Summertime is here – accessibility is in the air


Right now, accessibility is on everyone's lips. The combination of rapid and widespread digitisation, new legal requirements from the European Commission and a greater number of users who react to technology fatigue in the wake of the pandemic, means that the focus is on "our" issues. However, there is still some confusion about the key aspects EU legislation on accessibility.

Susanna Laurin
Title: Chief Research and Innovation Officer

It has probably never been more exciting to work in accessibility. Technology is evolving and the market is growing at lightspeed. Major players in e-commerce, transport and technology sectors are preparing for the new directive and questioning old truths about which solutions "usually" work. At the same time, reviewing the monitoring of the current directive has just been completed. Very soon, the European Commission's new mandate will be published, which gives standardisation organisations the task of developing and updating no less than 6 standards!

In many ways, the EU is a frontrunner in accessibility - except for its own institutions, which are still not in scope of the legislation … The European standard EN301549 is being implemented in more and more countries outside the EU and we are currently ahead of the US when it comes to technical specifications. In addition, EU member states have just conducted the world's largest accessibility audit - where more than 10,000 websites have been checked through national monitoring. The art of monitoring, the requirements for self-declaration through accessibility statements and the feedback mechanism involving end users are somewhat unique activities that arouse great international interest.

In our everyday lives, we are of course happy about all of this, but we notice that many of our clients, not least among the generalist ICT companies, have difficulty distinguishing between apples and pears. Therefore, here is a small attempt to sort out the concepts.

The two directives that are mixed up are:

  • The Web Accessibility Directive (WAD), and
  • The European Accessibility Act (EAA)

These laws are technically both directives, so it's not surprising that they are mixed up.

Another misconception that we often encounter is that the Accessibility Act would cover the "private sector". However, the Accessibility Act covers certain products and services - regardless of the type of organisation behind them.

An overall comparison between the two directives can be found below:
(please note that not all details are included the table)

If you want to know more - feel free to contact us.

An overall comparison between the two directives can be found below
  Web Accessibility Directive European Accessibility Act
In scope

Public sector bodies

Bodies governed by public law

(plus, some additional sectors in various member states going beyond the minimum requirements)


Authorised representatives


Distributors of specific products and services (see next box)

Not in scope

Public broadcasters


Micro enterprises providing services, i.e. companies with less than 10 employees and a turnover/balance sheet of less than 2M EURO
What should be accessible





Mobile apps

Computers and operating systems

Self-service terminals

Digital TV and streaming services

E-books and e-readers

Emergency communication

Transportation (digital services)


Consumer banking services

Minimum requirements EN301549 v 3.2.1 Annex A

Updated requirements of:




Plus, three new standards defining requirements for:

non-digital information

customer support/service centre

emergency number (112)

From when Now 28th of June 2025
Some parts can be applicable later
Monitoring carried out Yes Yes
Accessibility Statement required Yes Yes
Feedback mechanism required Yes Yes
Complaints mechanism in place Yes Yes
Alternative formats provided Yes Yes
Disproportionate burden clause Yes Yes
Possible penalties In theory, yes Yes. And products can be taken off market.

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