Direct answer: the EU Accessibility Act (EAA, Directive (EU) 2019/882) has applied since 28 June 2025: specified products placed on the market after 28 June 2025 and specified services provided to consumers after 28 June 2025 must meet the Annex I accessibility requirements. For Chinese exporters/cross-border sellers, two points matter most: (1) e-commerce websites/mobile apps are in scope and must let consumers browse, order, pay and obtain information without barriers; (2) computers/operating systems, payment terminals, ATMs/ticketing/check-in/self-service terminals, consumer terminal equipment for electronic communications/audiovisual services and e-readers are in scope, with manufacturer/importer/distributor obligations. Two key exceptions: microenterprises providing services can be exempt from the Article 4(3) service accessibility requirements; microenterprises dealing with products are not automatically exempt—they have lighter obligations and may be exempt from documenting the disproportionate-burden assessment. The transitional period runs to 28 June 2030, and service contracts agreed before 28 June 2025 may continue until expiry, for no longer than five years.
This guide is for Chinese manufacturers of consumer electronics/self-service terminals/e-commerce services, cross-border sellers, EU importers/authorised representatives and website/product teams. It explains EAA scope, the 2025/2030 timeline, e-commerce website/app duties, the microenterprise exception, Annex V information, disproportionate-burden assessment, penalties and a 90-day readiness checklist. Sources are the EUR-Lex text of Directive (EU) 2019/882 and the European Commission EAA page (both accessed 8 November 2026). Legal facts, editorial interpretation and items to confirm are kept separate. This is not legal advice.
(1) It already applies from 28 June 2025: newly placed products and newly provided consumer services (including e-commerce websites/apps) must meet Annex I; this is not future law. (2) Microenterprises "providing services" can be exempt from service accessibility duties; product microenterprises are not automatically exempt—they have lighter duties and may skip the written assessment record. (3) A WCAG check is not enough: EAA also requires Annex V information, ongoing compliance procedures, corrective action and, where needed, notifying authorities; exceptions must be assessed and kept for five years.
Timeline: 2022 transposition, 2025 application, 2030 transition
The EAA was adopted in 2019; Member States had to transpose it by 28 June 2022. The core application date is 28 June 2025: products placed on the market and services provided to consumers after that date must meet Annex I. Transitional arrangements run to 28 June 2030: service providers may continue to use products lawfully used before that date; service contracts agreed before 28 June 2025 may continue until expiry, for no longer than five years. In 2026 this is no longer a "preparation" phase but an "implementation/enforcement" phase; companies that have not started should prioritise e-commerce websites/apps and product compliance files.
| Date | Event | What it means |
|---|---|---|
| 17 Apr 2019 | EAA adopted (Directive (EU) 2019/882) | Member State transposition begins |
| 28 Jun 2022 | Transposition deadline | National obligations in force |
| 28 Jun 2025 | Core application date | New products/services must meet Annex I |
| 28 Jun 2030 | Transitional period ends | Continued use of old products ends |
| Contracts before 28 Jun 2025 | May continue to expiry | No longer than five years |
Sources: Directive (EU) 2019/882 Articles 2 and 32; European Commission EAA page (accessed 8 November 2026). National transposition/enforcement details follow Member State law.
Scope: which products, which services, is e-commerce included?
The EAA covers products and services identified as most important for persons with disabilities and most likely to have divergent national requirements. Products include consumer general-purpose computer hardware and operating systems, payment terminals, ATMs/ticketing/check-in/interactive self-service terminals, consumer terminal equipment used for electronic communications services, consumer terminal equipment used for accessing audiovisual media services, and e-readers. Services include electronic communications (excluding M2M transmission), access to audiovisual media, air/bus/rail/water passenger transport websites/apps/e-tickets/information, banking, e-books and e-commerce. EAA defines e-commerce as a distance service provided through websites/mobile apps, by electronic means, at the individual request of a consumer, to conclude a consumer contract; online sale of any product or service counts, including products that are themselves covered by the EAA.
| Category | Examples | Covered? |
|---|---|---|
| Consumer electronics/terminals | General-purpose computer hardware/OS, electronic communications/audiovisual terminals, e-readers | Yes (placed on market after 28 Jun 2025) |
| Self-service terminals | Payment terminals, ATMs, ticketing/check-in/interactive information terminals | Yes |
| E-commerce services | Website/app ordering, payment, accounts, product information | Yes (provided to consumers) |
| Banking/e-books/audiovisual/electronic communications | Online banking, e-books, streaming, communications | Yes |
| Passenger transport | Air/bus/rail/water websites, apps, e-tickets | Yes (urban/regional transport only specific elements) |
| B2B non-consumer services | Pure enterprise procurement/internal systems | Usually outside "provided to consumers" |
Sources: Directive (EU) 2019/882 Article 2(1)(2), recitals 35/42/43; European Commission EAA page. Editorial summary; whether a specific product/service is in scope follows the legal text and competent authority interpretation.
