The European Accessibility Act and what it means for small and medium businesses

If you've recently heard about the European Accessibility Act and found yourself wondering whether it applies to your business, you're not alone.

For many small and medium businesses, accessibility can feel like another complex compliance requirement to navigate. The good news is that it doesn't have to be.

This article explains what EAA means, who it applies to and the practical steps you can take to understand your current position and prepare with confidence.

What is the EAA?

The European Accessibility Act (EAA) is an important EU Directive that introduces mandatory minimum accessibility requirements for certain products and services in the EU.

The Directive came into effect on 28 June 2025.

In simple terms, the EAA is an EU-wide directive. While the requirements are consistent across the EU, each member state is responsible for incorporating them into local law and enforcing compliance.  In Ireland, the EAA was transposed into Irish Law through Statutory Instrument No. 636 of 2023.

For most businesses, the key date to be aware of is 28 June 2025. Any new products or services covered by the EAA and placed on the market from this date must meet the accessibility requirements. Existing products and services placed on the market before this date generally have until 28 June 2030 to comply.

What is the purpose of the EAA?

The Directive advocates for a universal design or ‘design for all’ approach to accessibility, which means ensuring access to products and services for persons with disabilities on an equal basis with others.

In simple terms, the EAA is designed to make sure digital products and services can be used by as many people as possible, including people with disabilities.

For many businesses, this isn't about rebuilding your website or mobile app from scratch. It's about understanding where barriers exist and having a plan to address them.

What products and services does the EAA cover?

The Directive covers a range of commonly used products and services that are important for daily life, including:

• Computers and operating systems

• ATMs, ticketing and check-in machines

• Smartphones

• TV equipment related to digital television services

• Telephony services and related equipment

• Access to audio-visual media services such as television broadcast and related consumer equipment

• Services related to air, bus, rail, and waterborne passenger transport

• Banking services

• E-books

• E-commerce.

Who does the EAA apply to?

The EAA will apply to any company that wishes to trade in the EU, regardless of where that company is based.

Manufacturers, importers, and distributors must ensure that, for the products and services covered by the EAA, only those in compliance with its requirements are placed onto the EU market.

What does this mean in practice?

The EAA requirements focuses on removing barriers that prevent people with disabilities from accessing digital products and services.

Imagine a customer trying to complete a purchase on your website using a screen reader. If they can't find the checkout button, understand the form fields or complete the payment process independently, you've created a barrier that may prevent them from becoming a customer.

In practical terms, this means asking questions such as:

• Can someone navigate your website using only a keyboard?

• Can a screen reader understand your content?

• Are the forms, buttons and links easy to identify and use?

• Can people with visual impairments access important information?

Why is accessibility important to small and medium businesses?

One of the biggest misconceptions about accessibility is that it's only relevant to people with disabilities. But accessibility isn't just about ticking boxes. It's about removing barriers.

In reality, many accessibility improvements make products easier for everyone to use.

Clear navigation, readable content, well-structured forms and intuitive user journeys benefit all users, regardless of ability. When people can find what they need, complete tasks easily and interact with your business without frustration, they're more likely to become, and remain, customers.

Even if your business is exempt from the requirements of the European Accessibility Act, accessibility still makes good business sense. It can help you reach more customers, improve customer satisfaction, reduce support requests and create a better overall digital experience.

Are there any exemptions to the EAA requirements?

There are some scenarios in which an exemption is available or in which the business or operator may request an exception. However, when applying for an exception, the EAA still requires the business or operator to make the product as accessible as possible.

EAA Exceptions: Fundamental Alteration and Disproportionate Burden

There are two possible exceptions available to businesses or operators: fundamental alteration and disproportionate burden. In both cases you must satisfy certain requirements and it is important to note that exceptions should only be applied for in exceptional circumstances.

Fundamental alteration is when the implementation of the EAA requirements would cause a significant change that results in the fundamental alteration of the basic nature of the product or service.

Disproportionate burden is (in the context of the EAA,) compares the burden of applying an accessibility requirement with the benefit of the accessibility requirement.

Information about the fundamental alteration and disproportionate burden can be found in Part 6 of the S.I. No. 636/2023.

Micro-enterprises providing services

Micro-enterprises (fewer than 10 employees AND less than €2 million turnover) are generally exempt from the obligations and requirements of the EAA when providing services.

Not sure where to start?

The biggest challenge for many businesses isn't fixing accessibility issues. It's understanding where they stand today.

Our Accessibility Audits are designed to do exactly that. We review your key user journeys, identify barriers, assess risk and provide a practical roadmap for improvement.

Our goal is to help you move forward with clarity and confidence.

If you'd like to know more, email us at hello@empathyedgeux.com and let us help you with your accessibility goals.