EAA Scope Checker
Answer nine questions and get an indicative read on whether the European Accessibility Act applies to you, with the article behind every part of it. It checks scope — it does not scan your website, which is what the other tools called "EAA checkers" actually do.
Indicative result
Runs in your browser. Nothing uploaded.
How to use it
- Say who you are — private business or public body, where you’re established, and whether you reach EU consumers.
- Tick the categories you actually offer. The EAA lists specific products and services. If none of them describe you, tick nothing.
- Set your role and size. Manufacturer and service provider carry different duties, and the size bands decide the microenterprise question.
- Read the result, which cites the article behind every part of it. Copy it, download it, or share the link.
Nothing you enter leaves your browser. Size is collected as a band rather than a number, and there’s no free-text field anywhere, so there’s nothing here worth storing and nothing is stored.
What this tool does that the others don’t
Search for an “EAA checker” and almost everything you find scans a website for accessibility errors. That’s a useful thing. It is not this thing.
A scanner answers is my site accessible. This answers does the law reach me at all — which depends on your sector, your size, your role and your market, none of which appear anywhere in your HTML. A business that’s entirely outside scope can still run a scanner and get back a list of contrast failures and a sales call.
Who the EAA covers
The Act doesn’t cover business in general. It lists categories, and you’re either in one or you aren’t.
| Products — Article 2(1) | What it means |
|---|---|
| Consumer computers and operating systems | General purpose hardware sold to consumers, and the OS on it |
| Self-service terminals | ATMs, payment terminals, ticketing and check-in machines, interactive information terminals. Terminals built into vehicles are excluded |
| Consumer terminal equipment for electronic communications | Smartphones and similar |
| Consumer equipment for audiovisual media | Set-top boxes, smart TVs |
| E-readers | Dedicated e-reading devices |
| Services — Article 2(2) | What it means |
|---|---|
| E-commerce | Selling to consumers through a website or app. The broadest category, and where most businesses land |
| Consumer banking | Retail banking, credit agreements, payment accounts, e-money |
| Passenger transport | The digital parts — sites, apps, e-tickets, travel information, self-service terminals. Urban, suburban and regional services are treated differently: materially only the self-service terminals are caught |
| E-books | The files and the reading software |
| Electronic communications | Telephony, messaging, internet access, emergency communications |
| Access to audiovisual media | The sites, apps and programme guides you reach content through — not the content itself |
If you’re outside the EU, read this part
Where your company is registered doesn’t matter.
The EAA follows the market, not the business. If you place in-scope products on the EU market, or offer in-scope services to consumers in the EU, you’re covered on exactly the same terms as a company in Dublin or Berlin. A US retailer shipping to France is in scope. So is a UK SaaS company selling to Spanish consumers, Brexit notwithstanding.
Two things follow that catch people out:
- Non-EU manufacturers need an authorised representative in the Union. That’s an extra obligation EU-based manufacturers don’t have.
- The nexus is easy to acquire without deciding to. Accepting EU orders, shipping to an EU address, pricing in euro, or offering a local-language version can each create it. EU geo-blocking rules also limit how far you can simply refuse EU customers.
The microenterprise carve-out, and the trap in it
A microenterprise employs fewer than 10 people and has annual turnover or a balance sheet total of €2 million or less. Both limbs — headcount and money. Within the money limb it’s the other way round: turnover or balance sheet, so you qualify on whichever of the two is lower.
Article 4(5) puts microenterprises outside the accessibility requirements for services. You don’t apply for it and nobody grants it — the carve-out is automatic, and it disappears automatically too.
Counting only your own staff is the mistake that costs people this exemption. The EU definition aggregates linked and partner enterprises: if another company holds 25% or more of you, or you of it, their headcount and finances are counted alongside yours. A six-person subsidiary of a multinational is not a microenterprise. If you sit anywhere in a group structure, don’t rely on the carve-out until you’ve checked that.
Status also doesn’t flip the instant you cross a line. Under the SME rules you generally gain or lose it only after exceeding the thresholds in two consecutive accounting periods.
Here’s the part most published guidance gets wrong, including several from vendors who should know better:
The carve-out covers services only. It does not cover products.
