The first set of regulations of the European Accessibility Act (EAA) 2019, came into effect in June 2025. The act is designed to harmonise accessibility requirements for a range of products and services across the European Union. It has major implications for several categories of IoT and smart technologies.

The act’s primary goal is to make a variety of essential products and services accessible to people with disabilities, including those with vision, hearing, cognitive, and motor impairments, as well as the elderly.

Although supporting the broad intentions of the act, many manufacturers and service providers are reporting finding the regulations difficult to navigate and to implement in practice.

Products and Sectors Affected

The EAA impacts the design, development, and provision of IoT, embedded, and smart devices and the applications that run on them, where these might be used by people with disabilities, and the elderly. It aims to create a unified set of rules for consumer products and services. For manufacturers and service providers, this means that new products and services must be designed with accessibility “from the ground up.”

The act means that consumer devices, smartphone apps, smart home technologies, health devices, transportation devices and kiosks must be accessible across a range of disabilities and impairments, including cognitive.

Certain sectors are prioritised in the EAA. This means that there is greater stress on compliance, and greater penalties for failure to comply. These sectors can be defined as essential or common services. They include consumer, banking, retail, transportation, entertainment, telecommunications, healthcare, and home products. Any devices or products in these areas have to comply with the EAA.

In addition, categories of products have to comply, irrespective of the sector they apply to. These include consumer electronics, self-service machines, check-in machines, information kiosks, electronic communications devices, and e-book readers.

Implementation Timetable

The EAA was approved in 2019 by the Parliament and Council of the EU. By July 2022, all national parliaments within the EU had to incorporate the EU legislation into their own national law.

The act effectively came into force in July 2025, when national measures implementing the EAA became applicable. From this date, all new products and services covered by the act placed on the EU market must comply with the accessibility requirements.

A transitional period applies for some services. Service providers may continue to use products that were lawfully used before the 2025 deadline to provide similar services until June 28, 2030. Self-service terminals have an even longer transition, as they can be used for up to 20 years after their initial entry into use.

The act provides for “effective, proportionate and dissuasive” penalties. These can include millions of euros in fines, and forced withdrawal of non-compliant products.

Workplace Requirements

Although there is a focus in the act on consumer devices, the EAA can apply with equal force to workplace technology. The EU maintains a swathe of directives and legislation to ensure equal access to the workplace for disabled and ageing workers. The primary legislation is the Employment Equality Directive 2000, which includes Article 5, the Reasonable Accommodation Obligation. But the Union of Equality Strategy 2021, and the European Pillar of Social Rights are also key in this regard. The latter contains Principle 17 which explicitly states that people with disabilities have the right to a work environment adapted to their needs.

The EAA is being interpreted as an extension of workplace legislation. It applies to both public and private sector organisations. The European Agency for Safety and Health at Work (EU-OSHA) underlines that this right to accessibility applies to both disabled and to ageing members of the workforce.

Required Alterations

The EAA requires that devices and products must have a user interface and functionality that is perceivable, operable, understandable and robust for all the groups covered under the act. That includes people with disabilities, including those with vision, hearing, cognitive, and motor impairments, as well as the elderly.

Information and the user interface must be presented in a way that users can perceive it. This includes providing text alternatives for non-text content, and ensuring content can be presented in different forms, such as through screen readers or with high-contrast modes.

Devices and systems must also be operable. Users must be able to operate the interface. Navigation should be clear, consistent, and easy to use with assistive technologies.

The content and operation of the user interface must also be understandable. This includes making text readable and understandable. Websites, apps and interfaces must also operate in a predictable way. Content must also be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies.

Accessible Support Services

In addition to making products accessible, there is also an obligation under the act to provide accessible product information, support services, product documentation, packaging and instructions. All these should be designed to maximise their use for people with the range of disabilities designated under the EAA.

Products must be accompanied by accessible information on their functioning and accessibility features. Customer support, help desks, and call centres must be accessible to people with disabilities and provide information about the product’s accessibility features. Manufacturers must also retain technical documentation and an EU declaration of conformity for a period of time to be made available to market surveillance authorities upon request.

Manufacturers’ Experience with EAA

Manufacturers are in the early stages of working with the requirements of the EAA. Some have reported finding the process of compliance challenging, and in some cases, onerous.

The immediate and practical requirements for compliance have been seen by some as a significant burden. In addition, the act is seen as being legally ambiguous. There is considerable uncertainty as to the scope of the act, its practical implications, or to enforcement. This has been complicated by the act’s transposition into 27 different national legislative frameworks, with many different national interpretations and enforcement principles possible.

Companies are reporting particular challenges in evaluating their interfaces and content against the requirements of the act, and ensuring compatibility with a wide range of assistive technologies. Another challenge is designing and implementing accessible user interfaces, and creating accessible customer support services to comply with the act.