European Accessibility Act: does it cover every business PDF?

The European Accessibility Act, EAA, covers selected products and services. Services include e-commerce, e-books and certain consumer banking services. The rules started applying on 28 June 2025. National legislation sets out responsibilities, enforcement and implementation.

Sources: [1]

Products include consumer computer systems and operating systems, payment terminals, specified other self-service terminals, certain consumer equipment for electronic communication and audiovisual media services, and e-readers. Requirements extend beyond document files to information, interfaces and functions.

Services include electronic communications with qualifications, access to audiovisual media services, specified elements of passenger transport, consumer banking services, e-books and dedicated software, and e-commerce. Transport has particular limits; this is not a blanket requirement for every document from every transport business.

Use the categories as a starting point. Describe the actual product or service and compare it with Article 2 and the national definition. Then examine the requirements for that category. A company’s industry label or turnover alone cannot determine the position of every document.

Sources: [2]

Instructions, contractual information or an e-book may need assessment based on their function. Being a PDF is neither an independent reason for coverage nor a way to escape it.

First ask which service the document supports. Establish its audience and the relevant country and legal framework. A standalone annual report and terms used in a consumer service may require different assessments.

Imagine an online bookseller publishing three PDFs: an annual report for investors, terms the consumer needs to understand a purchase, and a book delivered as a digital file. The file extension is identical; their functions differ.

The annual report does not automatically become an EAA service because the company also runs an online shop. Purchase terms may form part of the information in the covered e-commerce service. The e-book needs assessment within the specified e-book service. Other legislation or contracts may still impose requirements on the annual report.

Map the reader’s task: find the offer, understand the terms, identify themselves where necessary, pay and obtain the purchased content. Mark every point where documents are used. A working checkout form does not compensate for essential information locked in an unusable attachment.

Distinguish a service outside scope, a specific exemption and a covered service with defects. These require different evidence and actions. A small business may need to assess the microenterprise rule, while another operator needs to examine the actual requirements for its service.

Once scope is established, allocate responsibility for content, technical work and customer contact. Agree how suppliers will demonstrate document quality and handle later versions. Remediation fixes one document; a reliable process prevents the same failures in the next communication or edition of the terms.

• Describe the product or service in ordinary language.
• Identify whether the recipient is a consumer or a business.
• Describe what readers need to do with the document.
• Check national exceptions and transitional provisions separately.

If customers need PDF terms to understand a purchase, checking the shop’s visible buttons is insufficient. Include the document in the purchase journey and assess it in the context of that service. This is a working method, not a definitive legal finding about every shop.