A five-person company manufacturing e-readers has the full product obligations — Annex I requirements, conformity assessment, EU declaration of conformity, CE marking, technical documentation kept for five years. The only relief microenterprises get on the product side is not having to document a disproportionate burden assessment.
This is why the tool computes the two sides separately and will happily tell you that one applies and the other doesn’t. That isn’t a bug in the result. It’s the directive.
The dates
| Date | What happens |
|---|---|
| 28 June 2025 | The EAA applies. This is a date that has passed, not a deadline ahead of you |
| 28 June 2030 | Service contracts concluded before June 2025 may run unchanged until they expire, capped at five years. A renewal is a new contract, so it wouldn’t carry the grace over |
| 28 June 2030 | Separately: products you were already lawfully using to provide a service may keep being used until this date. That’s the equipment behind the service — not the service, and not your website |
| Up to 20 years from entry into use | Self-service terminals already lawfully in use may continue to the end of their economically useful life. Replacements must conform |
The transitional periods are narrower than they look. They cover contracts and equipment that already existed. They don’t give you a general extension, and they don’t apply to your website.
EAA or Web Accessibility Directive?
Two different EU instruments, routinely confused.
| Web Accessibility Directive (2016/2102) | European Accessibility Act (2019/882) | |
|---|---|---|
| Who | Public sector bodies of EU member states | Private businesses, wherever established |
| What | Websites and mobile apps | Products and services |
| Statement | Accessibility statement required | Information on how the service meets the requirements |
| Applies since | 2019–2021, phased | 28 June 2025 |
If you’re a public sector body of an EU member state, the earlier directive is likely your primary obligation — though exactly which bodies it catches is set by your national transposition, not by the directive alone. The EAA can still reach you where you provide in-scope services, which is why the tool keeps assessing rather than stopping.
A public body outside the EU is in a different position entirely. 2016/2102 is addressed to bodies of member states, so it won’t normally reach you — but your own country’s public sector accessibility rules almost certainly will, and they’re usually stricter for government than anything here.
Worked example
A seven-person company in Toronto. Sells e-books to consumers, including in the EU, through its own site. Turnover about €900,000. No contracts predating June 2025.
| Answer | Effect |
|---|---|
| Established outside the EU | No effect on scope. Flagged, because people expect otherwise |
| Serves EU consumers | Nexus established |
| Services: e-commerce, e-books | Two in-scope service categories |
| Fewer than 10 staff, under €2m | Microenterprise on both limbs |
Result: the services-side carve-out appears to cover them. Not a clean bill of health — the result still notes that Canadian law applies on its own terms, that customers can impose accessibility requirements by contract, and that hiring three more people ends the carve-out.
Change one answer — they also sell a branded e-reader — and the product side lights up while the service side stays covered. Same company, two different answers, which is exactly the asymmetry Article 4(5) creates.
What standard you’d actually have to meet
The directive sets functional requirements in Annex I rather than naming WCAG. The harmonised European standard is EN 301 549, which for web content incorporates WCAG at level AA. Meeting the harmonised standard gives you a presumption of conformity, which is the practical route almost everyone takes.
Worth knowing: automated accessibility testing of every kind detects only about 30 to 40 per cent of real barriers. Keyboard-only navigation and time with a screen reader find things no scanner reports. Scope is the easy question. Conformance is the long one.
What this tool cannot tell you
It takes what you type and applies the directive to it. It doesn’t look at your site, verify your headcount, or know your sector better than you do.
More importantly: the EAA is a directive, not a regulation. It doesn’t bind you directly. Twenty-seven member states have transposed it into national law — Germany’s BFSG, for one — and a member state may go further than the directive floor. Your binding obligations are in your own country’s act, not in 2019/882 itself. No other tool we found says this, and it’s the thing most likely to make a confident answer wrong.
So: a well-researched starting point, with the article numbers attached so you can check the work or hand it to someone qualified. The result links straight to Directive (EU) 2019/882 on EUR-Lex — citing articles is worth little if we don’t tell you where to read them. Not legal advice, and not a substitute for it.