Role obligations: manufacturer, importer, distributor, service provider
On the product side: manufacturers must ensure Annex I conformity and carry out conformity assessment/technical documentation/EU declaration of conformity; importers must confirm third-country products have completed the conformity process and indicate their name/address on the product; distributors must ensure handling does not affect conformity. On the service side: service providers must design/provide services in accordance with Annex I, prepare Annex V information and make it public (written and oral, accessible formats), and put in place procedures for ongoing conformity; on non-conformity they must take corrective measures and, where required, immediately inform the competent authorities. For Chinese exporters, product obligations usually land through the EU importer/authorised representative, while e-commerce website/app services face consumers directly—responsibility cannot simply be pushed to the platform.
| Role | Core duty | Evidence/caveat |
|---|---|---|
| Manufacturer | Annex I conformity; conformity assessment/technical documentation/declaration | Design file, testing, risk assessment |
| Importer | Confirm third-country product conformity; name/address marking | Supplier declaration, technical file, label |
| Distributor | Do not affect conformity; cooperate with authorities | Storage/transport/modification records |
| Service provider | Design/provide per Annex I; Annex V information; ongoing conformity; corrective/notify | Accessibility information, testing, tickets, corrective records |
| Microenterprise (services) | Exempt from Article 4(3) service duties | Confirm microenterprise definition |
Sources: Directive (EU) 2019/882 Articles 7-13 and Article 4(5); editorial summary; specific conformity assessment/technical documentation/declaration requirements follow the legal text and competent authorities.
E-commerce websites/apps: beyond WCAG, EAA evidence
The EAA's core for e-commerce is not "publish an accessibility statement" but letting consumers complete the entire journey: browse products/services, select, order, pay, view orders/invoices, contact support and obtain help. Technically, teams often use WCAG/EN 301 549 as references, but the EAA also requires: Annex V information (service description, how Annex I is met, contact details, etc.) in accessible formats; procedures for ongoing conformity; corrective action and notification to authorities on non-conformity; and, if claiming "fundamental alteration/disproportionate burden", an Annex VI assessment kept for five years (product microenterprises may be exempt from the written record).
| Stage | What to do | Checkable evidence |
|---|---|---|
| Browse/search | Keyboard/screen reader/zoom/contrast/form labels | WCAG audit, manual testing |
| Order/payment | Error messages, timeouts, CAPTCHA alternatives, payment terminal | End-to-end tests, terminal compliance |
| Account/support | Login, recovery, live chat, help centre | Journey tests, alternative channels |
| Information | Annex V information, accessible formats, contact | Public pages, version records |
| Ongoing conformity | Change management, regression testing, corrective/notify | SOP, tickets, corrective records |
| Exceptions | Fundamental alteration/disproportionate burden assessment | Annex VI assessment, 5-year retention |
Sources: Directive (EU) 2019/882 Article 13, Article 14, Annex V/VI; editorial summary; WCAG/EN 301 549 are common technical references, but EAA compliance still depends on Annex I/competent authority requirements.
Microenterprise exception: services may be exempt, products are not automatic
The EAA distinguishes clearly: microenterprises providing services may be exempt from the Article 4(3) service accessibility requirements and related obligations (Article 4(5)); microenterprises dealing with products are not automatically exempt—the directive requires lighter obligations and allows them to be exempt from the Article 14(3) written assessment record (Article 14(4)). The microenterprise definition follows Commission Recommendation 2003/361/EC: fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million. Cross-border sellers providing services to EU consumers may fall under the service microenterprise exemption; if they sell covered products, they cannot simply assume the same exemption.
| Type | Exempt? | Caveat |
|---|---|---|
| Microenterprise + services | Exempt from Article 4(3) service duties | Confirm the microenterprise definition; Member States may have registration/evidence rules |
| Microenterprise + products | Not automatically exempt | Lighter duties; may skip Article 14(3) written assessment record |
| SME (non-micro) | Not exempt | May assess disproportionate burden |
| Large enterprise | Not exempt | Full duties; supply chain/platform cooperation |
Sources: Directive (EU) 2019/882 Article 4(5), Article 14(4), recitals 70-72; the microenterprise definition references Commission Recommendation 2003/361/EC. Editorial summary; exemption application depends on the business and Member State law.
Penalties and enforcement: not toothless
The EAA requires Member States to set effective, proportionate and dissuasive penalties, accompanied by corrective action, and to provide complaint/remedy mechanisms so consumers/organisations can seek redress. Specific fines, enforcement bodies and procedures are set by national law and can vary widely. For Chinese exporters, the risk is not only fines: delisting, recall, platform restrictions, importer claims/contract termination are also possible. Compliance evidence (testing, Annex V information, assessment records, corrective records) is critical when customers/regulators ask.
| Risk | Possible consequence | Control |
|---|---|---|
| Non-compliant product | Delisting/recall/fines/importer claims | Conformity assessment, technical file, labels |
| Non-compliant e-commerce site/app | Complaints, investigation, remediation/fines | WCAG/journey testing, Annex V, corrective records |
| Wrongly claimed exception | Assessment rejected, penalties | Annex VI assessment, 5-year retention |
| No supply-chain evidence | Customer audit failure/contract risk | Supplier declarations, test reports, version records |
Sources: Directive (EU) 2019/882 Article 30 (penalties) and Article 31 (enforcement/remedies); editorial summary; specific penalties/procedures follow Member State law.
