Which industries the European Accessibility Act covers

Not legal advice. Whether a particular offering falls under Austria's BaFG, Germany's BFSG or another national law depends on the individual case.

Legal basics and deadlines are in The European Accessibility Act and PDFs, country details in BaFG in Austria and BFSG in Germany. This page is about which industries are affected and to what extent.

The list in Article 2 of the directive

Article 2 of Directive (EU) 2019/882 sets out which products and services are in scope. Austria copied the list into section 2 of the BaFG, Germany into section 1 of the BFSG. The products are consumer general-purpose computer hardware and its operating systems (PCs, laptops, smartphones, tablets), self-service terminals such as payment terminals, ATMs, ticketing and check-in machines and interactive information terminals, consumer terminal equipment for electronic communications and for accessing audiovisual media services, and e-readers.

For PDFs, the second half of the list matters more. It covers the following services when they are provided to consumers after 28 June 2025:

• electronic communications services,
• services providing access to audiovisual media services,
• certain elements of air, bus, rail and waterborne passenger transport services,
• consumer banking services,
• e-books and dedicated software,
• e-commerce services.

Which PDFs each industry produces

These service industries produce the documents customers have to read, fill in or keep. The right-hand column links to the industry guide.

One requirement runs through all of these services and hits PDFs directly. Information about the service has to be provided in text formats from which alternative assistive formats can be generated. A scanned image PDF with no text layer fails that test. A tagged PDF with a sensible reading order, Unicode text and a document language (/Lang) gets much closer. The relevant WCAG criteria are covered in WCAG for PDFs.

Insurers, energy suppliers, gyms

None of these appear in the list, and neither do healthcare providers or property managers. That does not settle the matter. What counts is the individual offering, not the industry label.

The usual way in is e-commerce. Article 3(30) of Directive 2019/882 defines e-commerce services as services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract. If private customers can take out an electricity, insurance or membership contract online with you, check whether that process qualifies. How far the definition reaches has not been settled in practice. It does not, however, pull whole industries into scope.

Where an online sales process is covered, the website and the ordering process come first. The documents handed out along the way follow, for example contract terms or confirmations as PDFs. Legal duty or not, customers with disabilities simply get more out of an accessible PDF.

Public bodies follow different rules

Authorities, municipalities, universities and other public sector bodies have accessibility duties, but not because of the EAA. Those duties come from the Web Accessibility Directive (EU) 2016/2102 and its national transposition, which have applied for longer and explicitly include documents on websites. See Accessible PDFs for the public sector.

Consumers, business customers or both

The EAA protects consumers, meaning natural persons acting for purposes outside their trade, business or profession. A wholesale portal open only to traders is therefore generally outside the service obligations. Once private customers can order there too, the offering is usually covered.

Mixed shops are better off assuming they are in scope. Splitting output into “consumer PDFs” and “business PDFs” only makes sense if your systems can tell the two apart in the first place.

Microenterprises

Microenterprises providing services are exempt from the accessibility requirements (Article 4(5) of the directive, section 6 BaFG, section 3(3) BFSG). That means fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million. There is no such exemption for products. Microenterprises dealing with products only get relief from certain documentation and notification duties.

Old files, archives and transition periods

Article 2(4) of the directive excludes certain website and app content. Two exclusions matter for PDFs. One covers office file formats published before 28 June 2025, which are generally understood to include PDF documents. The other covers archived content that is neither updated nor edited after 28 June 2025.

Both apply to existing material. An account statement, an invoice or a revised set of terms created after that date gains nothing from them. Nor do the transition periods in Article 32, which run until 28 June 2030. They apply, for instance, to products that service providers were already lawfully using and to service contracts concluded before 28 June 2025, not to newly generated PDFs.

Where to start

First work out which of your services are aimed at consumers and fall into one of the categories. Then list the documents those services produce, whether someone writes them by hand or a system generates them. One sample per document type is enough to begin with. A PDF/UA check quickly shows whether tags, title, language and fonts are in place. What can only be checked by hand is in the accessible PDF checklist.

Fixes belong at the source, in the template or the generator. Individual files without a source can be given a technical base structure through retroactive tagging. EasyPDFUA tags conservatively and does not replace manual review or a legal assessment of your offering.

Frequently asked questions

Which industries are affected by the European Accessibility Act?

Mainly consumer banking, online retail and other e-commerce services, air, bus, rail and waterborne passenger transport, telecommunications and e-books. On the product side it affects manufacturers of computers, smartphones, e-readers, self-service terminals and certain terminal equipment.

Are insurers or energy suppliers covered?

Not as industries. If they conclude contracts with consumers online through a website or app, though, that can count as an e-commerce service. It depends on the specific offering.

Does the EAA apply to purely B2B companies?

Generally not, because the service obligations protect consumers. Once private customers can also order, the offering is usually in scope.

Do old PDFs have to be made accessible?

No, if they were published on a website before 28 June 2025 or remain unchanged as archived content afterwards. Newly generated or revised documents are not covered by these exemptions.