Background and Purpose #

The European Accessibility Act (EAA) is a landmark legislation aimed at improving digital accessibility for disabled and older people across the European Union. Set to become law on June 28, 2025, the EAA addresses the growing need for inclusive design in products and services, particularly in the digital realm. The Act’s implementation is driven by several key factors:

1. Demographic Shifts: The aging population in Europe is increasing, with the UN projecting that the percentage of individuals over 65 will rise from 10% in 2022 to nearly 16% by 2050.
2. Equal Opportunities: The EAA aims to provide equal access to labor markets, education, and transportation for approximately 135 million people with disabilities in the EU.
3. Harmonization of Standards: By standardizing accessibility rules across all EU member states, the EAA creates a unified market for accessibility solutions.
4. Technological Advancements: The Act recognizes the potential of digital technologies to enhance accessibility and independence for people with disabilities.

What is the EAA? #

The EAA applies to any organization providing products and services to consumers in the EU, including UK businesses. It sets minimum accessibility requirements for a range of products and services across the EU.

Key regulations focus on:

• It requires accessibility of passenger content and information systems in transportation services.
• It mandates compatibility with screen readers and other assistive technologies.
• It emphasizes the importance of real-time, dynamic information for passengers with disabilities.

Key European Standards, Legislation, and Initiatives Supporting the EAA #

The European Commission and EFTA have promoted the development of key European standardisation documents to support European policies on accessibility through Mandates M/376, M/420, and M/473. These standards were developed upon specific request from the EC and funded by the EC and EFTA.

The main existing standards, legislation, and initiatives supporting the EAA accessibility efforts include:

• EN 301549: Accessibility requirements for ICT products and services.
• EN 17161: Design for All approach in products, goods, and services.
• EN 17210:2021:
  • Section 6.2 “Wayfinding” covers requirements for:
    • Consistent use of visual, tactile and audible information.
    • Provision of clear directions and location information.
  • Section 6.3: “Information and communication” includes:
    • Requirements for visual, audible and tactile information.
    • Specifications for the provision of information in alternative formats.
  • Section 11: “Signage and orientation information” covers:
    • Audible information systems.
• EN 17210 (future): Accessibility and usability of the built environment.
• Public Procurement Directive: This directive encourages the purchase of accessible goods and services by public authorities:
  • Article 42:1 requires technical specifications to “take into account accessibility criteria for persons with disabilities or design for all users.”
• Web Accessibility Directive (WAD): While focused on public sector websites and apps, WAD’s principles support accessible digital solutions:
  • It requires public sector digital content to be “perceivable, operable, understandable and robust.”
  • It mandates accessibility features like screen reader compatibility and provision of alternative information formats for people with disabilities.
• European Electronic Communications Code: This directive supports accessibility in electronic communications:
  • It aims to ensure “equivalent access for end-users with disabilities” to electronic communications services.
• European Strategy for the Rights of Persons with Disabilities 2021–2030:
  • Launch of AccessibleEU resource center to increase coherence in accessibility policies.
  • Evaluation of the Web Accessibility Directive.
  • Review of passenger rights regulations for persons with disabilities in transport.
• Article 9 – Accessibility of the UN CRPD:
  • States Parties shall ensure persons with disabilities have equal access to:
    • The physical environment, Transportation, Information and communications, including ICT systems, and other facilities and services open to the public.
  • Measures shall include identifying and eliminating obstacles and barriers to accessibility, applying to:
    • Buildings, roads, transportation and other indoor/outdoor facilities.
    • Information, communications and other services, including electronic and emergency services.
  • States Parties shall:
    • Develop and monitor implementation of minimum accessibility standards and guidelines.
    • Ensure private entities offering public facilities/services consider all aspects of accessibility.
    • Promote the design, development, production and distribution of accessible ICT systems at an early stage.

These standards define accessibility as the “extent to which products, systems, services, environments and facilities can be used by people from a population with the widest range of user needs, characteristics and capabilities to achieve identified goals in identified contexts of direct use or use supported by assistive technologies.”

Non-Compliant Solutions #

Third-party provider’s digital interactive maps and blue-dot navigation are not EAA compliant because they lack:

• Real-time dynamic navigation and directions that constantly update as the user moves through the space. Such as, “Continue 30 feet, 10 feet, turn left, turn around and go left.”
• Voiceover compatibility (screen reader for blind users) of the entire interface and all components of the end user platform.
• Accurate audio directions (within 2-3 meters) that announce directions and provide multiple output options such as haptics, textual, audio, braille output (assistive tech), visual map, etc. to meet the broad range of needs for EAA.
• Ability to access the platform without knowing the user’s starting point or using visual anchor points that have to be scanned such as QR codes, making the solution inaccessible for blind passengers.

