The European Accessibility Act (Directive 2019/882) has applied since 28 June 2025 to a closed list of products and services sold to consumers in the EU, including e-commerce services, consumer banking, e-books and electronic communications. A SaaS sold only to businesses is not on the list. Microenterprises that provide services, meaning fewer than 10 people and turnover or balance sheet of at most EUR 2 million, are exempt from the service requirements but not from the product ones. EN 301 549 V4.1.1, based on WCAG 2.2, was published in September 2026 and is awaiting citation.
The short answer
The European Accessibility Act is Directive (EU) 2019/882. It has applied since 28 June 2025, and it does not cover every website or app. It covers a closed list of products and services offered to consumers, and the list includes e-commerce services, consumer banking services, electronic communications services, e-books and dedicated software, access to audiovisual media, and parts of passenger transport. If your product is a business tool that only companies buy, it is outside that list on our reading. If consumers in the EU can buy through your website or app, the purchase flow is likely an e-commerce service.
Microenterprises that provide services, meaning fewer than 10 people and either turnover or balance sheet of at most EUR 2 million, are exempt from the accessibility requirements for services. They are not exempt for products. This page is general information, not legal advice, and national laws can add detail.
What the Directive covers
Article 2 of the Directive lists the products and services in scope. For an app or SaaS MVP, the service categories matter most:
| Article 2(2) service | What it means for a software team |
|---|---|
| (a) Electronic communications services | Defined by reference to Directive (EU) 2018/1972, which we did not read; messaging and calling products may fall here, so check the definition |
| (b) Access to audiovisual media services | Players, program guides and apps used to find and watch audiovisual services |
| (c) Air, bus, rail and waterborne passenger transport | Their websites, mobile apps, e-tickets, travel information and self-service terminals |
| (d) Consumer banking services | Consumer credit, certain investment services, payment services, payment account services and e-money, as listed in Article 3(28) |
| (e) E-books and dedicated software | An e-book and the software built to read it |
| (f) E-commerce services | Services provided at a distance, through websites and mobile device-based services, at the individual request of a consumer with a view to concluding a consumer contract (Article 3(30)) |
Article 2(1) lists the products, such as consumer computers and their operating systems, payment terminals, ticketing and check-in machines, consumer terminal equipment used for electronic communications or audiovisual services, and e-readers. A software startup rarely builds these.
Article 2(4) also excludes some content from websites and mobile apps: pre-recorded time-based media and office file formats published before 28 June 2025, online maps where essential navigation information is accessible, third-party content you did not fund, develop or control, and archives that are not updated after 28 June 2025.
Where an AI or SaaS MVP usually lands
This is our reading of the wording, not guidance from the Commission. We searched on 22 October 2026 and found vendor and law-firm articles and some national microenterprise guides, but no Commission document that settles the points below.
- A consumer subscription sold through a website or app (a chatbot, a coaching app, a design tool for individuals): the purchase flow is provided at a distance, by electronic means and at the individual request of a consumer to conclude a consumer contract, which matches the e-commerce services definition in Article 3(30) and recital 42. Whether the product behind the checkout is also covered is not settled by the text, so ask counsel.
- A fintech MVP that offers consumers credit, payments, e-money or payment accounts: consumer banking services, with the additional requirements for identification, electronic signatures, security and payment, and a language level no higher than B2.
- A B2B SaaS, an internal tool or a developer tool: not in Article 2(2), because a consumer is a natural person acting outside their trade, business or profession (Article 3(22)). A public pricing page that businesses use does not make them consumers, but if individuals can also buy, that purchase flow can be in scope.
- A content site or blog that sells nothing to consumers: not a listed service.
The microenterprise exemption
Article 4(5) says microenterprises providing services shall be exempt from the accessibility requirements for services in Article 4(3) and any obligations relating to compliance with them. Article 3(23) defines a microenterprise as an enterprise that employs fewer than 10 persons and has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million.
Three points to get right:
- The money test is either figure. The Directive uses "or" between turnover and balance sheet. The headcount test (fewer than 10 persons) always applies.
- It covers services, not products. Article 4(1) and 4(2) apply to products with no microenterprise exemption. Article 14(4) only relieves microenterprises dealing with products from documenting their assessment of fundamental alteration or disproportionate burden.
- It is a status you have to keep. Hire your tenth person or cross a threshold and the exemption no longer applies to you. Recital 53 says microenterprises and SMEs must in fact meet the requirements of Commission Recommendation 2003/361/EC and the case law aimed at preventing circumvention. That Recommendation has its own rules for partner and linked enterprises, which we did not read, so ask counsel if you share ownership with other companies.
