VPAT® and Accessibility Conformance Reports
Independent ACRs for Section 508, WCAG 2.2 and EN 301 549, written from real test evidence.
International · Updated October 2026
The European Accessibility Act: what US companies need to know
If you sell products or digital services to consumers in the European Union, the EAA likely applies to you — wherever your company is based.
What the EAA is
The European Accessibility Act (Directive (EU) 2019/882) sets common accessibility requirements for key products and services across all EU member states. Each country passed its own implementing law, and the requirements have applied since June 28, 2025.
What’s in scope
Services provided to consumers, including:
- Ecommerce — any website or app selling products or services to consumers
- Consumer banking — online and mobile banking, payment services, credit agreements
- E-books and e-reading software
- Passenger transport — websites, apps, ticketing and real-time travel information for air, bus, rail and waterborne transport
- Electronic communications — telephony, messaging, emergency communications
Products, including computers and operating systems, smartphones, tablets, e-readers, smart TVs with interactive features, routers, ATMs, ticketing and check-in machines, and payment terminals.
Transition periods
- Service contracts agreed before June 28, 2025 can continue unchanged until they expire, but no later than June 28, 2030.
- Products already lawfully used to provide services before that date may continue to be used until June 28, 2030.
- Self-service terminals already in use may remain until the end of their economically useful life, up to 20 years.
New websites, apps and products placed on the market after June 28, 2025 must comply now.
The technical standard
The EAA itself describes functional requirements. Compliance is presumed when you meet the harmonized standard EN 301 549, whose web and mobile requirements align with WCAG 2.1 Level AA. Service providers must also publish information explaining how their service meets the requirements — in effect, an accessibility statement.
Penalties
Each member state sets its own penalties, which the directive requires to be “effective, proportionate and dissuasive.” They vary widely: some countries provide for fines that can reach six figures in euros, and market surveillance authorities can require non-compliant products to be withdrawn from the market. Consumer organizations can also bring complaints.
For US companies: one program, two markets
The good news: the work is largely the same as for US law. A product built to WCAG 2.2 AA, documented with an ACR on the VPAT INT edition (covering Section 508, WCAG and EN 301 549), and supported by an accessibility statement puts you in a strong position on both sides of the Atlantic.
Frequently asked questions
Does the EAA apply to American companies?
Yes, if they place covered products on the EU market or provide covered services to consumers in the EU. Location of the company doesn’t matter; the EU customer does.
Is there a small-business exemption?
Microenterprises — fewer than 10 employees and annual turnover or balance sheet total of no more than €2 million — are exempt from the requirements for services. Microenterprises dealing in products are not exempt, though they have lighter obligations.
What standard should we meet?
The harmonized standard EN 301 549, which for web and mobile content aligns with WCAG 2.1 Level AA. Meeting WCAG 2.2 AA covers it.
Find out where you stand, in writing.
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