Accessibility Act 2025: Impact on websites, services and (digital) products

European Accessibility Act 2025

Accessibility Act 2025: Impact on websites, services and (digital) products

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Table of contents

The demand for accessible products and services is already high, but the number of people with disabilities will continue to rise significantly in the future. Accessible products and services are therefore an essential prerequisite for an inclusive society that does not exclude anyone from professional and social life. The European Assesscibility Act (EAA) and its implementation in the EU member states create the legal basis for this.

Distinction between WCAG, EAA and the Accessibility Act

With the European Accessibility Act (also known as Directive 2019/882), the European legislator aims to contribute to the smooth functioning of the internal market by harmonizing the rules of the Member States. Differences in accessibility requirements in the Member States are eliminated in favor of the free movement of products and services. This also takes into account the principle of “universal design” ”, whereby products and services are designed in such a way that they can be used by all people without the need for additional adjustments.

The creation of accessibility standards is based on international guidelines that have been adopted by the European Union (with modifications and additions) in a directive, which in turn has been implemented in national law:

The EAA is not the first directive at EU level to address the issue of accessibility. However, Directive (EU) 2016/2102 on the accessibility of websites and mobile applications was aimed at public bodies. In Austria, it was implemented at federal level with the Web Accessibility Act and at state level with corresponding state laws. Certain activities carried out via websites and apps of public bodies will also comply with the EAA in addition to the applicable accessibility requirements of Directive (EU) 2016/2102. This ensures that the online sale of products and services is accessible to people with disabilities, regardless of whether the online sale is carried out by public or private economic actors.

Scope of the Accessibility Act based on EAA & WCAG

The federal Accessibility Act applies to products and services that are placed on the market or provided to consumers after after June 28, 2025

Which products are affected?
  • Hardware systems and operating systems of general-purpose computers for consumers
  • Self-service terminals
    • All payment terminals
    • Self-service terminals for the most part:
      • ATMs
      • Ticket terminals
      • Check-in terminals
      • All self-service terminals for the provision of information, with the exception of those installed in vehicles, aircraft, ships or rail vehicles
  • Interactive consumer terminals for electronic communication services
  • Interactive consumer terminals for accessing audiovisual media services
  • E-book readers
Which services are affected
  • All electronic communication services except for emergency calls and machine-to-machine communication services
  • All services that enable access to audiovisual media services
  • Most elements of passenger transport services by air, bus, rail and boat
    • Excluding urban, suburban and regional transport services
    • Websites
    • Services on mobile devices, including mobile applications (apps)
    • Electronic tickets and ticketing services
    • Provision of real-time traffic and travel information
      • Restriction: only in the territory of the EU
    • Interactive self-service terminals in the territory of the EU
      • Exception: terminals installed in vehicles, aircraft, ships and rail vehicles
  • All consumer banking services
  • All e-books and the software designed for them
  • All services in electronic commerce
Exceptions: when are websites and mobile applications not affected?
  • Recorded time-based media published before June 28, 2025
  • File formats of office applications published before June 28, 2025
  • Online maps and map services, provided that essential information for navigation purposes is accessible without barriers
  • Third-party content that is not financed and/or developed by the economic operator or is not under its control
  • Content from websites/apps that are considered archives and will not be revised after June 28, 2025.
Accessibility requirements for websites and other services and products

Mandatory accessibility requirements: economic operators may only place products on the market and offer services that meet the accessibility requirements.

Exemption for micro-enterprises

Micro-enterprises (annual turnover of less than EUR 2 million and fewer than 10 employees) that provide services are exempt from the accessibility requirements and from all obligations related to the fulfillment of these requirements.

Ensuring the free movement of goods

The provision of products and the offer or provision of services that comply with the requirements of Directive (EU) 2019/882 may not be prohibited for reasons related to accessibility requirements.

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Requirements of the Accessibility Act for economic actors
Obligations of manufacturers under the Accessibility Act

A manufacturer may only place products on the market if they have been designed and manufactured in accordance with the accessibility requirements.

The manufacturer must create the technichal documentation and must carry out a conformity assessment procedure or have it carried out. If conformity has been demonstrated, the manufacturer must issue an EU declaration of conformity and affix the CE-Marking.

The manufacturer must keep the technical documentation and the EU declaration of conformity for a period of five years after the product has been placed on the market.

The manufacturer must ensure that conformity with the Accessibility Act is always guaranteed, even in the case of batch production , by means of suitable procedures. Changes to the design or characteristics must be considered as appropriate.

The manufacturer may only place products on the market if they bear a mark identifying them (e.g. type, batch or serial number). If this is not possible, the required information must be provided on the packaging or in a document accompanying the product.

The manufacturer must indicate his registered trade name or or registered trademark and his contact address on the product itself or on the packaging (or accompanying documents). The address must state how the manufacturer can be contacted in German or English.

The manufacturer must ensure that instructions for use and safety information in German are enclosed with the product.

