EAA requirements: who is covered and what to do

Which companies the European Accessibility Act covers, what the Swedish law requires and how you show compliance.

In short

The EAA (Directive (EU) 2019/882) has applied since 28 June 2025. In Sweden it is implemented through the Accessibility Act (tillgänglighetslagen). It covers consumer services such as e-commerce, consumer banking, e-books and electronic communications. Websites and apps should meet EN 301 549, which means WCAG 2.1 AA today, and providers must publish how they comply.

The European Accessibility Act is no longer a future deadline. As of October 2026, the EAA has applied for more than a year, Swedish authorities supervise it, and customers can report barriers. This guide is written by Devies, a Gothenburg-based product and engineering consultancy, for teams that sell digital services to consumers in Sweden and the rest of the EU. It covers who is in scope, what the requirements mean for a website or app, how the law differs from the Swedish public-sector rules, and a practical order of work.

Who does the EAA cover?

The EAA covers a defined list of consumer products and services, not every website. Tillgänglighetsdirektivet, the Swedish name for Directive (EU) 2019/882 on accessibility requirements for products and services, sets out that list, and the Swedish Accessibility Act (SFS 2023:254) repeats it. The Swedish law entered into force on 28 June 2025.

Services are covered when they are intended for consumers:

E-commerce services: selling products or services to consumers at a distance through a website or app.
Consumer banking services.
Electronic communications services.
Services giving access to audiovisual media.
E-books and the software used to provide them.
Parts of passenger transport services by air, bus, rail and water, such as websites, apps, e-tickets and travel information, plus self-service terminals in urban and regional transport.

Products covered include general-purpose computers and operating systems, smartphones, payment terminals, ATMs, ticketing and check-in machines, e-readers and consumer equipment for TV and electronic communications.

Three limits matter when you assess your own position:

Microenterprises are exempt for services. A microenterprise is a company with fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million.
Business-to-business services are outside the scope. A SaaS product sold only to companies is not covered. A company that also sells to consumers online is covered for that consumer service.
Exemptions must be documented. A provider may argue that a requirement would fundamentally alter the service or be a disproportionate burden, but the law requires a written assessment.

What does the European Accessibility Act require of digital services?

The European Accessibility Act requires covered services to be perceivable, operable, understandable and robust, and requires providers to publish how the service meets those requirements. The directive itself does not name WCAG. It sets functional requirements in its annexes and relies on harmonised standards to make them testable.

For websites and apps, that standard is EN 301 549. EN 301 549 is the European standard for accessibility of ICT products and services, and its web and software clauses reuse the WCAG success criteria. As of October 2026, the version that gives a presumption of conformity is V3.2.1, built on WCAG 2.1 level AA. ETSI published EN 301 549 V4.1.1 in September 2026, which moves to WCAG 2.2 and adds an annex mapped to the directive, but it only gives that presumption once the Commission cites it in the Official Journal. A sensible target for new work is therefore WCAG 2.2 AA: it contains almost everything in 2.1 AA and prepares you for the next citation.

In practice the requirements turn into work in four areas:

Area