EAA – insufficient information to consumers

With the 28 June application of the European Accessibility Act (EAA), EU member states’ competent authorities and market surveillance authorities are moving into position. Their role is crucial: to ensure that the wide range of products and services covered — from e-commerce platforms and smartphones to ticketing machines and banking apps — meet the EAA’s common accessibility requirements.

National authorities in several countries have already published instructions for businesses on how to report compliance. There are also forms and procedures for declaring “disproportionate burden” or “fundamental alteration” where full compliance is claimed to be technically or economically unfeasible. These documents help providers navigate their legal obligations and, hopefully, also make it easier for authorities to get the right information and avoid complex and costly investigations and enforcement procedures.

End-user perspective

However, when it comes to guidance for end users with disabilities, the picture is far less complete. While the EAA explicitly grants consumers the right to complain about inaccessible products and services, far fewer member states have published clear, centralised instructions for how an individual can exercise that right.

This gap matters. Under the EAA, a complaint is not just a customer service issue — it is a legal enforcement trigger. If an end user reports an accessibility barrier to the relevant competent authority, that authority is obliged to investigate and, if necessary, order corrections, impose fines, or restrict sales. Without clear and accessible information on how to file such complaints, many legitimate cases will never reach enforcement channels.

The absence of visible, accessible complaint pathways risks undermining the Act’s effectiveness. Even the most well-crafted accessibility requirements rely on feedback from those directly affected to identify failures in the real world. Without this loop, authorities may focus heavily on compliance documentation from providers, missing persistent barriers that users face.

For the EAA to deliver on its promise, end-user complaint procedures must be as visible and clear as the compliance guidance given to economic operators. That means:

• Publishing easy-to-read instructions on where to complain, what to include, and what happens next.
• Ensuring complaint processes are accessible, offering multiple formats and languages.
• Actively promoting the right to complain through disability organisations, public service campaigns, and provider accessibility statements.

The EAA is a milestone in harmonising accessibility across the EU. But legislation is only as strong as its enforcement, and without the lived experience of persons with disabilities, important aspects will be neglected.

This is not to say that accessibility is the responsibility of the end users. Far from it. But to truly succeed, competent authorities must give equal weight to empowering end users to speak up as they do to helping businesses prepare. Accessibility experts as well as the civil society should do our best to help spreading the word.

Susanna Laurin