E-Commerce
All websites, mobile apps, online shops, and digital platforms that sell products or services to EU consumers.
European Accessibility Act for mobile apps
A practical guide to what the EAA covers, why enforcement risk varies by country, and how mobile app teams can build credible evidence.
What is the EAA?
It is a set of regulations that came into force in EU countries in June 2025, enforcing in law that certain digital products must be accessible.
In-scope products must meet the relevant criteria defined in EN 301 549. This standard covers a range of physical and digital consumer products, but for apps and websites, the relevant technical standard is WCAG 2.1 Level AA.
In-Scope Products
It applies to B2C digital products falling into these categories.
Audio-Visual Media Services
Video streaming platforms, digital television services, and electronic program guides.
E-Books
Digital books, publications, and the specialised software used to read and download them.
Banking Services
Customer-facing digital banking portals, mobile banking applications, and electronic financial interfaces.
Telecommunications
Fixed or mobile telephony services, internet access providers, VoIP software, and digital messaging apps.
Emergency Services
Digital infrastructure and responses to the single European emergency number "112".
Passenger Transport Services
Websites, mobile applications, interactive map services, digital ticketing platforms, and real-time travel information systems for air, rail, bus, and waterborne travel.
Micro-enterprise Exemption
Micro-enterprises are exempted from legal enforcement, so companies with less than 10 staff and turnover, or balance sheet, that does not exceed €2 million are treated differently.
Larger organisations, regulated services, and teams selling digital services into the EU should not assume an exemption without legal review.
Regions Applicable
This law applies to all countries in the EU where your product is available. Even if that region is not your primary market, or you do not sell in the local currency or language, you still must comply.
Examples of in-scope products
Website selling jewellery
- Website written in English
- Payment taken in GBP £
- Visible in EU countries
- You offer international shipping
Why it is in-scope: This constitutes an e-commerce service. By offering international shipping to EU members, the site actively targets EU consumers, requiring the entire digital browsing and checkout funnel to meet standards.
Consumer loan and financial management app
- Interface displayed in Polish
- Available via app stores to customers in Poland
- Users can manage loans, track repayment timelines, and view APR terms
Why it is in-scope: This falls under consumer banking services. The EAA explicitly covers digital credit agreements, meaning critical loan terms like dynamic APRs and repayment schedules must be fully screen-reader readable.
Mobile gaming app with in-app purchases
- Interface displayed in English or any EU language
- Available via the Apple App Store or Google Play Store in Ireland, France, or Spain
- Users can purchase in-game currency or cosmetics via credit card
Why it is in-scope: Microtransactions, subscriptions, and digital storefronts constitute a consumer contract under e-commerce rules.
Hotel or gym class booking system
- Web-based booking engine for a UK-based boutique hotel chain or specialist retreat
- Accepts bookings and processing payments from tourists living in the EU
Why it is in-scope: Even if the physical service takes place in the UK, the digital storefront provides consumer bookings directly to EU citizens, classifying it as an e-commerce service.
B2B SaaS platform
- Cloud-based business platform built by a London software house
- Licensed to enterprise clients in Germany or the Netherlands
Why it is in-scope: While the software is B2B, client companies may need to deploy accessible tools to their own teams and consumers under EU workplace and service requirements, putting pressure on UK vendors to comply.
Social video sharing app
- Interface displayed in English
- Sold via app stores in EU countries
- Users can upload and view media
Why it is in-scope: The EAA regulates audio-visual media services. While user video uploads may be treated differently, the app's navigation, player controls, and captioning tools still need to be accessible.
Technical blog selling PDF guides
- UK engineering consultancy website publishing insights
- Offers paid digital download whitepapers or e-books priced in Euros
Why it is in-scope: The EAA explicitly highlights e-books and dedicated reading software. If a site sells downloadable instructional text documents to EU users, the checkout flow and document structure must meet accessibility rules.
Parking or EV charging app
- UK-designed app allowing drivers to locate and pay for EV charging or parking slots
- Operates physical hubs or digital booking networks crossing into Northern Ireland and Ireland
Why it is in-scope: It can constitute an element of passenger transport infrastructure and an interactive payment gateway, making user interactions regulated.
