The Act is Directive (EU) 2019/882. It has applied since 28 June 2025. It is a directive, not a regulation, which matters more than it sounds and is dealt with near the end.
Question 1 — is what you sell on the list?
The Act does not cover the economy. It names specific products and services.
| Services | Products |
|---|---|
| E-commerce | Computers and operating systems |
| Consumer banking | Payment terminals and ATMs |
| E-books and dedicated software | Ticketing and check-in machines |
| Electronic communications | Smartphones and similar |
| Access to audiovisual media services | TVs and set-top boxes with internet |
| Air, bus, rail and waterborne passenger transport | E-readers |
If you sell B2B software that is none of these, the Act does not reach you directly. Read on anyway, because the last section is the one that will actually cost you time.
Question 2 — do you offer it to consumers in the EU?
The obligation follows the market, not the head office. A company based outside the EU that sells a covered service to EU consumers is in scope; an EU company selling only to businesses is not, because the Act is about consumer-facing provision.
Question 3 — are you a microenterprise providing a service?
If so, you are exempt from the service requirements. The definition is precise and both parts must hold:
Fewer than 10 people, and an annual turnover or balance sheet total not exceeding €2 million.
The exemption covers services, not products. If you manufacture, import or distribute a covered product, being small does not exempt you.
There is also no grace period built into it. Cross either threshold and the exemption stops applying.
What "accessible" means here
The Act itself states functional requirements rather than a technical specification: information must be perceivable, operable, understandable and robust, and provided through more than one sensory channel. Annex I sets those out.
For anything on the web, the practical target is EN 301 549, the European standard for ICT accessibility, whose web chapter adopts WCAG Level A and AA directly. If you are working to WCAG 2.1 AA you are working to the substance of what the Act asks for.
You will see claims that meeting a standard guarantees compliance. Conformity with a harmonised standard cited in the Official Journal creates a presumption of conformity, which is a legal term of art and not the same as immunity. Check which version is currently cited before relying on it.
Why "directive, not regulation" matters
A regulation applies as written across the EU. A directive is transposed into each member state's own law, and the national text is what binds you. Consequences of this worth knowing:
- Penalties are national and vary enormously. Published figures differ by more than an order of magnitude between member states, and some regimes carry non-financial sanctions — market withdrawal, restrictions on providing the service, and in at least one state criminal liability. Any single number quoted as "the EAA fine" is wrong.
- Enforcement is decentralised. Each state designates its own authorities, with different ones for products and for services.
- Deadlines and transitional arrangements can differ in the detail of the national text.
So the document to read is not the directive. It is your own country's transposition of it, and any secondary source — this page included — is a starting point rather than an answer.
The part that catches people who are exempt
Say you are a six-person SaaS company under €2m turnover. The Act very likely does not bind you as a service provider.
Then a customer's procurement questionnaire asks for your accessibility conformance report, with a deadline.
That request is not enforcement of the Act. It is a buyer who is covered — or who sells to a public body that is — managing their own obligation by pushing it down the supply chain. It arrives as a contract term, and no regulatory exemption touches a contract term. In practice this reaches far more small vendors than the Act itself does.
If you need to answer one of those questionnaires
The ACR Builder walks the WCAG 2.1 and 2.2 Level A and AA success criteria — the same ones EN 301 549 Chapter 9 adopts — records your judgement on each, and exports a report you can send. Free, MIT, runs entirely in your browser, no account and no upload.
Open the builderNot sure what the questionnaire is asking for? What a customer actually means when they ask for your VPAT. Publishing a public statement instead? What it has to contain, and why it has to be true.