European Accessibility Act: what it requires and who it covers

The European Accessibility Act is Directive (EU) 2019/882. Since 28 June 2025 it has required certain products and services for consumers, including online shops, to be accessible to people with disabilities. Each EU country has turned it into national law; in Lithuania this is the Law on Accessibility Requirements for Products and Services (No XIV-1633). This article explains who the Act applies to, the exemptions, the key dates and what an online shop actually has to do.

What is the European Accessibility Act

The European Accessibility Act, or EAA, was adopted on 17 April 2019. EU countries had until 28 June 2022 to transpose it into their own law, and the requirements have applied since 28 June 2025.

The Act sets the same accessibility requirements across the EU. A business that sells in several countries no longer has to adapt to a different set of national rules in each one. For websites and apps, the requirements rest on four principles: content must be perceivable, operable, understandable and robust – meaning it works with different browsers and assistive technologies.

Who the European Accessibility Act applies to

The Act does not cover every website. It covers specific services that businesses provide to consumers:

• e-commerce – websites and apps through which a consumer buys goods or services online;
• consumer banking services;
• electronic communications services, such as phone and internet;
• elements of air, bus, rail and waterborne passenger transport services: websites, apps, e-tickets and travel information;
• e-books and the software used to read them;
• access to audiovisual media services.

The directive also covers answering calls to the European emergency number 112. In Lithuania, 112 is not on the law’s list of services; accessibility policy for 112 calls is shaped by the Ministry of the Interior.

Besides services, the Act covers products: computers and their operating systems, smartphones, TV equipment, e-readers, ATMs, payment terminals, and ticketing and check-in machines.

When a website falls outside the Act

A company website that presents services, contact details and an enquiry form, but where consumers cannot enter into a contract online, is usually not an e-commerce service in the sense of the Act. The Act also does not apply if you sell only to other businesses. There are plenty of borderline cases, such as bookings with advance payment, so if in doubt, ask a lawyer. For a checklist by type of business, see Does my website need to be accessible?

The microenterprise exemption

Microenterprises that provide services do not have to meet the Act’s requirements. A business counts as a microenterprise if it meets both conditions:

The exemption is narrower for microenterprises that make or distribute products: they must meet the accessibility requirements, but they do not have to document a disproportionate burden assessment.

The exemption does not stop you making your website accessible voluntarily. A growing business may cross the microenterprise thresholds, and the requirements then apply straight away.

Key dates

In Lithuania, this transitional period is set by Article 30 of the law. It covers products used to provide a service (payment terminals, for example) and contracts agreed earlier. An online shop that was already running before 28 June 2025 has to meet the requirements now.

What an online shop has to do

The directive and its Annex I set out several specific requirements for e-commerce services:

1. An accessible website or app. Product search, product pages, the basket and the order form must work with a keyboard and a screen reader, and text must have enough contrast. In practice websites are assessed against the European standard EN 301 549, which applies the WCAG 2.1 AA criteria to websites. These are explained in WCAG requirements in plain English.
2. Accessible login and payment. Identification, security and payment steps must be perceivable, operable, understandable and robust.
3. Information on product accessibility. If the manufacturer provides information on a product’s accessibility, the shop must show it to the customer.
4. Information on service accessibility. Explain in your general terms and conditions, or an equivalent document, how your service meets the requirements. This information must also be accessible.
5. A disproportionate burden assessment. If you cannot meet a requirement because it would be a disproportionate burden or would fundamentally change the service, you must justify this in a documented assessment, inform the supervisory authority and review the assessment at least every five years.

Content the Act does not cover

The directive sets out several exceptions for website content:

• pre-recorded video and audio published before 28 June 2025;
• office documents, such as PDF or Word files, published before the same date;
• online maps, as long as essential navigation information, such as an address, is provided in an accessible way;
• third-party content that the business does not fund, develop or control;
• archives – content that is not updated or edited after 28 June 2025.

These exceptions do not apply to new videos, documents and pages.

Enforcement and penalties

Each EU country appoints its own market surveillance authorities and lays down its own penalties. The directive only requires them to be effective, proportionate and dissuasive, so supervisors and fines differ from country to country.

Supervision and fines in Lithuania

In Lithuania, several authorities share supervision, each for its own services (Article 6 of the law):

• e-commerce, consumer banking, e-books and products – the State Consumer Rights Protection Authority (VVTAT);
• electronic communications services – the Communications Regulatory Authority of the Republic of Lithuania (RRT);
• passenger transport websites, apps and e-tickets – the Lithuanian Transport Safety Administration (LTSA);
• access to audiovisual media services – the Radio and Television Commission of Lithuania (LRTK).

The authorities handle complaints, advise businesses and prepare guidance on meeting the requirements. If an authority finds a service non-compliant, it orders the provider to fix the problem within a set period, and to stop providing the service if it is not fixed.

Under Article 23 of the Lithuanian law, providing a non-compliant service carries a fine of €500 to €2,500. If a business keeps providing the service after being ordered to stop, the fine is €1,000 to €6,500, and €2,500 to €15,000 if a consumer’s health has been harmed.

Where to start

1. Check whether the Act applies to you. Do you provide one of the listed services to consumers, and are you a microenterprise?
2. Assess your website. Start with the most important customer journey: product search, the basket and payment.
3. Fix the issues and publish accessibility information. We describe how to do this step by step in How to make a website accessible.

If you are building a new online shop, put the accessibility requirements in the brief from the start – fixing them later costs more. This article is for general information only and is not legal advice.

If you want to find out what needs fixing in your online shop, get in touch about website accessibility – we will start with an accessibility audit.