European Accessibility Act (EAA): what does it mean for UK further and higher education?

 

Supporting those with accessibility needs is something that we all know is the right thing to do.  

We don’t like to think of the confrontational side. Why should it be necessary to enact strict enforcement laws to compel organisations and people to make their content and services available to everyone? 

Change, of course, requires investment in terms of time and effort and financial resources. Those who marshal those resources have many competing priorities. Despite substantial goodwill making progress can be slow and can leave those who need accessible content and services at a distinct disadvantage. 

Public sector and education 

In education, significant progress has been made as a consequence of The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. 

[Note: The regulations – sometimes called the PSBARs – implemented the EU Directive on the accessibility of the websites and mobile applications of public sector bodies – Directive (EU) 2016/2102.]  

These regulations impose obligations on public sector bodies to meet accessibility standards when publishing and delivering web browser materials. 

Awareness is increasing of the need to design accessibility in from the start. It is the smart and most cost effective approach to any project involving the delivery of content and services.  

Led by UK Government departments, this message has been received by colleges and universities throughout the UK and has positively influenced their journey towards the delivery of more accessible content and services. 

We have definitely seen a shift in thinking.  

What about commercial products and services? 

Into this environment comes The European Accessibility Act (EAA) which is another European Union (EU) directive (Directive 2019/882). This EU law takes aim at commercial products and services and requires them to be accessible for persons with disabilities. It aims to harmonise accessibility standards and took effect in April 2019. It will become national law in all 27 EU member states on June 28 2025. 

Potential benefits for UK users? 

One obvious question is: what has an EU directive got to do with how colleges and universities operate now that the UK is no longer a member of the EU? 

There are at least two sides to this.  

• As a direct effect of the EAA, providers/producers of commercial digital products and services will be required to meet accessible standards when selling and distributing them in the EU.  

It is likely that the same providers/producers will be selling and distributing these commercial digital products and services in the UK. The knock-on effect is likely to be that even without specific UK legislation requiring them to do so accessibility will be built into these commercial digital products and services.  

• A second question for us is to what extent the legislation applies to products and services that colleges and universities themselves here in the UK are selling and distributing in the EU? If they are what do the new regulations mean for selling and distributing these products and services? 

Commercial activities – some questions that remain to be answered. 

• Now that commercial activities are included in accessibility compliance to what extent are colleges and universities engaging in commercial activities overseas?  

• For colleges and universities actively engaging in recruiting overseas students from the EU how will the EAA apply to the digital products and services involved? 

• Is offering an online course to potential students in the EU, for example, selling a product for the purposes of the EAA? 

EAA – what we do know? 

• It applies to any business with at least 10 staff and a turnover above €2 million. 

• It applies to any business that trades in the EU. 

• Businesses headquartered or based outside the EU must comply with the Act if they sell relevant goods or services within the EU. 

• The directive specifically lays out some key requirements for e-books, e-readers, and reader software to ensure digital reading material is available to everyone.  

• A key takeaway from the EAA is that it highlights the need for the accessibility of the services provided through a device, not just the device itself. For example, “access to audiovisual media services” includes not only the hardware and software of the media player but also the accessibility of the content being accessed. 

What does it mean for procurement? 

Procurement policies can be a critical lever in increasing accessibility and inclusion. Setting standards and criteria for purchasing goods and services in education has become central to safeguarding the equitable inclusion and participation of all. The demand for products and services that meet accessibility standards is increasing and the EAA supports that trend.  

In summary – what are we hoping for from the EAA? 

The EAA complements existing EU legislation on accessibility and as of 28 June 2025, companies must ensure that newly marketed products and services covered by the Act are accessible.  

The EAA aims to create a level playing field, and specifically lays out some key requirements for e-books, e-readers, and reader software to ensure digital reading material.  

In the UK, as a knock-on effect, it can play a role in highlighting the importance of ensuring that commercial products and services that are essential in education meet accessibility standards.  

The influence of the EAA on products and services that colleges and universities here in the UK themselves are selling and distributing in the EU remains to be seen.  

Is your college or university selling and distributing products or services overseas?  Continue the conversation with your peers in our accessibility community.