European Accessibility Act (Directive (EU) 2019/882)

Directive (EU) 2019/882 sets accessibility rules for certain products and consumer services from 28 June 2025.

21 October 2026 · Category: Accessibility · Compliance-Kit

TL;DR

The European Accessibility Act is Directive (EU) 2019/882 on the accessibility requirements for products and services. It applies to certain products placed on the market after 28 June 2025 and to certain services provided to consumers after that date, such as consumer banking services and e-commerce (Art. 2(1) and (2)). Member States apply their transposing measures from 28 June 2025 (Art. 31(2)). Germany transposes the Directive through the BFSG (footnote to the title of the act), Austria through the BaFG (§ 44 BaFG).

What is the European Accessibility Act?

The European Accessibility Act is Directive (EU) 2019/882. It approximates the accessibility requirements for certain products and services in the Member States in order to contribute to the smooth functioning of the internal market (Art. 1). Member States had to adopt and publish their transposing measures by 28 June 2022 and apply them from 28 June 2025 (Art. 31(1) and (2)).

Products placed on the market after 28 June 2025 (Art. 2(1)): consumer general purpose computer hardware systems and their operating systems, self-service terminals such as payment terminals, ATMs, ticketing machines and check-in machines, consumer terminal equipment with interactive computing capability used for electronic communications services and for accessing audiovisual media services, and e-readers.
Services provided to consumers after 28 June 2025 (Art. 2(2)): electronic communications services, services providing access to audiovisual media services, elements of passenger transport services, consumer banking services, e-books and dedicated software, and e-commerce services.

Websites and mobile apps of these services must be perceivable, operable, understandable and robust (Annex I Section III point (c)). For websites and mobile applications, the Directive does not apply, among other things, to office file formats published before 28 June 2025 or to archives whose content is neither updated nor edited after that date (Art. 2(4)(b) and (e)). Microenterprises providing services are exempt from the requirements for services under Art. 4(3) and from all related obligations (Art. 4(5)). The requirements also apply only insofar as they do not cause a fundamental alteration of the product or service or a disproportionate burden (Art. 14(1)). Products and services that conform with harmonised standards whose references have been published in the Official Journal of the EU are presumed to conform, to the extent those standards cover the requirements (Art. 15(1)).

Germany and Austria compared

Both countries have transposed the Directive in their own acts, with almost the same scope and differences in transitional periods and sanctions.

Germany

The BFSG transposes Directive (EU) 2019/882 (footnote to the title of the act). It applies to products placed on the market after 28 June 2025 and to services provided to consumers after that date (§ 1(2) and (3) BFSG), including e-commerce (§ 1(3) no. 5 BFSG). Office files published before 28 June 2025 and archives whose content is neither updated nor edited after that date are excluded (§ 1(4) nos. 2 and 5 BFSG). Microenterprises offering or providing services are exempt from the accessibility obligation (§ 3(3) BFSG). The presumption of conformity is linked to harmonised standards (§ 4 BFSG). Anyone who intentionally or negligently offers or provides a service contrary to § 14(1) BFSG commits an administrative offence; the fine can reach 100,000 euros (§ 37(1) no. 8 and (2) BFSG). Read more in the article BFSG for companies and documents.

Austria

The BaFG transposes the Directive (§ 44 BaFG) and entered into force on 28 June 2025 (§ 37(1) BaFG). It applies to products placed on the market after that date and to services provided to consumers after that date (§ 2(1) and (2) BaFG), including e-commerce (§ 2(2) item 6 BaFG). Office files published before 28 June 2025 and archives not updated after that date are excluded (§ 2(3) items 2 and 5 BaFG). Microenterprises offering or providing services are exempt from the requirements for services (§ 6(1) BaFG). The presumption of conformity is linked to harmonised standards (§ 5(1) BaFG). Anyone who offers or provides a service contrary to § 14(1) BaFG commits an administrative offence and is to be fined by the Sozialministeriumservice up to 80,000 euros, or up to 50,000 euros as a microenterprise or SME (§ 36(1) item 3 BaFG). Read more in the article BaFG for companies in Austria.