The Law
The EAA for digital products relies on self-declaration. All in-scope digital products must publish an accessibility statement within the digital product or a link to the statement online.
The document must include your compliance status, for example conforming to EN 301 549 or WCAG 2.1 AA. This should include a list of any known temporary accessibility issues.
In addition, you must provide an active feedback mechanism, such as an email or form, allowing users to report accessibility barriers.
Enforcement and Investigation
Enforcement happens via market surveillance and customer complaints. If a regulator receives a complaint from an EU citizen about your app or website, they can launch an investigation and request internal technical documentation and assessment records.
Ignoring a Formal Rectification Notice
The authority sends an official notice outlining accessibility bugs and gives you a strict deadline, often 30 to 90 days, to fix them. Fines are triggered if you miss the deadline or refuse to make changes.
Missing or Incomplete Documentation
Failing to publish a valid Public Accessibility Statement, or failing to provide internal technical testing documentation to a market authority within the requested timeframe, can create enforcement risk.
Deliberately Ignoring User Feedback Mechanisms
Leaving an accessibility reporting email unmonitored, ignoring complaints filed by disabled consumers, or failing to log and address those complaints can trigger investigation.
Penalties
Daily Accumulating Fines
Many countries, including France, apply ongoing daily fines often up to €1,000 per day until your software engineering team pushes an update that resolves the specific violations.
One-Time Administrative Fines
Flat penalties for severe or repetitive violations vary by location. For example, Germany's BFSG Enforcement Law issues fines up to €100,000, while other nations cap them closer to €10,000 to €20,000 per violation.
App Store and Market Removal
For software and apps, surveillance authorities can legally force Apple and Google to remove your app from the regional App Store entirely, blocking your business from operating in that country until compliance is proven.
Personal Executive Liability
In rare, extreme cases of continuous, willful neglect, some countries target company leadership. For example, Ireland's EAA transposition allows corporate directors to face up to 6 months of prison time.
What Is Required to Comply with the EAA?
To make a mobile application or website fully accessible, you must build user interfaces that function independently of standard touchscreens or mice. Under global standards like WCAG 2.1 Level AA, digital products must be compatible with assistive technologies, flexible layouts, and alternative input methods.
Screen Reader Compatibility
The foundation of digital accessibility relies on native screen reader optimisation: VoiceOver for iOS, TalkBack for Android, and NVDA or JAWS for desktop browsers. Your code must provide accurate programmatic labels, roles, and values for every user interface component.
Layout Flexibility and Font Scaling
Apps and websites must support text reflow and scaling up to at least 200% without breaking the user interface. Content cannot clip, overlap, or become obscured, and layouts should avoid unnecessary horizontal scrolling.
Keyboard Navigation and Input Focus
The entire interface must be navigable using standard tab or arrow inputs. Interactive journeys need a logical focus order, visible high-contrast focus indicators, and no keyboard traps in forms, modals, or pop-ups.
Color Contrast and Visual Design
Standard text must achieve a minimum contrast ratio of 4.5:1 against its background. Large text and essential graphical components require a minimum ratio of 3:1, and color must not be the only way information is communicated.
Evidence-led, not panic-led
Accessibility is now a board-level operational risk, not a design afterthought. The safest message is practical: see the risk clearly, prioritise it sensibly, and fix it in the product. Our audits connect the legal context to the digital journeys that matter: identity, payments, records, checkout, account recovery, bookings and support.
- Directive, not one fixed standardThe EAA is implemented through national requirements. Most delivery teams need practical evidence that maps app journeys to recognised accessibility expectations and remediation decisions.
- Mobile services are in the frameE-commerce, banking, transport, communications and other consumer-facing digital services can involve mobile app journeys, which is why the audit starts with the tasks users actually need to complete.
- Non-EU teams can still be affectedBusinesses outside the EU can still face accessibility expectations when their products or services reach EU consumers.
- Penalties vary by countryEnforcement, fines, monitoring authorities and market consequences are country-specific and should be reviewed with legal teams.
We provide accessibility audit, remediation and reporting support. We do not provide legal advice, and no statement on this site is a legal opinion on obligations in any jurisdiction.