(EU) 2019/882 EU Accessibility Act Compliance Assessment Service

The European Accessibility Act (EAA), also known as Directive (EU) 2019/882, will officially come into effect on June 28, 2025. This bill is a supplement and extension to the EU Directive on Web Accessibility (EU 2016/2102). The EU Directive (EU) 2016/2102 specifies requirements for accessibility of public sector websites and mobile applications, including services such as passenger transport and e-commerce.

After the release of the new bill, regardless of whether the seller is a public institution or a private enterprise, their website and application must also comply with the accessibility standards of Directive (EU) 2019/882 to ensure equal access to online products and services for people with disabilities. At the same time, by coordinating the laws, regulations, and administrative provisions of member states regarding accessibility requirements for certain products and services, barriers to the free flow of certain accessibility products and services arising from differences in accessibility requirements among member states can be eliminated and prevented, thereby promoting market operations.

From June 28, 2025, ICT products and services launched or provided in the European market must comply with the Accessibility Act. Services provided and contracted before June 28, 2025: can continue to be used during the validity period of the contract, but with a maximum transition period of 5 years, and must be fully implemented by June 28, 2030. Self service terminals used to provide services before June 28, 2025 can continue to be used to provide similar services until their service life ends, but not exceeding 20 years after they are put into use.

What products are covered by Directive (EU) 2016/2102?

Consumer general-purpose computer hardware systems and their operating systems - computers and operating systems, personal computers, especially desktops and laptops; Self service terminal: Payment terminal - POS machine; The following self-service terminals are dedicated to providing the services covered by this directive: Automated Teller Machines (ATMs); Ticket vending machines; Self service check-in terminal; Interactive self-service terminals that provide information, excluding terminals installed as integrated components of vehicles, aircraft, ships, or locomotives; Consumer terminal devices and their auxiliary devices with interactive computing capabilities for electronic communication services: smartphones, tablets, routers, optical cats, etc; Audiovisual media service terminal; Electronic readers.

● Computers and operating systems

● Self service terminals (such as ATMs, ticket machines)

● Smartphones

● Television equipment

● E-book reader

What services are covered by Directive (EU) 2016/2102?

Electronic communication services, except for transmission services used to provide machine to machine services; Provide access to audiovisual media services; The following elements of air, bus, railway, and water passenger services, except for urban, suburban, and regional transportation services, only apply to the elements under point (5): website; Mobile based services, including mobile applications; Electronic tickets and electronic ticketing services; Provide transportation service information, including real-time travel information; In terms of information screens, this should be limited to interactive screens located within the territory of this alliance; Interactive self-service terminals located within the European Union, except for terminals installed as integrated components of vehicles, aircraft, ships, and locomotives, used to provide any part of such passenger services; Personal banking services; Electronic books and specialized software; E-commerce services.

● E-commerce

● Banking services

Transportation services (aviation, bus, railway, water transportation)

● Electronic communication services

● Consumer banking services

E-books and specialized software

Emergency communication services (such as the European emergency number "112") are not applicable to certain content released before June 28, 2025 (such as office documents, map services, etc.).

Which websites and apps are the instructions not applicable to?

Pre recorded time-based media released before June 28, 2025; Office file formats released before June 28, 2025; Online maps and map services, providing important information for navigation maps in accessible digital formats; Third party content that is not sponsored, developed, or controlled by relevant economic operators; The content of websites and mobile applications that meet the archiving criteria, which means they only contain content that has not been updated or edited after June 28, 2025.

Instruction requirements

The design and production of the product should include sufficient instructions related to its use, such as nameplates, instructions, and warning messages; The user interface and functional design of the product should allow people with disabilities to access, perceive, operate, understand, and control it; The support services for the product, including technical support and customer service, should provide accessible communication methods for people with disabilities.

Recommended standards for instructions

EN 301 549, as one of the recommended reference standards for EAA, provides comprehensive guidance for accessible design of information and communication technology (ICT) products and services. Shenzhen Element Testing Co., Ltd. will provide one-stop compliance assessment services in accordance with the EU Accessibility Act and this coordinated standard.

Amazon platform requirements:

Requirements for selling products on Amazon Marketplace: Starting from June 28, 2025, all product information of affected products must comply with the EU Accessibility Act. If any violations are found, we will remove the products in question. In order to meet the requirements, your product must be convenient for disabled sellers to use and comply with the CE marking requirements. For the CE mark, the product must pass a conformity assessment, and after completing the assessment, the manufacturer must obtain a declaration of conformity. After obtaining a declaration of conformity, the manufacturer must affix the CE mark on the product.

Exemptions and Special Policies:

Exemption for micro enterprises: Employees<10, annual turnover ≤ 2 million euros or balance sheet ≤ 2 million euros. Exemption scope: Service accessibility requirements can be exempted, but voluntary compliance is encouraged. Transitional grace period: Old equipment can continue to be used until the end of its economic lifespan (up to 20 years), but upgrades must be completed before 2030.

Suggestions for enterprise response:

By June 28, 2022: EU member states have completed the transformation of their domestic laws.

June 28, 2025: Fully enforced.

