European Accessibility Act: Guidance for Application

What is the EAA?

The EAA focuses on products and services destined for end-users, as accessibility is, in principle, evaluated from the perspective of the end-user. Thus, products and services included in business-to-business agreements are excluded from the scope of the EAA.

The requirements of the EAA follow the general standing principle of multimodality, which essentially means that end-users must have the possibility of using products and services in different ways.  

Example: if a self-service machine, like a bank terminal or check-in machine, mainly uses touch to operate, the EAA requires it to also be operated using other senses. This could be achieved by adding sound instructions, image or video support, simpler menus, or any other feature that helps people with disabilities to use the equipment.

It is important to note that the principle of multimodality does not lay a quota on the measures to take, meaning that manufacturers may choose to implement one or more of the aforementioned examples, which in turn will have an effect on the degree of accessibility. However, this does not come to the detriment of its compliance. As a result, there is no “one compliance strategy” for the EAA, which is reflected in its evaluation though self-assessment only, as noted in Annex IV.

Does my website need to comply with the EAA?

Over the past months, we have seen quite a lot of different messages being launched around the EAA. More specifically, some organizations make the claim that all websites need to comply with the EAA, though this is not the case as explained below.

As per the guidance provided by FPS Economy, the EAA only applies to websites with an e-commerce function. An e-commerce function is defined as a service provided remotely, through websites and mobile device-based services, electronically and at the individual request of a consumer, with the aim of concluding a consumer contract. As the key aspect is the consumer contract, the EAA does not apply to e-commerce services for business-to-business, nor does it apply to websites offering reservation services at no cost. Lastly, websites with only redactional content are also excluded.

Guidance by FPS Economy

Over the course of the establishment, publication, and implementation of the EAA, questions were raised about its applicability to certain products and services. In response to this ambiguity, the SPF Economy published a guidance page (in Dutch and French) with dedicated guidance documents for banking services and e-commerce.