European Accessibility Act

• In scope

  You sell to consumers online.

  E-commerce services, meaning anything sold to consumers at a distance through a website or an app, are one of the directive's ten categories. Consumer banking and e-books are two more. It is about who you sell to, not what you build.

• Out of scope

  You sell only to other businesses.

  The directive protects consumers. A product or service sold only to businesses sits outside it, as do the hardware categories: terminals, phones, television equipment, transport.

• Exempt

  You are a microenterprise.

  Under ten people and under two million euro turnover: the service obligations do not apply. Product obligations still do.

What the directive asks along the supply chain

1. Article 7

   Manufacturers design for accessibility

   Products are designed and produced to meet the requirements of Annex I. A third-party component built in must not break them.

2. Article 9

   Manufacturers outside the EU appoint a representative

   An authorised representative in the EU carries the accessibility obligations on the manufacturer's behalf.

3. Article 11

   Importers verify before placing on the market

   An importer checks that the manufacturer has carried out the assessment and that the product meets Annex I before it enters the EU market.

4. Article 14

   Distributors verify before making available

   A distributor checks the CE marking and the documentation of what it sells on, and does not make a non-conforming product available.

• Manufacturer

  You build software and sell it under your own name.

  • Design to Annex I
  • Keep technical documentation
  • Assess conformity
  • Affix the CE marking
  • Watch embedded components

• Distributor

  You resell, integrate or manage software made by others.

  • Check the CE marking
  • Check the documentation
  • Withhold non-conforming products
  • Report non-conformity

How the evidence lands

1. Accessibility scanning

   Your web properties are loaded in a real browser and checked against WCAG 2.1 AA: contrast, keyboard navigation, ARIA, structure. Findings land on the Annex I controls.

2. Embedded components

   Your vendor profile lists every sub-processor and embedded service, so you know which third-party components sit in your product.

3. Continuous conformity

   Conformity is not a one-time certificate. Scans repeat on a schedule and every reading enters the event log as evidence.

4. Five years of documentation

   The event log is append-only: every scan, finding and fix is timestamped and kept, which is what an importer or distributor must be able to show.