Recital 70 gives the reason: asking a microenterprise to assess proportionality would itself be a disproportionate burden, so the requirements and obligations should not apply to microenterprises providing services in scope. Member States must give microenterprises guidelines and tools (Article 4(6)). Look for your country's guidance if you rely on the exemption, and write the date and the facts behind your decision in your records.
Dates and transition
| Date | What happens |
|---|---|
| 28 June 2022 | Member States had to adopt and publish their national laws (Article 31(1)) |
| 28 June 2025 | National measures apply; the Directive applies to products placed on the market and services provided to consumers after this date (Articles 2 and 31(2)) |
| 28 June 2030 | End of the transition for service providers using products lawfully used before 28 June 2025 (Article 32(1)) |
Service contracts agreed before 28 June 2025 can continue without alteration until they expire, but no longer than five years from that date (Article 32(1)). A service launched now gets no transition.
What the requirements ask for
Annex I Section III applies to every covered service. It asks you to provide information about how the service works in more than one sensory channel and in text formats that assistive tools can reuse, with adequate font size, contrast and spacing, and alternative presentations of non-text content. It asks you to make websites, related online applications and mobile apps accessible in a consistent way, using the four principles that WCAG also uses: perceivable, operable, understandable and, in WCAG's wording, robustness. Where you offer support services, they must give accessibility information in accessible modes of communication.
For e-commerce services, Section IV(g) adds three things: accessibility information about the products and services you sell when you provide it, an accessible identification, security and payment function, and accessible identification methods, electronic signatures and payment services.
Article 14 lets an operator rely on the limits of fundamental alteration and disproportionate burden, but only after a documented assessment. The assessment must be kept for five years, renewed at least every five years or when the service changes, and reported to the authority in the Member State, with an exception for microenterprises. Funding received for accessibility improvements removes the right to rely on disproportionate burden.
The technical standard
Article 15 gives a presumption of conformity to products and services that meet harmonized standards cited in the Official Journal. EN 301 549 is the European standard for ICT accessibility. Ireland's National Disability Authority wrote in September 2026 that:
- V4.1.1 was published online by ETSI on 2 September 2026 and updates V3.2.1 from 2021.
- Its headline change is a move of the web content baseline from WCAG 2.1 to WCAG 2.2, with the web, non-web document and software clauses pointing to Level AA.
- It adds an annex that maps its clauses to the Act's essential requirements.
- It becomes legally binding for the presumption of conformity once the Commission cites it in the Official Journal, which the NDA says is currently expected on 16 December 2026. Until then V3.2.1 remains the standard in force.
We have not seen the Official Journal entry, so treat the December date as an expectation.
What to build into an MVP
These are our recommendations, in the order we would do them.
- Decide your status in writing. Are consumers in the EU a customer group? Is any feature an Article 2(2) service? Are you a microenterprise providing services? Date it and keep it.
- Build to WCAG 2.2 Level AA from the first sprint. It covers V3.2.1 and V4.1.1, and retrofitting contrast, focus order and form labels later costs more than building them in.
- Make sign-up, sign-in, checkout and payment work by keyboard and screen reader. These are the flows the e-commerce and banking requirements name.
- Test on real assistive technology. Use VoiceOver on iOS, TalkBack on Android and a desktop screen reader, and check mobile apps as well as the web view.
- Make your AI interface accessible. Announce streamed replies to screen readers, allow users to stop or pause generation, do not rely on color alone, and keep the AI disclosure readable. The EU AI Act asks that the disclosure of an AI system meets the accessibility requirements, which we cover in EU AI Act for AI MVP founders.
- Publish accessibility information about your service and a contact for problems, and keep your support channel accessible.
- Write the burden assessment if you rely on it, and keep it for five years.
- Check each country where you sell. The Directive sets the minimum; national laws decide penalties and procedures.
If you also ship a mobile app, read the App Store and Google Play rules for AI apps. For the wider launch gate, use our AI MVP checklist, and see our UX audit for AI products.
Limits of this page
We read the Directive text as published in the Official Journal on 7 June 2019 (L 151), retrieved from the EU Publications Office on 22 October 2026, and one note from Ireland's National Disability Authority. EUR-Lex did not answer our scripted requests, and we did not check for corrigenda or later amendments in the consolidated version. We did not read national laws, the Directive's other annexes, the definition of electronic communications services in Directive 2018/1972, or ETSI's standard itself. The Commission page we opened lists the covered products and services but not the exemption or the transition. The mapping to app and SaaS products, the status test and the checklist are our reading and are not legal advice.
Sources
- Directive (EU) 2019/882 on the accessibility requirements for products and services, Official Journal L 151, 7 June 2019, EU Publications Office, read 22 October 2026
- European Accessibility Act, European Commission, read 22 October 2026
- Updated EN 301 549 Standard Strengthens Accessibility Requirements for ICT Products and Services, National Disability Authority (Ireland), September 2026