Accessibility: Directive (EU) 2019/882 now applies
News · Regulatory evolution
Since 28 June 2025, Directive (EU) 2019/882, known as the European Accessibility Act, applies across the European Union. It imposes accessibility requirements on many consumer electronic products and related services. For a hardware maker, this is a new family of essential requirements to fold into the technical file and the CE marking.
What changed on 28 June 2025
Section titled “What changed on 28 June 2025”Directive (EU) 2019/882 was adopted on 17 April 2019. Member States had to transpose it into national law by 28 June 2022 and to apply it from 28 June 2025. In practice, products placed on the market and services provided to consumers after that date must meet the accessibility requirements set out in the text.
This is not a separate marking: for products already covered by CE marking, accessibility becomes an additional essential requirement, documented in the technical file alongside electrical safety or electromagnetic compatibility.
Electronic products covered
Section titled “Electronic products covered”The directive targets a precise list of products. For an electronics design house, the categories most directly concerned are:
- Consumer computers and their operating systems.
- Self-service terminals: automated teller machines, payment terminals, check-in machines, transport ticketing machines.
- Payment terminals.
- Consumer terminal equipment with interactive computing capability used for electronic communications services.
- Consumer terminal equipment with interactive computing capability used to access audiovisual media services.
- E-readers.
The EN 301 549 standard
Section titled “The EN 301 549 standard”The harmonised standard EN 301 549 is the technical reference for the accessibility of ICT products and services in Europe. Developed jointly by ETSI, CEN and CENELEC, it draws in particular on the WCAG criteria for digital content and extends the approach to hardware.
When a harmonised standard is cited in the Official Journal of the European Union, applying it opens the presumption of conformity with the corresponding essential requirements. A manufacturer that designs a product to EN 301 549 therefore has a recognised path to compliance, without having to demonstrate equivalence by other means.
What it means for hardware design
Section titled “What it means for hardware design”Accessibility requirements touch both the embedded software and the hardware itself. For a terminal or kiosk, you typically need to plan for:
- Interfaces usable without sight: audio output, text-to-speech, headphone jack, haptic feedback.
- Adapted physical ergonomics: height and reach of controls, contrast and size of display elements, buttons identifiable by touch.
- Alternatives to interactions that rely solely on hearing, sight, fine motor skills or speech.
- Accessible documentation: instructions, labelling and information on available accessibility features in a perceivable format.
These choices are made early, at the product architecture stage: adding an audio output or rethinking the ergonomics of a front panel after the fact costs far more than designing for accessibility from the start.
Microenterprises and transitional regime
Section titled “Microenterprises and transitional regime”The directive provides for adjustments. Microenterprises providing services are exempt from certain obligations, and transitional provisions cover ongoing service contracts and self-service terminals already in use. These exceptions are interpreted strictly: a manufacturer wishing to rely on one must be able to justify it case by case.
As with any essential requirement, products lawfully placed on the market before 28 June 2025 are not made retroactively unlawful, but any new placing on the market from that date onward must be compliant.
Key takeaways
Section titled “Key takeaways”- Directive (EU) 2019/882 applies since 28 June 2025 across the Union.
- It adds essential accessibility requirements to the existing CE marking framework, without creating a separate marking.
- The standard EN 301 549 grants the presumption of conformity for ICT products and services.
- Self-service terminals, payment terminals, computers, smartphones and e-readers are among the products covered.
- Accessibility is designed upfront: multimodal interfaces, physical ergonomics, perceivable documentation.
Going further
Section titled “Going further”- CE scope: applicable directives and products covered
- CE technical file: contents and declaration of conformity
Sources & references
- Directive (EU) 2019/882 on accessibility requirements for products and services , EUR-Lex eur-lex.europa.eu/eli/dir/2019/882/oj
- EN 301 549, accessibility requirements for ICT products and services , ETSI www.etsi.org/standards