensure that identification methods, electronic signatures, payment services are accessible and the information is understandable to users.
• E-commerce services will have to provide information concerning the accessibility of the product and services being sold, ensure accessibility of identification and payment methods.

For more, read Annex I of the European Accessibility Act.

Since its adoption in 2019, Member States have had three years to transpose it into national law by adopting or updating national legislation that complies with the EAA. Member States had to inform the European Commission about the transposition measures before June 2022.

Unfortunately, some Member States did not adopt national measures by the required timeline or adopted measures that did not meet the requirements of the EAA. To ensure compliance, the European Commission started different infringement procedures. Information about open infringement procedures is available online.

When this procedures fail, the European Commission can refer the Member State to the European Court of Justice, as it was the case for Bulgaria in 2024.

Since its adoption in 2019, Member States have had three years to transpose it into national law by adopting or updating national legislation that complies with the EAA. Member States had to inform the European Commission about the transposition measures before June 2022.

Unfortunately, some Member States did not adopt national measures by the required timeline or adopted measures that did not meet the requirements of the EAA. To ensure compliance, the European Commission started different infringement procedures. Information about open infringement procedures is available online.

When this procedures fail, the European Commission can refer the Member State to the European Court of Justice, as it was the case for Bulgaria in 2024.

Member States will have to nominate specific bodies to ensure that services and products covered by the Act comply with the accessibility requirements when they are introduced into the EU market.

For products, Market Surveillance Authorities will be in charge of monitoring compliance and assess the adequate use of exemptions foreseen by the Act. In case of non-compliance, Market Surveillance Authorities will require relevant businesses to take appropriate corrective action. If it fails, they can oblige the business to withdraw the product from the market. When one EU country demands the withdrawal of a product from the market, the others must do the same.

For services, Member States will have to appoint a special authority that checks compliance of services with the act, asses the services that want to be exempt from accessibility requirements, follow-up on complaints and make sure service providers take corrective measures when necessary.

Such authorities can make use of penalties for non-compliance.

Member States will have to nominate specific bodies to ensure that services and products covered by the Act comply with the accessibility requirements when they are introduced into the EU market.

For products, Market Surveillance Authorities will be in charge of monitoring compliance and assess the adequate use of exemptions foreseen by the Act. In case of non-compliance, Market Surveillance Authorities will require relevant businesses to take appropriate corrective action. If it fails, they can oblige the business to withdraw the product from the market. When one EU country demands the withdrawal of a product from the market, the others must do the same.

For services, Member States will have to appoint a special authority that checks compliance of services with the act, asses the services that want to be exempt from accessibility requirements, follow-up on complaints and make sure service providers take corrective measures when necessary.

Such authorities can make use of penalties for non-compliance.

In EDF’s opinion, the Act has a number of strengths, for example:

• Businesses are obliged to take immediate corrective measures if a product doesn’t meet the accessibility requirements of the Act ,or even withdraw it from the market.
• If one Member State withdraws an inaccessible product from the market, the others must follow suit.
• Market Surveillance Authorities are given a prominent role and NGOs, national authorities or other bodies can represent individuals in court under national law.
• Public authorities must respect the accessibility requirements when purchasing products or services covered by this Directive.
• The EAA can be referred to, and has already been referred to, in other EU pieces of legislation when there is an accessibility obligation. This will ensure certainty in implementing accessibility provisions in other EU laws (e.g. on combating violence against women, on digital identification, on digital euro, or the Artificial Intelligence Act).

However, there are ways in which the Act fell short of EDF expectations:

• Healthcare services, education, transport, housing, and household appliances were left out of the Act.
•  A number of exemptions are made even in case of products and services covered by the Act. For example, when the service is related to urban, suburban and regional transport or is provided by a microenterprise, it is exempt from the requirements of the Act.
• Requirements concerning the built environment related to the services covered by the Act are left to the decision of Member States.
• There are provisions that allows loopholes for economic operators to still place inaccessible products on the market (fundamental alteration and disproportionate burden).
• It is also unfortunate that the robust enforcement mechanism does not apply to infringement cases made by public authorities.
• The period of transposition by Member States is lengthy and for some of the products and services, implementation is disproportionately long.

In EDF’s opinion, the Act has a number of strengths, for example:

• Businesses are obliged to take immediate corrective measures if a product doesn’t meet the accessibility requirements of the Act ,or even withdraw it from the market.
• If one Member State withdraws an inaccessible product from the market, the others must follow suit.
• Market Surveillance Authorities are given a prominent role and NGOs, national authorities or other bodies can represent individuals in court under national law.
• Public authorities must respect the accessibility requirements when purchasing products or services covered by this Directive.
• The EAA can be referred to, and has already been referred to, in other EU pieces of legislation when there is an accessibility obligation. This will ensure certainty in implementing accessibility provisions in other EU laws (e.g. on combating violence against women, on digital identification, on digital euro, or the Artificial Intelligence Act).

However, there are ways in which the Act fell short of EDF expectations:

• Healthcare services, education, transport, housing, and household appliances were left out of the Act.
•  A number of exemptions are made even in case of products and services covered by the Act. For example, when the service is related to urban, suburban and regional transport or is provided by a microenterprise, it is exempt from the requirements of the Act.
• Requirements concerning the built environment related to the services covered by the Act are left to the decision of Member States.
• There are provisions that allows loopholes for economic operators to still place inaccessible products on the market (fundamental alteration and disproportionate burden).
• It is also unfortunate that the robust enforcement mechanism does not apply to infringement cases made by public authorities.
• The period of transposition by Member States is lengthy and for some of the products and services, implementation is disproportionately long.