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European Accessibility Act (EAA, Directive 2019/882) came into force on 28 June 2025, marking a significant shift in the EU market. The important legislation requires many businesses offering products and services within the EU to ensure that they are accessible to everyone, including people with special needs.
The main objective of the directive is to reduce barriers and promote inclusiveness. The directive aims to harmonize the internal market for accessible products and services and ensure that everyone can participate equally in society as independently as possible. A main principle is that products and services should be designed to be accessible from the outset, not afterwards. Meeting the accessibility requirements is not just a legal obligation but also an active step towards a larger market share, better customer satisfaction, and a stronger brand reputation.
The EAA in Finland
In Finland, the EAA has been implemented nationally through the Act on the Accessibility Requirements of Certain Products (102/2023). The act formally came into force a couple of years ago and now it is being properly put into practice. The directive’s broad impact is clear, as its implementation also required amendments to several other acts in Finland. Amendments have been made to acts concerning the governing of digital services, electronic communications, transport services, and even emergency response operations. The market surveillance authority responsible for enforcing these new accessibility requirements in Finland is the Finnish Transport and Communications Agency, Traficom. As the market surveillance authority, Traficom can impose sanctions such as prohibitions and fines to ensure compliance with the law.
Who is affected by the requirements?
The new accessibility requirements apply broadly to both public and private entities that offer products and services to consumers. The requirements apply only to new products placed on the market after June 28, 2025. However, services falling within the scope of application must meet accessibility requirements even if they have been available before that date.
On the other hand, there is an exemption for micro-enterprises, which are defined as having fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. These small businesses are not subjected to the accessibility requirements for the services they provide and are granted some reliefs regarding products as well. Additionally, a company may claim an exemption for an unreasonable burden if compliance would fundamentally alter a product or impose a disproportionate cost, though this requires thorough documentation and reporting to authorities.
Scope of the EAA requirements
The requirements cover a wide range of everyday products and services.
The products falling within the scope include:
- Personal computing devices, such as computers, smartphones, and tablets, as well as their operating systems.
- Self-service terminals, including payment terminals, ATMs, ticket machines, and check-in kiosks.
- Interactive self-service terminals used in passenger transport.
- Consumer terminal equipment used for electronic communication services.
- Terminal equipment used for audiovisual media services, such as digital set-top boxes and smart TVs.
- E-readers for consuming e-books.
- Other products that are used to provide any of the services covered by the requirements.
For these products, the user interface must be manageable, and all instructions covering packaging, use, installation, maintenance, and disposal must be understandable and easily accessible. In practice, this means information should be available through more than one sensory channel, text should be in a sufficiently large font, and the product’s operation must not require significant physical strength. Additionally, these products must come with an EU declaration of conformity and display the CE marking.
Service providers are responsible for ensuring compliance throughout the entire service delivery lifecycle. The services included are:
- Electronic communication services, such as internet access services.
- Interpersonal communication services.
- Services providing access to audiovisual media services.
- E-commerce services.
- E-books.
- Consumer banking services.
- Services offered via self-service terminals, such as registration and payment services.
- Errand and appointment booking services.
Service providers must ensure that the service’s user interface is clear, understandable, and technically compatible with assistive technologies like screen readers and magnification software. The service must function smoothly with compliant accessible devices. The clear information about the service’s operation, its accessibility features, and its compatibility with assistive devices must be provided for the users.
There are also specific additional requirements for certain services. Interpersonal communication services must offer not only voice communication but also real-time text and, where video is included, “total conversation” capabilities. Services that provide access to audiovisual media content must offer a reliable and easily discoverable electronic program guide. Accessibility features like subtitles and audio description must be high-quality, accurate and properly synchronized with the audio and video, with the user being able to control their use independently.
What should be done now?
Businesses need to concentrate on these three essential actions:
1. Assess and prioritize compliance:
- Determine if your products/services fall under EAA scope.
- Review digital platforms (websites, apps) and services against EAA standards (e.g., WCAG).
- Identify and fix any features preventing independent and equal access for users with special needs.
2. Finalize & communicate accessibility status:
- Update your accessibility statement to be comprehensive and easy to find on your website.
- Clearly explain how your offerings meet standards and how users can provide feedback.
3. Enhance user information & support:
- Ensure all information on using accessibility features is clear and accessible.
- Confirm customer support channels are ready to effectively assist all users.
A more accessible EU benefits everyone. For businesses subject to accessibility regulations, the deadline for ensuring compliance has now passed. It is therefore important to check that all required actions are completed, and your business meets the legal standards and compliance.
Waltteri Messo
Read more about the topic:
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Traficom: New accessibility requirements.
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Traficom: Frequently asked questions about new accessibility requirements for products and services.
Author:
Waltteri Messo assists our lawyers as a Legal Trainee. His duties include especially legal research and information retrieval.
