Accessibility becomes a product requirement for Europe's service economy

The European Accessibility Act made accessible consumer journeys, supplier components and continuing evidence of accessibility part of the same product responsibility.

A hand holding an orange bank card beside a blue contactless payment terminal.
Contactless bank card and payment terminal.ING Nederland (opens in a new tab) · CC BY-SA 2.0 (opens in a new tab)

A customer who can browse a store but cannot complete its identity check has not received an accessible shopping service. The same problem appears when a banking app works with assistive technology until it opens a payment confirmation, or when ticket information cannot be understood without seeing a particular screen. Accessibility depends on the whole task a person needs to complete.

From 28 June 2025, national measures implementing the European Accessibility Act were due to apply. The directive established common requirements for specified products and consumer services. For startups building those services, or supplying components inside them, the requirements made accessibility part of product delivery and procurement. Its purpose was participation and independent use by people with disabilities; commercial opportunities arose from doing that work well.

Define the service before auditing its screens

The directive covered categories including consumer computer hardware and operating systems, payment terminals and e-readers. Its service scope included consumer banking, e-commerce, electronic communications, e-books and specified elements of passenger transport. The scope was more precise than a requirement that every business website look a certain way. A software supplier first needed to understand whether it provided a covered service or contributed to one delivered by a customer.

A Singapore bus fare reader displays a prompt to tap a card above the EZ-Link, NETS and payment network logos.
Singapore bus fare card reader, 2023.SBS6577P (opens in a new tab) · CC BY-SA 3.0 (opens in a new tab)

That distinction mattered to a business selling authentication, booking or payment components. Even where a supplier's standalone product for business customers did not itself fit a category of consumer services, its customer might need the component to deliver an accessible service. Procurement could therefore ask for evidence about particular features, supported environments and known limitations. A generic declaration about the supplier's corporate website would not answer whether a consumer could finish the customer's actual transaction.

Follow the customer through the difficult steps

Annex I specifically addressed identification, security and payment in e-commerce services, requiring those functions to be perceivable, operable, understandable and robust. It also required accessibility information about products and services being sold when the responsible economic operator supplied that information. These provisions directed attention to tasks that frequently crossed product and supplier boundaries.

The silver back of an iPhone XS stands upright against dark acoustic foam, with its dual camera visible.
iPhone XS, 2019.Cullen Steber (opens in a new tab) · CC BY-SA 4.0 (opens in a new tab)
Review a complete consumer transaction
  1. Understand

    Can the customer find and understand the information needed to choose?

  2. Identify

    Can the customer authenticate and recover from an identification error?

  3. Authorise

    Can the customer review and complete the payment with their means of access?

  4. Confirm

    Can the customer understand the result and obtain accessible support?

Illustrative review sequence informed by Annex I of Directive (EU) 2019/882. It is not a complete legal conformity checklist.

Consider a checkout using a storefront, an identity provider and a payment service. A keyboard user might reach the payment button but lose their position when a new dialogue opened. A person using a screen reader might receive an unexplained verification failure. Resolving such problems required reproducing the journey across components, understanding the error and giving somebody responsibility for the correction. The review needed to establish whether the customer could complete the task and recover when something went wrong.

The findings also needed to inform product development. Teams needed to carry accessible interaction patterns into reusable components and to test them when external services changed. A purchasing decision could turn on whether a supplier exposed clear error messages, allowed an accessible alternative and documented how its component behaved. Buyers were evaluating the support needed to keep a service usable, alongside the initial integration.

Automated checks need human review

The W3C's accessibility evaluation methodology describes tools as support for expert evaluation and calls for review of complete processes. Automated checks can help find recurring failures, but interpreting labels, navigating an unfamiliar sequence and recovering from an error call for broader assessment. Involving people with disabilities helps reveal barriers that a checklist can miss.

Accessibility software could support this work without replacing human assessment. A tool could locate issues, connect them to source components and track corrections across releases. It could also help teams preserve evidence and coordinate human review. Claiming that an automated score established complete legal compliance would go further than the method supported. A useful service made accessibility easier to maintain and clearly identified the judgements that required people.

The exceptions were specific

Microenterprises providing services were exempt from the directive's accessibility requirements and related compliance obligations. The definition combined fewer than ten employees with annual turnover or a balance sheet total not exceeding two million euros. Microenterprises dealing with products received narrower relief, including from documenting certain burden assessments; they did not receive the same exemption as service providers.

The directive also addressed fundamental alteration and disproportionate burden through an assessment tied to specified criteria. Existing service contracts agreed before 28 June 2025 could continue without alteration until expiry, for no more than five years from that date. Other transitional provisions covered products already used to deliver services and, where Member States allowed it, self-service terminals. These were qualified arrangements. A growing company needed to check its own status, contracts and national implementation to establish which obligations applied and when.

Accessibility remained an operating responsibility

Article 13 required service providers to explain how their services met the applicable requirements and to maintain procedures for continuing conformity. It also addressed correction and notification when a service was not compliant. National implementation determined the competent authorities and enforcement arrangements. Ireland's implementing regulations, for example, assigned service supervision across sector authorities and the Competition and Consumer Protection Commission rather than creating a single authority for every covered activity.

For investors, evidence of readiness therefore extended beyond a completed audit. A company needed to know who owned defects, how releases were reviewed and how customer reports reached the team able to fix them. Reusable components and clear supplier agreements could reduce repeated work as the business expanded. The requirements focused attention on compliance while supporting a lasting product benefit: more people could use the service reliably to accomplish an ordinary task.

Sources

  1. Directive (EU) 2019/882 on the accessibility requirements for products and services (opens in a new tab)

    Official Journal of the European Union

  2. S.I. No. 636/2023: European Union (Accessibility Requirements of Products and Services) Regulations 2023 (opens in a new tab)

    Irish Statute Book

  3. Website Accessibility Conformance Evaluation Methodology (WCAG-EM) 1.0 (opens in a new tab)

    World Wide Web Consortium

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