Without these capabilities, the platform is not accessible for a blind user meaning they cannot independently navigate or access the building without assistance or booking passenger assistance. This means that the platform does not comply with EAA because EAA requires accessible options for passenger outside of requiring on assistance.

EAA Fines and Deadlines #

The European Accessibility Act (EAA) imposes significant penalties for non-compliance, which vary by country and severity of the violation. Key aspects of the fines and penalties include:

Types of Penalties

• Non-compliance Fines and Daily Penalties:
  • Range from €5,000 to €20,000 per violation and daily penalties up to €1,000 per day for continued non-compliance after notification.
  • Severity of the issue determines the exact amount and daily penalties designed to encourage swift remediation.

Country-Specific Variations

• Penalties vary significantly across EU member states:
  • Ireland: Up to €60,000 and/or 18 months imprisonment for severe cases.
  • France: Up to €250,000.
  • Germany: Up to €500,000 with potential service suspension.
  • Spain: €5,000 to €300,000.
  • Sweden: Up to €200,000.
  • Italy: Up to 5% of turnover or between €5,000 and €40,000.

Enforcement

• National supervisory bodies in each EU member state oversee compliance.
• These bodies monitor, investigate complaints, impose penalties, and can require withdrawal of non-compliant products or services.

Multiple Violations and Complaints

• Multiple accessibility issues with the same product (e.g., a digital map) are typically treated as separate violations.
• Each distinct accessibility failure (e.g., lack of screen reader compatibility, missing haptic feedback) may be considered a separate violation.
• In Germany, fines can reach up to €100,000 per distinct violation.

Impact of Multiple Complaints

• Multiple complaints about the same issue generally result in a single fine.
• However, the number of complaints may influence the severity assessment and potentially increase the fine amount.
• Higher number of complaints could trigger faster enforcement action.

Additional Consequences

Beyond financial penalties, non-compliance can lead to reputational damage, increased regulatory scrutiny, legal costs, and potential market exclusion specifically for public-sector contracts.

It’s crucial for organizations to proactively address accessibility issues to avoid these severe penalties and negative consequences.

Achieving EAA Compliance #

To comply with the EAA, organizations need to ensure their products and services meet the accessibility requirements outlined in the Act and supporting standards. This may involve:

• Conducting accessibility audits of existing products and services.
• Implementing necessary changes to meet EAA requirements.
• Ensuring new products and services are designed with accessibility in mind from the outset.
• Training staff on accessibility requirements and best practices.
• Regularly reviewing and updating accessibility measures.

Using GoodMaps to Meet EAA Requirements for Digital Solutions #

GoodMaps offers a comprehensive solution to make digital mapping and navigation EAA-compliant. GoodMaps can integrate existing maps, that may not be accessible, or create new ones, utilizing LiDAR and 360-degree imagery to provide sub-meter level accurate positioning. GoodMaps employs computer vision training to enhance accuracy and offers a customizable interface tailored for users with various disabilities. The solution has been validated through testing in airports and rail markets, and independently peer-reviewed by universities for inclusivity and universal design.

1. Customizable Accessible Interface
   • Features tailored for various user needs:
     • Blind or low vision users.
     • Deaf or hard of hearing individuals.
     • Neurodiverse users.
     • Non-native speakers.
     • Mobility impaired individuals.
2. EAA Compliance
   • Meets accessibility requirements for digital content and information systems.
   • Ensures compatibility with screen readers and assistive technologies.
   • Provides real-time, dynamic navigation information.
3. Key Features
   • Infrastructure-free implementation (no beacons or QR codes required).
   • Industry-leading accuracy: below 1 meter 100% of the time.
   • Multilingual functionality (support for 18+ languages).

Positive Impact Beyond Compliance #

1. Revenue opportunities from passengers with disabilities:
   • 16% of the world population experiences significant disability.
   • Potential millions in spend from this demographic.
2. Reduced labor/costs for passenger assist efforts:
   • PRM passengers increased from 0.82% in 2019 to 1.00% in 2023 (21% growth).
   • Average PRM charge per departing passenger rose from €0.57 in 2019 to €0.71 in 2023.
3. Improved passenger experience:
   • Only 16% of airports have accessible Flight Information Display Systems for visually impaired users.
   • Just 30% of airports have accessible self-baggage drop-off points.
4. Future-proofing for demographic shifts:
   • UN projects individuals over 65 will rise from 10% in 2022 to nearly 16% by 2050.

By implementing accessible solutions, organizations can enhance compliance, reduce costs, improve user experience, and tap into new market opportunities.