June 2025 – The European Accessibility Act (Directive (EU) 2019/882) ("EAA") represents a significant shift in the regulatory landscape for private sector businesses across the European Union. Introduced to harmonise accessibility requirements for key products and services, the EAA is designed to improve access for persons with disabilities and foster a more inclusive internal market.
With its full application date set for 28 June
2025, business entities that have not yet assessed their
compliance posture face growing legal, operational, and
reputational risks. The EAA expands beyond earlier public
sector-focused legislation and applies to a wide range of
industries—from tech to banking, telecoms, and
e-commerce—making timely preparation essential.
What is the EAA — and who Is affected?
The EAA requires that essential products and services be accessible to people with disabilities. Unlike previous frameworks, it imposes binding obligations on private-sector manufacturers, importers and service providers, including among others:
- consumer banking (including ATMs, computers, e-readers);
- e-commerce (including websites and mobile applications);
- audio-visual media services;
- transportation (including self-service terminals and check-in kiosks);
- telecommunications.
Each EU country in the CEE region has transposed the EAA into
national law, with some jurisdictions introducing variations within
their national legislation. Businesses with cross-border operations
in the region will need to navigate varying administrative
frameworks and comply with specific measures, as local
implementations may differ across jurisdictions. It is essential to
assess available exemptions and derogations (particularly in cases
involving microenterprises, the so-called disproportionate burden,
or fundamental alteration) in order to manage the compliance
project efficiently.
Key areas of impact for CEE businesses
The EAA introduces cross-border consistency in accessibility standards. Companies operating in CEE EU markets should prepare for:
- country-specific implementation timelines and enforcement mechanisms;
- audits, penalties, and potential product withdrawals for non-compliance;
- obligations for manufacturers, importers, and service providers throughout the supply chain.
Web accessibility: A legal and strategic priority
For businesses offering digital products or services, compliance with web accessibility standards is central. The EAA aligns with the Web Content Accessibility Guidelines, requiring:
- captions and transcripts for media content;
- accessible navigation and forms;
- high-contrast visuals and readable fonts;
- compatibility with assistive technologies.
Digital compliance not only reduces legal risk but also opens access to underserved consumer segments.
Practical steps toward compliance
With the deadline approaching, businesses should act now to:
- conduct a gap analysis and internal audits of websites, digital platforms, and physical products;
- integrate accessibility into design, procurement, and product development cycles;
- implement a conformity documentation process;
- prepare defensible justification for any exceptions;
- provide staff training;
- establish internal policies, training, and documentation to demonstrate due diligence;
- engage with local counsel and technical experts to ensure alignment with national implementation measures;
- monitor transposition laws in all Members States of operation.
How Kinstellar can help
At Kinstellar, we advise clients across the CEE region on the legal and operational implications of the EAA. Our cross-country teams provide strategic counsel tailored to each market, helping businesses:
- navigate national implementation of the EAA in each EU country in our markets;
- support in defining and completing steps ensuring full compliance;
- minimise risk and optimise accessibility practices.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
