European Accessibility Act, WCAG, RGAA — your questions, answered

The European Accessibility Act (EAA), Directive (EU) 2019/882, is an EU directive adopted on 17 April 2019 that sets harmonized accessibility requirements for a list of products and services sold or provided within the European Union, so that people with disabilities can access them under comparable conditions to other users.

Member States had to transpose the directive into national law by 28 June 2022 at the latest. The obligations came into application on 28 June 2025 for products and services placed on the market from that date. Transitional periods exist for certain ongoing service contracts and for self-service terminals already installed (see below).

Manufacturers, importers, distributors and service providers that place the covered products and services on the European market: e-commerce sites, banks and payment services, telecom operators and their sites/apps, transport carriers (travel information), e-readers and e-books, hardware manufacturers, and self-service terminals (ATMs, ticketing machines), among others.

Yes. The EAA applies whenever a covered product or service is placed on the European market or provided to consumers in the EU, regardless of where the company is established — the trigger is the target market, not the company's headquarters.

Microenterprises (fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million) are exempt from the service-related obligations. This exemption does not apply to other companies, including SMEs, which remain subject to the obligation even though support measures may exist depending on the Member State.

Among others: computers and operating systems, self-service terminals (ATMs, ticketing machines, check-in kiosks), smartphones, TV equipment related to audiovisual media services, telecommunications services, access to audiovisual media services, consumer banking services, e-books, e-commerce, and certain passenger transport services.

The RGAA (Référentiel Général d'Amélioration de l'Accessibilité) is the French accessibility framework, historically mandatory for the public sector and large companies above a certain revenue threshold. The EAA broadens the obligation to additional private-sector actors (banks, e-commerce, telecom, transport...) across the whole European Union. In France, the EAA's transposition relies on existing technical frameworks (RGAA, WCAG) to assess compliance.

The European standard EN 301 549 serves as the technical reference for presumption of conformity with the EAA; it is itself aligned with WCAG 2.1 level A and AA success criteria. In practice, an audit covering WCAG 2.1/2.2 AA (and, in France, the RGAA that derives from it) forms the technical basis of compliance.

Each Member State designates its own market surveillance authorities and sets its own penalty regime (formal notices, fines, mandatory compliance deadlines): exact amounts and procedures vary by country. Beyond regulatory risk, effectively excluding part of your users also carries commercial and reputational risk. Local legal counsel is recommended to assess a given company's precise exposure.

Transitional provisions exist: service contracts concluded before 28 June 2025 may continue to run unchanged until their expiry, up to a maximum of 5 years, and self-service terminals already in use by service providers may remain in service until the end of their economic lifetime, up to a maximum of 20 years. These grace periods apply to specific cases and don't remove the need to plan ahead for compliance.

An RGAA audit covers a large share of the technical baseline expected by the EAA, but the two frameworks don't overlap perfectly: some EAA criteria concern product or service requirements that go beyond the website itself (documentation, customer support, physical terminals). We recommend treating WCAG and RGAA as two independently tested frameworks — see our methodology — then checking the EAA scope specific to your business activity.

A scoping exercise (which products/services are covered for your activity), a technical WCAG/RGAA audit with real evidence rather than assumptions, prioritizing defects by severity and leverage, then a documented remediation plan form a solid foundation. See our Methodology page for the details of our approach.