The EAA and national accessibility laws: how they relate
What the EAA directive is, how the national implementing laws (such as Germany's BFSG) fit into it, and which level is decisive for you in practice.
Around digital accessibility, two levels of rule are easy to confuse: the European Accessibility Act and the national law that actually applies to you. This article explains what the EAA is, how the national implementing laws fit into it, and which level is decisive in practice. The overall overview is on the European Accessibility Act page.
What the European Accessibility Act is
The European Accessibility Act (EAA) is an EU directive – Directive (EU) 2019/882 of April 2019. Its goal is to harmonise the accessibility requirements for certain products and services across Europe, so that member states do not each set their own diverging rules.
Member states had to transpose the directive into national law by June 2022; it has applied since 28 June 2025. The exact dates are covered in EAA deadlines
National implementing laws
Each member state transposes the directive through its own law. Germany does this with the Barrierefreiheitsstärkungsgesetz (BFSG); other countries have their own implementing laws – for example Spain’s Law 11/2023, Italy’s Legislative Decree 82/2022, and France’s Law 2023-171.
These national laws are not separate special routes, but the concrete shaping of common European requirements. Behind them all stands the same EAA.
Directive or law: why there are two levels
Here lies the real distinction. An EU directive is not directly applicable – it is addressed to the member states and sets them a goal they must reach through their own laws. Only the national implementing law has direct effect on businesses and citizens.
For a business this means: the law that applies to you is the national one, not the EAA directly. The EAA is the European basis the national law follows; what is legally applicable in your relationship is the national law.
The chain from directive to technology
The interplay reads as a chain: the EAA (the EU directive) sets the framework; the national implementing law puts it into effect in each country and makes the requirements binding for private providers; for the technical detail it points to the harmonised standard EN 301 549, which in turn draws on the WCAG for web content. The technical bridge is explained in EN 301 549
What this means for you in practice
You comply with the national law of the market you serve – that is the law you are measured against. The view of the EAA becomes relevant above all when you offer across borders within the EU: because all member states transpose the same directive, the requirements are similar across Europe, even though each country has its own implementing law. The shared technical basis – EN 301 549 and the WCAG – stays the same throughout.
Frequently asked questions
Is the EAA the same as national laws like the BFSG?
No, but they belong together. The EAA is the EU directive; national laws such as Germany’s BFSG implement it. The law that applies to you is the national one.
Does the EAA apply directly?
No. An EU directive is not directly applicable; it takes effect through the national implementing law – in Germany, for example, through the BFSG.
Which law applies to me?
The national implementing law of the market you serve. Because all member states transpose the same EAA, the requirements are similar across the EU, and the technical basis (EN 301 549 and the WCAG) is the same everywhere.
This guide is not legal advice. For a binding assessment of your specific case, consult a qualified professional.