The EU Accessibility Act sets out to improve accessibility standards. Adela Buliman outlines what organisations need to consider before it comes into effect
The European Accessibility Act (EAA) represents a significant step forward in making the European Union more accessible to all people, including people with disabilities.
The legislation comes into effect on 28 June 2025. There are many industries in scope, including both the public and private sector.
The EAA is extending the reach of the existing Public Sector Accessibility Regulations under the EU Web Accessibility Directive.
Under current regulations, any organisation that is at least 50 percent funded by the state has to have a digitally accessible website, mobile app and digital documents, where relevant. The EAA is expanding this.
Scope of legislation
The EAA is much broader in scope than the public sector regulations.
The products covered by the Act include:
- ATMs
- Ticket and travel check-in machines
- Self-service terminals
- Mobile phones
- Computers, terminals and operating systems
- E-reading devices
The services covered include:
- Audio-visual media services
- Transportation services
- Banking services
- Electronic communications services
- E-books
- E-commerce
The services covered are much broader than it may seem.
For instance, when it comes to banking services, it is not just the digital assets that are in scope, but anything a user is required to interact with to use a service. So, a letter that the bank may send you with your card pin must have a digitally accessible alternative.
As well as this, when you look at the definition of “e-commerce” under the legislation, it is not just for retail companies, it is any organisation that either sells a product or service on a website or advertises that product or service online.
For example, the organisation may be in the insurance sector, but if it advertises its insurance plans online, it would be within the scope of this legislation too.
Taking all this into account, there are very few organisations that are not in scope of this legislation.
Regulators
Surveillance authorities have been assigned to each in-scope industry. The Competition and Consumer Protection Commission (CCPC) is the regulator for each product that is in scope.
For services, the following bodies are regulating:
Industry
|
Regulator
|
Electronic Communications
|
Commission for Communications Regulation
|
Audiovisual media
|
Coimisiún na Meán
|
Air passenger transport
|
Irish Aviation Authority
|
Bus, rail and waterborne passenger transport
|
National Transport Authority
|
Consumer banking
|
Central Bank of Ireland
|
E-books and dedicated software and e-commerce
|
Competition and Consumer Protection Commission (CPCC)
|
Emergency communications
|
Commission for Communications Regulation
|
Ramifications for non-compliance
It is important to note the consequences of non-compliance with the EAA:
- A fine (€5,000) or imprisonment of up to six months or both;
- A fine of up to €60,000 or imprisonment of up to 18 months or both; or
- Litigation
The one that poses the most risk to organisations is litigation. Under the EAA, users will be allowed to litigate against companies that they feel are discriminating against them.
Next steps for organisations
When it comes to getting ready for the legislation, there are three steps that we recommend:
Auditing
An audit is a great way to start your journey. An audit will provide you with an issue log of items that need to be fixed to be accessible and compliant.
Upskilling
Upskilling your own staff is an important second step in preparing for the EAA.
When you receive audit results, there will be a large amount of repetition in the types of issues found, highlighting a knowledge gap that you can fill by training staff.
Embedding
The last step is embedding accessibility into your company culture.
It can be up to 30 times more expensive to retroactively make something accessible.
Embedding the accessibility into your procurement process, design process, sprints, etc., allows you to keep costs low and create a long-term accessibility plan.
Adela Buliman is the Head of Accessibility at Vially and sits on the European Committee for Standardisations, in particular committees relating to the European Accessibility Act and Public Sector Accessibility Regulations