Accessibility technology requirements:

EN 301 549, as one of the recommended reference standards for the European Accessibility Act (EAA), provides comprehensive guidance for the accessibility design of information and communication technology (ICT) products and services. Overseas enterprises need to clarify whether their products and services are within the scope of application of EN 301 549. The following are the specific requirements of EN 301 549:

General requirements:

Compatibility: ICT products and services should be compatible with mainstream assistive technologies such as screen readers, magnifying glasses, speech recognition software, etc., to ensure that people with disabilities can use these assistive tools to access products and services without barriers.

● Configurability: Allow users to customize font size, color contrast, speech speed, etc. to meet the visual, auditory, and operational needs of people with different disabilities.

● Documentation and User Support: Product and service documentation should be provided in accessible formats to ensure that people with disabilities can access and understand usage information. At the same time, user support services should also have accessibility, such as providing text chat support, video call support, etc.

Visual accessibility requirements:

Text substitution: All non text content (such as images, icons, charts, etc.) should provide text substitution so that screen readers can read and convey it to visually impaired users.

Color contrast: There should be sufficient color contrast between text and background to ensure that visually impaired users can easily read. The recommended minimum contrast ratio is 4.5:1.

Zoom function: The product should support users to zoom in on interface content, with a minimum zoom ratio of 200%, and the content should not be lost or deformed after zooming in.

Dynamic content: Dynamically updated content (such as scrolling news, real-time notifications, etc.) should ensure that visually impaired users can access information in a timely manner, such as through voice prompts on screen readers.

Requirements for hearing accessibility

Text transcription: All audio content (such as conversations in videos, audio files, etc.) should provide text transcription.

Subtitles and Subtitle Synchronization: Video content should provide subtitles and ensure that subtitles are synchronized with audio content.

● Sound prompt substitution: For functions that rely on sound prompts (such as error prompt sounds, notification sounds, etc.), visual or tactile substitution methods should be provided, such as flashing icons or vibration prompts.

Accessibility requirements for operation

● Keyboard operability: All functions should be operable through the keyboard, ensuring that users with physical disabilities can use the keyboard to navigate and operate products and services.

Voice control: The product should support voice control function so that users with physical disabilities can operate through voice commands.

Simplify the operation process: The operation process should be simplified as much as possible, reducing the steps that users need to perform and avoiding complex interaction methods.

Hardware accessibility requirements

● Physical buttons and interfaces: Hardware devices should provide easy to operate physical buttons and interfaces to ensure that users with physical disabilities can use them conveniently.

● Screen readability: The screen should have good readability, such as high resolution, high contrast, anti glare, etc., to meet the needs of visually impaired users.

● Support for auxiliary input devices: The hardware should support auxiliary input devices (such as external keyboards, mice, touchscreens, etc.) so that users can choose the appropriate input method according to their own needs.

Software accessibility requirements

● Accessibility API: The software should provide accessibility APIs to enable assistive technology to interact with the software, obtain and operate interface elements.

Accessibility of interface elements: All interface elements (such as buttons, menus, input boxes, etc.) should have clear accessibility attributes, such as roles, states, and names, so that screen readers can correctly recognize and communicate them to users.

Error handling and feedback: The software should provide clear error prompts and feedback mechanisms to ensure that disabled users can understand the cause of errors and take appropriate measures.

Requirements for communication accessibility

Real time text (RTT): The communication system should support real-time text functionality so that hearing-impaired users can communicate in real-time. ● Voice call replacement: For voice call functions, alternative methods such as text chat or video calls should be provided to meet the needs of users with different disabilities.

Accessibility of communication protocols: Communication protocols should ensure the transmission and reception of accessible information, avoiding information loss or errors.

Accessibility requirements for mobile devices

● Touch screen operation: Mobile devices should provide easy-to-use touch screen gestures and support user-defined gestures, so that users with physical disabilities can easily use them.

Accessibility of mobile applications: Mobile applications should comply with the requirements of EN 301 549 standard to ensure the accessibility of application interfaces and functions, such as providing voice prompts, text transcription, etc.

Other requirements

Privacy and Security: While implementing accessibility features, it is important to ensure user privacy and data security, and avoid the leakage of user information due to accessibility features.

Continuous improvement: Products and services should undergo regular accessibility assessments and improvements to ensure continuous compliance with the requirements of EN 301 549 standard.

Shenzhen Element Detection Co., Ltd. Service Support:

Policy interpretation and guidance: In depth analysis of EU regulations and policies, detailed interpretation of relevant standards such as EN 301 549, to help enterprises fully understand technical specifications and standards, and provide compliance training for enterprises;

Accessibility testing: According to the EN 301 549 standard, a comprehensive inspection of the company's products is conducted to expose any existing accessibility defects;

Accessibility solutions: Provide targeted and specific accessibility solutions for accessibility defects;

Compliance report/declaration: Based on the evaluation of EN 301 549, issue an accessibility compliance report or accessibility declaration. A list covering product description, accessibility requirements, test results, defect description, and response measures to demonstrate that the product meets the accessibility requirements of the European Union.