Related tools
Once you know you’re in scope, the accessibility statement generator builds the statement — and handles the EAA rule that you need one in every language you serve. The colour contrast checker covers the criterion most likely to produce a real failure, testing a pairing or a whole palette against WCAG 2.2. For content itself, the invisible character detector finds zero-width characters that corrupt screen-reader output, the word counter reports readability alongside the count, and the reading time calculator helps judge whether a page is a reasonable length to work through with assistive technology.
Frequently asked questions
Does the European Accessibility Act apply to my business?
It depends on four things: whether you place in-scope products on the EU market or offer in-scope services to consumers in the EU, which categories those fall into, what role you play, and whether you meet the microenterprise test. The tool above walks all four. The short version is that if you sell to consumers in the EU online, you are more likely in scope than not — e-commerce is one of the listed service categories.
Does the EAA apply to businesses outside the EU?
Yes. Where you are established is irrelevant. The obligation attaches to placing products on the EU market or providing services to consumers in the EU, so a US, UK, Canadian or Australian company serving EU consumers is covered exactly as an EU one would be. Non-EU manufacturers additionally need an authorised representative in the Union. This is the single most misunderstood point in the whole directive.
What is the microenterprise exemption, and does it cover me?
A microenterprise employs fewer than 10 people and has an annual turnover or balance sheet total of no more than €2 million. Headcount and money both have to hold; within the money limb it is turnover or balance sheet, so you qualify on whichever is lower. Article 4(5) then puts microenterprises outside the accessibility requirements for services — automatically, with nothing to apply for. The trap is counting only yourself: the EU definition aggregates linked and partner enterprises, so if another company holds 25% or more of you, or you of it, their staff and finances count too. A small subsidiary of a large group is not a microenterprise.
Does the microenterprise exemption cover products too?
No, and this is where most published guidance goes wrong. Article 4(5) is a services-only carve-out. A microenterprise that manufactures, imports or distributes in-scope products — e-readers, self-service terminals, consumer computers — carries the full product obligations including conformity assessment and CE marking. What it does get is relief from having to document a disproportionate burden assessment.
What products and services does the EAA actually cover?
Five product categories: consumer computers and their operating systems, self-service terminals such as ATMs and ticketing machines, consumer terminal equipment for electronic communications, consumer equipment for accessing audiovisual media, and e-readers. Six service categories: e-commerce, consumer banking, the digital elements of air, bus, rail and waterborne passenger transport, e-books, electronic communications services, and access to audiovisual media services.
When did the EAA come into force, and are there deadlines left?
It has applied since 28 June 2025 — that is a past date, not an upcoming one. Three transitional measures remain. Service contracts concluded before that date may run unchanged until they expire, capped at five years, so 28 June 2030. Separately, products a provider was already lawfully using to deliver a service may keep being used until the same date. And self-service terminals already in lawful use may continue to the end of their economically useful life, capped at 20 years from entry into use. None of them cover your website.
Is this the same as the Web Accessibility Directive?
No. The Web Accessibility Directive (2016/2102) covers public sector bodies of EU member states, and their websites and mobile apps. The EAA (2019/882) reaches private businesses and covers products as well as services. A public sector body in the EU is primarily governed by the earlier directive, though the EAA can still apply where it provides in-scope services. A public body outside the EU is not normally caught by 2016/2102 at all, since it is addressed to bodies of member states — its own national rules apply instead. Tools that ignore these distinctions send public bodies down the wrong path.
What standard do I actually have to meet?
The technical reference is EN 301 549, the harmonised European standard, which for web content incorporates WCAG at level AA. Meeting the harmonised standard gives you a presumption of conformity. Note the directive itself sets functional requirements in Annex I rather than naming WCAG directly.
Why does this tool ask questions instead of scanning my site?
Because they answer different things. A scanner tells you whether your pages have accessibility errors. It cannot tell you whether the law reaches you, which depends on your sector, size, role and market — none of which is visible in your HTML. Most tools marketed as "EAA checkers" are scanners. Both are useful; this is the one nobody built.
Can I rely on this result?
Treat it as a well-researched starting point, not an answer. The EAA is a directive rather than a regulation, so it does not bind you directly — your obligations come from your own country's transposition law, which can go further than the directive floor. Germany's BFSG is one example among 27. Every part of the result cites the article it came from so you can verify it or hand it to a lawyer. It is not legal advice.
Guides that use this tool
Last updated: August 23, 2026