If the manufacturer has reason to believe that a product it has placed on the market does not comply with the requirements, it must immediately take the necessary corrective action or, if necessary, withdraw the product. In addition, he must inform the Ministry of Social Affairs and the EU market surveillance authorities. The manufacturer must then keep a record of the products concerned and the complaints relating to them.

The manufacturer must provide the Ministry of Social Affairs with all the information and documents in German or English that are required to demonstrate the conformity of a product and cooperate with the competent authority in ensuring that the product is brought into conformity.

Duties of authorized representatives under the Accessibility Act

The manufacturer can appoint an authorized representative by written order. The order must allow the authorized representative to perform at least the following tasks:

  • To keep theEU declaration of conformity and the technical documentation for a period of five years
  • Providing all the necessary information and documentation to prove the conformity of a product
  • Cooperating in all measures to eliminate non-compliance with accessibility requirements for products
Duties of importers under the Accessibility Act

The importer may only place compliant products on the market if:

  • the manufacturer has carried out the conformity assessment procedure
  • the manufacturer has created the required technical documentation
  • the product bears the CE-Marking
  • the required documents are enclosed with the product
  • the product can be identified (e.g. manufacturer's type, batch or serial number)
  • the manufacturer has affixed the trade name/trademark and contact address

If the product does not meet the accessibility requirements, the importer must inform the manufacturer and the Ministry of Social Affairs.

The importer must also indicate his name, registered trade name/trademark and contact address either on the product itself or on the packaging or an enclosed document in German or English.

The importer must ensure that the product is accompanied by instructions for use and safety information in German.

The importer must ensure that the storage or transport conditions do not affect the conformity of the product with the accessibility requirements.

The importer must keep a copy of EU declaration of conformity for a period of five years and must be able to present the technical documentation (on request).

Like the manufacturer, the importer (if he has reason to believe that the requirements have not been met) must take the necessary corrective action or, if necessary, withdraw the product. He must also inform the Ministry of Social Affairs and the market surveillance authorities of the EU. The importer must also keep a record of the products concerned and the complaints relating to them.

Like the manufacturer, the importer must provide the Ministry of Social Affairs with all the information and documents in German or English that are required to demonstrate the conformity of a product and cooperate with the competent authority in establishing the conformity of the product.

Duties of distributors under the Accessibility Act

When a trader makes a product available on the market, he must act with due care. This means that he must check whether:

  • the product bears the CE-Marking
  • the product is accompanied by the required documents, instructions for use and safety information in German
  • the manufacturer and importer have fulfilled their obligations with regard to product identification, trade names/brands, and contact address

If the product does not meet the accessibility requirements, the distributor must also inform the manufacturer or importer and the Ministry of Social Affairs.

Like the importer, the distributor must ensure that the storage or transport conditions do not affect the product's compliance with the accessibility requirements.

Like the manufacturer and the importer, the distributor (if he has reason to believe that the requirements are not met) must take the necessary corrective action or, if necessary, withdraw the product. He must also inform the Ministry of Social Affairs and the EU market surveillance authorities. The importer must also keep a record of the products concerned and the complaints relating to them.

Like the manufacturer and the importer, the dealer must also provide the Ministry of Social Affairs with all the information and documents (in German or English) required to prove the conformity of a product and cooperate with the competent authority in ensuring that the product is brought into conformity.

Obligations of service providers under the Accessibility Act

Only services that meet accessibility requirements may be offered and provided. The service provider must state the following in a suitable document (e.g.: the general terms of conditions:

  • a general description of the service (in an accessible format)
  • descriptions necessary to understand how the service is provided
  • a description of how the service fulfills the accessibility requirements

He must keep this information for the duration of the service offer.

The service provider must ensure that the accessibility requirements are met when the service is offered and provided and must respond accordingly to any changes

If the service provider has reason to believe that the service he offers and provides does not meet the requirements, he must take the necessary corrective action immediately. In addition, he must inform the Ministry of Social Affairs and the EU market surveillance authorities.

The service provider must provide the Ministry of Social Affairs with all the information and documents in German or English that are necessary to prove the conformity of the service and cooperate with the competent authority in establishing conformity.

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Disproportionate burden

The accessibility requirements only apply to the extent that compliance with them does not lead to a disproportionate burden on the economic operators concerned.

The economic operator must assess whether compliance with the accessibility requirements would lead to a disproportionate burden.

Download: Criteria for assessing disproportionate burden

The economic operator shall document the assessment and keep the results for a period of five years from the last provision of a product (or after the last provision of a service) and provide a copy to the Ministry of Social Affairs upon request.

If the economic operator invokes disproportionate burdens for a product or service, it must provide information to the Ministry of Social Affairs and the market surveillance authority

Exception: These documentation and information obligations do not apply to micro-enterprises dealing with products. However, at the request of the Ministry of Social Affairs, they must provide the facts relevant to the assessment.

A service provider who invokes disproportionate burdens must repeat the assessment for each category of service:

  • if the service offered is changed
  • if the service provider is requested to do so by the Ministry of Social Affairs
  • or otherwise at least every five years.

Please note: if a business has received funding(public or private) to improve accessibility, it cannot claim disproportionate burden.

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