EAA compliance audits, aimed past where the law is today

Yes. Directive (EU) 2019/882 has applied to new products and services placed on the market since 28 June 2025 — that date is in the past as of this page's 2 September 2026 review. Products and services already on the market before that date generally get until 28 June 2030 before they must comply, provided they don't undergo a substantial change in the meantime; a substantial change resets that clock.

It depends on whether you're a service provider or a product manufacturer. The EAA's microenterprise exemption (fewer than 10 employees and annual turnover or balance sheet under €2 million) applies to service providers only. If your business manufactures or distributes a covered product — self-service terminals, consumer computer hardware, e-readers — the microenterprise exemption doesn't apply to that product line, regardless of your headcount.

No — that's a documented, case-by-case assessment, not a blanket opt-out. A business claiming disproportionate burden or fundamental alteration has to actually perform and retain the assessment, covering costs and benefits relative to the estimated benefit for people with disabilities, and be ready to produce it to a competent national authority on request. It also isn't permanent — a reasonable reassessment cadence, or a trigger like a product/service redesign, is expected to prompt a fresh look.

The EU's current presumption-of-conformity route still runs through EN 301 549 V3.2.1, which incorporates WCAG 2.1 AA — that's the version a regulator will check first today. But a draft revision (V4.1.0) moving the standard's web, document and software clauses to WCAG 2.2 AA went to public comment in November 2025 and is expected to be referenced in the Official Journal around October 2026 — a matter of weeks from this page's review date. Auditing to 2.2 now means you're not rebuilding a remediation backlog the moment the standard catches up.

For services, Article 13 and Annex V of the EAA require you to publish a self-assessment — typically in your general terms and conditions or an equivalent public document — that describes the service, explains how it works, and sets out how each applicable accessibility requirement is met. A vague 'we care about accessibility' paragraph doesn't satisfy this; it needs to map to the specific requirements your service is subject to.

No. Automated tools reliably catch a meaningful slice of technical issues — missing alt text, contrast ratios, missing form labels — but they cannot evaluate most WCAG success criteria that depend on context: whether reading order makes sense, whether a custom widget is actually operable by keyboard, whether error messages are genuinely understandable, or whether authentication doesn't rely on a cognitive test a screen-reader or low-vision user can't complete. A credible audit combines automated scanning with manual keyboard and screen-reader testing.

They get a transition period running to 28 June 2030, but that grace period is conditional, not automatic forever. Self-service terminals lawfully in use before the application date, and service contracts concluded before it, can generally continue under the older terms for a defined period, but a substantial change to the product or service — a redesign, a new major version — is generally treated as bringing it back into full scope immediately rather than at the 2030 deadline.