90-day readiness checklist
Use the first 90 days to answer "are we in scope, which role, what evidence is missing, what to fix first". The order is scope/role, e-commerce journey audit, product compliance file, Annex V/exception assessment, remediation/retest, contracts/monitoring. Do not stop after one WCAG scan; the EAA requires ongoing conformity and checkable evidence.
| Phase | Action | Output |
|---|---|---|
| Weeks 1-2 | Determine product/service scope; confirm manufacturer/importer/service-provider role | Scope/role conclusion |
| Weeks 2-4 | End-to-end e-commerce website/app audit (browse/order/pay/support) | Issue list, priorities |
| Weeks 3-5 | Product technical documentation/conformity assessment/labels/importer information | Compliance file |
| Weeks 5-7 | Annex V information, exception assessment (if needed), 5-year retention | Public information, assessment record |
| Weeks 7-9 | Fix high priorities; retest; build ongoing-conformity SOP | Remediation log, SOP |
| Weeks 9-12 | Contract/supplier clauses, monitoring, training, mock inquiry | Contract clauses, drill report |
Editorial readiness advice, not an official template; scope/duties/evidence follow the EAA, Member State law and competent authorities.
FAQ
Does the EAA apply now?
Yes. The core application date is 28 June 2025; covered products placed on the market and covered services provided to consumers (including e-commerce websites/apps) after that date must meet Annex I. The transitional period runs to 28 June 2030.
Are e-commerce websites/apps covered?
Yes. The EAA defines e-commerce as a distance service provided through websites/mobile apps, by electronic means, at the individual request of a consumer, to conclude a consumer contract; online sale of any product or service counts.
Are microenterprises always exempt?
No. Microenterprises providing services may be exempt from the Article 4(3) service duties; product microenterprises are not automatically exempt—they have lighter duties and may skip the Article 14(3) written assessment record. Confirm the microenterprise definition first.
Is WCAG enough?
No. WCAG/EN 301 549 are common technical references, but the EAA also requires Annex V information, ongoing conformity procedures, corrective action/notification and exception assessment/records. Technical compliance is not the same as complete legal evidence.
What about contracts signed before 28 June 2025?
Service contracts may continue until expiry, but no longer than five years from 28 June 2025; the transition period runs to 28 June 2030, during which service providers may continue to use products lawfully used before that date. Check Member State law and contract terms.
How is "disproportionate burden" used?
Assess compliance costs/benefits/enterprise size under Annex VI to show the burden is disproportionate; document the assessment and keep it for five years for authorities. Product microenterprises may skip the written record, but that is not an automatic exemption.
What product documents are needed?
Typically conformity assessment/technical documentation, EU declaration of conformity, labels/importer information, etc., depending on the product category and Member State law. Chinese manufacturers should confirm the file package with the EU importer/authorised representative.
What happens for non-compliance?
Member States must set effective, proportionate and dissuasive penalties with corrective/remedy mechanisms; delisting, recall, platform restrictions and customer claims are also possible. Specific penalties follow national law.
Research method and limitations
This article separates "legal facts" from "editorial interpretation." The EAA adoption/transposition/application dates, product/service scope, e-commerce definition, microenterprise exception, Article 13 service duties, Article 14 exception assessment, Article 30 penalties and Article 32 transition come from the EUR-Lex text of Directive (EU) 2019/882 and the European Commission EAA page (accessed 8 November 2026); the 90-day checklist and "evidence/action" columns are editorial. The EAA is transposed into national law, so enforcement/penalties/procedures may differ by Member State.
Eight limitations: (1) this is not legal advice; (2) national transposition/penalties/authorities are not checked country by country; (3) product/service scope and "consumer" status depend on the specific business; (4) not all Annex I technical clauses are covered; (5) the WCAG/EN 301 549 to EAA mapping needs case-specific/competent-authority confirmation; (6) microenterprise/exception assessment depends on actual size/cost; (7) interactions with GPSR/CRA/machinery/battery rules are not mapped clause by clause; (8) the law/guidance may update, so recheck the official text before publishing or transacting.
Sources and basis
- EUR-Lex, Directive (EU) 2019/882 (European Accessibility Act): eur-lex.europa.eu/eli/dir/2019/882/oj/eng. Articles 2, 4, 13, 14, 30, 32 and Annexes I/V/VI. Accessed 8 November 2026.
- European Commission, European Accessibility Act (EAA): ec.europa.eu/social/main.jsp?catId=1202. Scope, transposition timing, product/service list, related documents. Accessed 8 November 2026.
- European Commission, EAA page (English): commission.europa.eu/.../european-accessibility-act-eaa_en. Scope, implementation, related news. Accessed 8 November 2026.
Data cut-off 8 November 2026; EAA duties/penalties follow Directive (EU) 2019/882, Member State law and competent authorities; this is not legal advice.