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What do you allow?

The European Accessibility Act and your documents.

The EAA (Directive (EU) 2019/882) has applied since 28 June 2025. It is the first cross-sector EU accessibility law aimed at the private sector — and downloadable documents are explicitly in scope.

  • (EU) 2019/882
  • EN 301 549
  • WCAG 2.1 AA
  • PDF/UA-1
On this page
  1. Who is covered
  2. What it means for PDFs
  3. The backlog rule
  4. Enforcement differs by country
  5. What to do about it

Who is covered

Banking and payment services, e-commerce, passenger transport, telecoms, e-books and audiovisual media services — plus their suppliers, because covered companies pass the requirement down their contracts. Micro-enterprises (fewer than 10 employees and under €2M turnover) are exempt from the services rules.

The public sector was covered earlier: the Web Accessibility Directive (EU) 2016/2102 has required accessible websites, apps and office-format documents from public bodies since 2018 (documents published after 23 September 2018 are in scope; the duty phased in fully by June 2021).

What it means for PDFs

The harmonized standard EN 301 549 translates the EAA into technical requirements. For documents it points to WCAG 2.1 Level AA, and PDF/UA-1 (ISO 14289-1) is the recognized technical vehicle for a conformant tagged PDF — what that means in practice →

The backlog rule

Service-related content published before June 2025 generally must be brought into scope by 2030 (with narrow archival exceptions). The backlog is real, but it is budgetable — especially at automated per-page cost instead of agency rates.

Enforcement differs by country

The EAA sets the duty; each member state sets the penalty. The spread is wide — from €15,000 in Lithuania to €1,000,000 in Luxembourg and Spain, and several countries fine as a percentage of revenue.

  • Austria On time (BaFG, 28 Jun 2025) €80,000
  • Belgium On time (CDE amendment, 28 Jun 2025) €200,000 or 6% of turnover
  • Bulgaria Late; CJEU judgment C-646/24 BGN 50,000 ≈ €25,600
  • Croatia Partial; EC formal notice (Mar 2026) €50,000
  • Cyprus Late but transposed (Law 57(I)/2024) €30,000 (criminal liability possible)

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Last reviewed: June 2026, against primary national sources. National rules change; verify a specific figure before relying on it.

What to do about it

  1. Inventory the documents you publish (websites, portals, customer communications).
  2. Check what fails — upload a PDF; the analysis is free.
  3. Remediate at per-page cost with the price visible up front — see pricing.
  4. Keep the reports. Every a11yfy output ships with an issue-level report you can show an auditor or a market-surveillance authority.

a11yfy is a technology provider, not a law firm; this page is not legal advice.