The digital world is becoming more inclusive – by law. With the enforcement of the European Accessibility Act (EAA) fast approaching on June 28, 2025, organizations across the EU must prepare to meet a new standard of accessibility. This sweeping directive affects nearly everything you “publish” on a “website”, and for many providers compliance is no longer optional.
Demand for accessibility is increasing in tandem with the projected increase in the number of persons with physical, mental, intellectual and sensory impairments, as well as persons with functional limitations, such as the elderly. The EAA (Directive (EU) 2019/882) aims to improve the functioning of the EU market for accessible products and services by removing barriers created by divergent accessibility rules in the different Member States.
With the aim to deliver sustainable economic and social benefits from a connected digital single market, thereby facilitating trade and promoting employment within the EU, the impact of the directive is wide. It applies to economic operators offering products and services in the private sector, and sets out common accessibility requirements for a large range of such goods and services, spanning everything from ATMs and smartphones to e-books and e-commerce platforms, and makes special reference to audiovisual media services.
An area of particular interest for the audiovisual localization sector is exactly how this directive affects the accessibility of audiovisual media content, which so far has been regulated by Directive 2010/13/EU of the European Parliament and the Council. While the latter still applies and the EAA primarily addresses platforms and services providing access to audiovisual content rather than the content itself, there is an implication that newly published content may also need to be made accessible when offered through these services.
(31) For the purposes of this Directive, access to audiovisual media services should mean that the access to audiovisual content is accessible, as well as mechanisms that allow users with disabilities to use their assistive technologies. Services providing access to audiovisual media services could include websites, online applications, set-top box-based applications, downloadable applications, mobile device-based services including mobile applications and related media players as well as connected television services. Accessibility of audiovisual media services is regulated in Directive 2010/13/EU of the European Parliament and the Council, with the exception of the accessibility of electronic programme guides (EPGs), which are included in the definition of services providing access to audiovisual media services to which this Directive applies.
The definition of “services that provide access to audiovisual media services”, provided in Article 3.6, makes it clear that streaming platforms specifically fall under the scope of the directive, and therefore need to be accessible – as opposed to linear broadcasters that are not affected at all.
Article 3.6: ‘services providing access to audiovisual media services’ means services transmitted by electronic communications networks which are used to identify, select, receive information on, and view audiovisual media services and any provided features, such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation, which result from the implementation of measures to make services accessible as referred to in Article 7 of Directive 2010/13/EU; and includes Electronic Programme Guides (EPGs);
What is not easy to ascertain from the above definition is whether media content itself, such as films and series, also falls under the definition of “services providing access to audiovisual media services” and would therefore need to be made accessible. This has left content owners wondering whether they need to start offering accessibility services in bulk for their content and, if so, which accessibility services are required to ensure compliance – some or all of them.
It might be easier to answer the first part of this question by looking where the directive does not apply. Article 2.4 points out that pre-recorded time-based media published before June 28, 2025 is exempt, implying that pre-recorded time-based media published after that date needs to be made accessible.
Article 2.4: The Directive does not apply to the following content of websites and mobile applications:
(a) pre-recorded time-based media published before June 28, 2025;
(b) office file formats published before June 28, 2025;
(c) online maps and mapping services, if essential information is provided in an accessible digital manner for maps intended for navigational use;
(d) third-party content that is neither funded, developed by, or under the control of the economic operator concerned;
(e) content of websites and mobile applications qualifying as archives, meaning that they only contain content that is not updated or edited after June 28, 2025.
Exceptions to the obligation to make the content of websites accessible do exist and are defined under Article 14 of the directive. These are based on the principle of disproportionate burden, but this must be demonstrated with evidence, not assumed. Factors considered include the cost of compliance relative to the size of the business and the potential market impact. The full list of criteria listed in Annex VI of the directive.
The responsibility of proving compliance with accessibility requirements falls directly with each service provider, which must self-declare and provide information as to how exactly the accessibility requirements referred to in Article 4 are met – as explained in Annex V.
While there is no requirement for periodic compliance reports, local regulators may request explanations or remedial actions if issues are identified, particularly when issues are reported by consumers or advocacy groups.
By following harmonized standards such as EN 301 549 service providers can benefit from a presumption of conformity making it easier for them to demonstrate compliance.
EN 301 549 is the European standard that outlines the functional accessibility requirements for the full range of ICT products and services, including multimedia players, software and digital services. It is developed by the European Telecommunications Standards Institute (ETSI), is harmonized under the EAA, and it incorporates the Web Content Accessibility Guidelines (WCAG).
A new revision of EN 301 549 is under development, and if you're a stakeholder, you can participate. This revision will directly define what counts as “accessible” under the EAA, so influencing the process now means shaping the future of digital compliance. It will also provide an answer to the question as to which or how many accessibility services one is required to offer.
If you are the content owner of a website or mobile app that includes “services providing access to audiovisual media services” you could take several actions:
The European Accessibility Act is more than a legal mandate—it is a cultural shift and broader commitment toward digital inclusion. As of June 28, 2025, all newly published web content and audiovisual services must be accessible to everyone, including people with disabilities. Organizations that embrace accessibility will not only avoid penalties but open their services to millions of users with disabilities.
[1] Directive (EU) 2019/882 ofthe European Parliament and the Council of 17 April 2019 on the accessibilityrequirements for products and services (OJ L 151/85, 7.6.2019, p.4).
[2] Directive (EU) 2019/882 ofthe European Parliament and the Council of 17 April 2019 on the accessibilityrequirements for products and services (OJ L 151/85, 7.6.2019, p.15).
[3] Ibid.
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