Point	Directive (EU) 2019/882	BFSG (DE)	BaFG (AT)
Continuing services with products already in use	Transitional period ends on 28 June 2030 (Art. 32(1))	until 27 June 2030 (§ 38(1))	until 28 June 2030 (§ 37(2))
Self-service terminals in use before 28 June 2025	Member States may allow up to 20 years after entry into use (Art. 32(2))	up to 15 years (§ 38(2))	up to 20 years, at the latest until 28 June 2040 (§ 37(3))
Exemption for microenterprises providing services	Art. 4(5)	§ 3(3)	§ 6(1)
Sanction for a non-accessible service	Member States lay down effective, proportionate and dissuasive penalties (Art. 30(1) and (2))	fine up to 100,000 euros (§ 37(1) no. 8, (2))	fine up to 80,000 euros, microenterprises and SMEs up to 50,000 euros (§ 36(1) item 3)

Practical example

Suppose an online retailer sells to consumers in Germany and Austria and is not a microenterprise. Its shop falls under e-commerce services (Art. 2(2)(f); § 1(3) no. 5 BFSG; § 2(2) item 6 BaFG). After 28 June 2025 it publishes a guide to the customer account as a PDF created in Word and a PowerPoint presentation on returns on its website.

The exemption for office files does not apply, because it only covers files published before 28 June 2025 (Art. 2(4)(b); § 1(4) no. 2 BFSG; § 2(3) item 2 BaFG).
Information about how the service works must be available in text formats suitable for generating alternative assistive formats, and non-text content needs an alternative presentation (Annex I Section III point (b)(iv) and (vi)). For the two files this means, for example, real text instead of scanned pages and alternative text for charts.
In its general terms and conditions or a similar document, the retailer states how its service meets the accessibility requirements (Annex V point 1). It makes this information available to the public in written and oral form, including in an accessible format (Art. 13(2)).

If you prefer not to convert such files yourself, you can have your documents made accessible. This entry is not legal advice. Whether your offer is covered must be assessed case by case.

Frequently asked questions

Does the European Accessibility Act apply to PDF documents?

For PDF files on websites and in apps of covered consumer services, the exemption for office files only applies if they were published before 28 June 2025 (Art. 2(4)(b)). The BFSG and BaFG adopt this exemption (§ 1(4) no. 2 BFSG; § 2(3) item 2 BaFG). Archives whose content is neither updated nor edited after 28 June 2025 are also excluded (Art. 2(4)(e)).

Are microenterprises exempt from the European Accessibility Act?

Partly. Microenterprises employ fewer than ten persons and have an annual turnover or balance sheet total of no more than 2 million euros (Art. 3 point 23). If they provide services, they are exempt from the requirements for services and from all related obligations (Art. 4(5); § 3(3) BFSG; § 6(1) BaFG). For microenterprises dealing with products, this exemption does not apply. However, they do not have to document their assessment of a disproportionate burden (Art. 14(4)).

From when do the requirements apply?

Member States apply their measures from 28 June 2025 (Art. 31(2)). Covered are products placed on the market after that date and services provided to consumers after that date (Art. 2(1) and (2)). For services using products already in use, the transitional period ends on 28 June 2030 (Art. 32(1)), under the BFSG on 27 June 2030 (§ 38(1) BFSG), under the BaFG on 28 June 2030 (§ 37(2) BaFG).

Sources

Directive (EU) 2019/882 on the accessibility requirements for products and services (European Accessibility Act), Art. 1; Art. 2 Abs. 1, 2 und 4 lit. b und e; Art. 3 Nr. 23; Art. 4 Abs. 3 und 5; Art. 13 Abs. 2; Art. 14 Abs. 1 und 4; Art. 15 Abs. 1; Art. 30 Abs. 1 und 2; Art. 31 Abs. 1 und 2; Art. 32 Abs. 1 und 2; Anhang I Abschnitt III lit. b Ziffer iv und vi, lit. c; Anhang V Nr. 1, eur-lex.europa.eu
Barrierefreiheitsstärkungsgesetz (BFSG), Germany, Fußnote zum Titel; § 1 Abs. 2, Abs. 3 (Nr. 5), Abs. 4 Nr. 2 und 5; § 3 Abs. 3; § 4; § 37 Abs. 1 Nr. 8 und Abs. 2; § 38 Abs. 1 und 2, gesetze-im-internet.de
Barrierefreiheitsgesetz (BaFG), Austria, consolidated version, § 2 Abs. 1, Abs. 2 (Z 6), Abs. 3 Z 2 und 5; § 5 Abs. 1; § 6 Abs. 1; § 36 Abs. 1 Z 3; § 37 Abs. 1 bis 3; § 44, ris.bka.gv.at

Legal status of the sources checked: 19 October 2026 (RIS, gesetze-im-internet.de, EUR-Lex)

Practitioner note: This article is practice-oriented compliance documentation, not legal advice. We are compliance specialists, not a law firm. For legally binding advice, consult an admitted lawyer.