European Accessibility Act (EAA)

The European Accessibility Act is Directive (EU) 2019/882 of April 17, 2019 on the accessibility requirements for products and services. A directive does not bind companies directly. Each member state had to write it into national law by June 28, 2022 and apply that law from June 28, 2025. In Poland that law is the Act of April 26, 2024 on ensuring compliance with accessibility requirements of certain products and services by economic operators (Journal of Laws 2024, item 731), which entered into force on June 28, 2025.

The EAA lists what it covers. Products placed on the market after June 28, 2025: consumer computers and their operating systems, payment terminals, ATMs, ticketing and check-in machines, interactive information kiosks, consumer devices used for telecom services and for accessing audiovisual media, and e-readers. Services provided to consumers after June 28, 2025: electronic communications, access to audiovisual media services, the websites, mobile apps, e-tickets and real-time travel information of air, bus, rail and waterborne passenger transport, consumer banking, e-books and dedicated software, and e-commerce.

Before you decide your service is in scope, check these limits:

• The service list covers services provided to consumers. A tool sold only to other businesses is outside that list.
• Micro-enterprises that provide services are exempt. The directive counts a company as a micro-enterprise when it has fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million.
• Some website and app content is excluded: pre-recorded audio and video and office documents published before June 28, 2025, archives that are no longer edited, and third-party content the company does not fund, build or control.

Service contracts signed before June 28, 2025 may continue unchanged until they expire, but no longer than until June 28, 2030. A service provider may keep using products it already used for the same service until June 28, 2030, and self-service terminals for up to 20 years from when they were first used. A company may also skip a requirement when meeting it would fundamentally alter the product or service or impose a disproportionate burden, but it has to document that assessment, keep it for five years and, for services, repeat it at least every five years.

For services, the core requirement is in Annex I: websites, including related online applications, and mobile apps must be perceivable, operable and understandable, and must work reliably with browsers and assistive technologies. These are the four principles of WCAG. The directive itself does not name WCAG or any version of it. It says a product or service that meets a harmonized standard cited in the Official Journal of the EU is presumed to conform.

That standard is EN 301 549. Version 4.1.1, adopted on August 24, 2026, was written under the Commission's standardization request for the EAA, maps its clauses to the directive's requirements in Annex ZB, and aligns its web and app clauses with WCAG 2.2. Under Article 15 of the directive, it gives a presumption of conformity once its reference is published in the Official Journal. The previous version, 3.2.1 from 2021, is built on WCAG 2.1 and is the standard for public sector websites under the Web Accessibility Directive. In practice, a product team that builds to WCAG 2.2 level AA covers the web and app requirements of both versions.

The Polish act names the President of the Management Board of PFRON (the State Fund for Rehabilitation of Disabled Persons) as the coordinator of the supervision system and assigns market surveillance authorities by sector. For e-commerce it is the minister responsible for digitalization, for consumer banking the Financial Ombudsman, and for telecom services, access to audiovisual media, e-readers and e-books the President of the Office of Electronic Communications. Passenger transport services have their own transport authorities.

A consumer can file a complaint directly with the company. The company has 30 days to respond, or up to 60 days in particularly complex cases if it explains the delay. If the company misses the deadline, the complaint is treated as accepted as filed, and the company has up to 6 months from receiving it to do what the consumer asked.

For a service provider that does not meet the accessibility requirements, the fine can reach ten times the average monthly salary in the national economy for the previous year, but no more than 10% of the company's turnover in the previous financial year. The amount depends on how serious the breach is, how many products or services fail and how many people it affects. PFRON or the sector authority imposes the fine by decision.

This is a different law from the Polish Act of April 4, 2019 on the digital accessibility of websites and mobile applications of public bodies (consolidated text, Journal of Laws 2023, item 1440). That act, often called the digital accessibility act, covers public bodies and requires them to publish an accessibility statement. The EAA and the 2024 act cover private companies that provide the listed products and services.

Whether the EAA covers a given service is a legal question. The software work looks the same either way:

• List the consumer-facing channels: website, web app, iOS and Android apps, and the documents and emails they generate.
• Run an accessibility audit against WCAG 2.2 AA. It should combine automated scans with manual keyboard and screen reader testing, because a scanner checks only part of the criteria.
• Fix the findings in design and code, then retest each one. A finding is closed after a retest, not after a commit.
• Watch the parts scanners miss, such as focus management in dialogs and navigation, which decides whether a screen reader user can finish a payment or a sign-up.
• Write the accessibility information for the terms of service and set up a way to receive and answer complaints within 30 days.
• Add accessibility checks to the release process, so each new version keeps the level you reached.

We audit web and mobile apps against WCAG 2.2 AA and fix what fails in React, React Native and Django, with the same team. Our accessibility audit services describe the work in detail.

In Centrum Komunikacji, an app for deaf, hard of hearing, blind and deafblind users built to WCAG 2.1 AA, a dialog with 4 controls keeps VoiceOver inside it, so a screen reader user never reaches the 25 controls behind it. We built that behaviour into the React Native components. For PSONI's Generator ETR, the specification requires WCAG 2.2 at level AAA, and screen reader findings are tracked and retested on each platform separately.

On October 10, 2026 we audited our own website against WCAG 2.2 AA. Before the fixes, the axe scanner found 6 violations, while pixel measurement found 29 text elements on photos with too little contrast. Our site is still partially compliant, partly because 7 of our 10 YouTube videos have only automatic captions.