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The European Accessibility Act (“EAA”, Directive 2019/882) entered into force on 28 June 2025, marking a significant shift on the European single market. This important piece of legislation sets requirements for many businesses within the EU in order to ensure that the products and services they offer 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 to ensure that everyone is able to participate in the society equally and as independently as possible. As a principle, products and services should be designed to be accessible from the outset, not afterwards. From a wider angle, the legislators encourage companies to view the accessibility requirements as not merely fulfilling a legal obligation, but also as an active step towards a potentially larger market share, better customer satisfaction and stronger brand reputation.
The EAA in Finland
In Finland, the EAA has been implemented via the Act on the Accessibility Requirements of Certain Products (102/2023). Formally, the act 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 has required amendments to several other statutes in Finland. Amendments have been made to legislation covering digital services, electronic communications, transport services and even emergency response operations. The authority responsible for the enforcement of the new requirements in Finland is the Finnish Transport and Communications Agency, Traficom. As the designated market surveillance authority, Traficom can impose sanctions, such as prohibitions and fines, to ensure compliance with the requirements.
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 the 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. Such small businesses are not subjected to the accessibility requirements for the services they provide, and they benefit from certain reliefs regarding products as well. In addition, a company may invoke an exemption on the basis of unreasonable burden in cases where compliance with the requirements would fundamentally alter a product or impose a disproportionate cost. Relying on this exemption, however, also 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:
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- 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 to the extent they are used to provide any of the services covered by the requirements.
For these products, their user interface must be manageable, and all instructions covering their packaging, use, installation, maintenance and disposal must be understandable and easily accessible. In practice, this means that information should be available through more than one sensory channel, any text should be available in a sufficiently large display font, and that operating the product should not require significant physical strength. Additionally, the 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:
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- 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 user interface of the service is clear, understandable and technically compatible with assistive technologies like screen readers and magnification software. The service must function smoothly with compliant accessible devices. In addition, the users must be provided with clear information about the service’s operation and accessibility features, as well as its compatibility with assistive devices.
There are also additional specific requirements for certain services. In addition to voice communication, interpersonal communication services must offer 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 of 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 should focus on the following three essential measures:
1. Assess and prioritize compliance:
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- Determine if your products/services fall under the 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 and communicate accessibility status:
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- Update your accessibility statement to be comprehensive and easily discoverable on your website.
- Clearly explain how your offerings meet the standards and how users can provide feedback.
3. Enhance user information and support:
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- See to that all information on the use of accessibility features is clear and accessible.
- Ensure that customer support channels are ready to assist all users effectively.
A more accessible EU benefits everyone. For businesses subject to the accessibility requirements, the deadline for ensuring compliance has now passed. It is therefore important to verify that all required measures and actions have been completed, and that 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.
