Resource guide
Who Does It Apply To?
Products, services, exemptions, and how to work out whether your organisation is in scope.
By Calling All Minds·Last updated April 2026
Employees for micro exemption
AND turnover under €2m — both required.
Final compliance deadline
All existing content must comply by then.
Service categories in scope
E-commerce, banking, telecoms, and more.
Who does it apply to?
Products in scope
The EAA covers consumer products identified as most important for people with disabilities. These include:
- Computers and operating systems — desktops, laptops, and tablets
- Smartphones and their operating systems
- E-readers
- Consumer TV equipment and set-top boxes
- Self-service terminals — ATMs, payment terminals, ticketing machines, check-in kiosks, interactive information terminals
For physical products, the requirements extend beyond the product itself. Packaging, instructions, and labelling must also be accessible.
Who does it apply to?
Services in scope
This is where most website and app owners need to pay attention. The following services must comply:
- E-commerce — any online shop selling to EU consumers, regardless of where the business is based
- Banking and financial services — online banking, payment services, investment platforms
- Telecommunications — phone services, messaging, video calling
- Audiovisual media services — streaming platforms, video-on-demand, broadcast services
- Transport services — websites, apps, ticketing, and real-time travel information
- E-books and dedicated reading software
E-commerce is broadly defined
The EAA applies to any provider offering e-commerce services to EU consumers, even if you are based outside the EU. If someone in the EU can buy from your website, the website itself must be accessible.
Who does it apply to?
Who is exempt?
The EAA includes a small number of exemptions, but they are narrower than many organisations expect.
Micro-enterprise exemption
Micro-enterprises providing services are exempt. A micro-enterprise is defined as a business with fewer than 10 employees AND an annual turnover or balance sheet total not exceeding €2 million. Both conditions must be met. Note this exemption does not apply to products.
Undue burden
Organisations can claim an exemption if compliance would impose a disproportionate burden. This is a narrow defence requiring formal documentation. Regulators can challenge it, and it must be renewed whenever the product or service changes.
Fundamental alteration
If meeting accessibility requirements would fundamentally alter the basic nature of the product or service, an exemption may apply. Again, this must be carefully documented and is subject to challenge.
Content-specific exemptions
Pre-recorded time-based media published before 28 June 2025, third-party content not funded or controlled by the organisation, and archived content that will not be updated after 28 June 2025.
Do not rely on exemptions as a strategy
Claiming undue burden or fundamental alteration is risky. Regulators expect thorough documentation, and incorrect reliance on an exemption could lead to enforcement action. The safer path is to plan for compliance from the start.
Who does it apply to?
Transitional provisions
- Self-service terminals lawfully in use before 28 June 2025 can continue until the end of their economic life, but no longer than 20 years from first use.
- Service contracts agreed before 28 June 2025 can continue without alteration until they expire, but no longer than five years (by 28 June 2030).
- All existing digital content must be fully compliant by 28 June 2030.
Who does it apply to?
What about UK businesses?
The EAA applies to any organisation that offers products or services to consumers in the EU, regardless of where the organisation is based. This is a critical point for UK businesses post-Brexit.
If you run an e-commerce website that ships to EU countries, or provide a digital service accessible to EU residents, you are in scope. Being based in the UK does not provide an exemption.
🇬🇧 UK organisations
The UK has its own accessibility requirements under the Equality Act 2010. The Public Sector Bodies Accessibility Regulations 2018 additionally require public-sector websites to meet WCAG 2.1 AA. Meeting WCAG 2.2 AA satisfies both UK and EU frameworks.
Who does it apply to?
Quick scope check
Do you offer products or services to consumers in the EU? If yes, continue.
Are they in scope categories — e-commerce, banking, telecoms, transport, audiovisual media, e-books, or covered hardware? If yes, continue.
Do you employ 10 or more people, or have a turnover or balance sheet exceeding €2 million? If yes, continue.
If yes to all three — the EAA applies to you.
Even if you are exempt as a micro-enterprise, compliance is good practice and may be required under other legislation such as the UK Equality Act or the US ADA.
AXS Audit
AXS Audit evaluates your website against the full WCAG 2.2 matrix — visual, cognitive, and keyboard criteria that most automated scanners miss. Built by the same team that created this guide.