Background and Purpose
The EAA aims to remove market fragmentation caused by diverging accessibility requirements among Member States and to ensure that consumers, particularly persons with disabilities, have equal access to key mainstream products and services. The Law represents a significant step toward realising the EU’s broader commitment to inclusivity, non-discrimination, and full participation in society for persons with disabilities, in line with the United Nations Convention on the Rights of Persons with Disabilities.
The Law adopts a broad definition of persons with disability, covering individuals with long-term physical, mental, intellectual or sensory impairments which, in interaction with various barriers, may hinder their effective participation in society on an equal basis with others.
Scope of Application
The Law applies to both products and services placed on the market or provided to consumers as of 28 June 2025.
Covered products include general-purpose computer hardware and operating systems, e-book readers, consumer terminal equipment used for electronic communications or access to audiovisual media, and a range of self-service terminals such as payment terminals, ATMs, ticketing and validation machines, and interactive information terminals (excluding those embedded in vehicles or other transport equipment).
On the services side, the Law governs electronic communications services (excluding machine-to-machine communications), access to audiovisual media services, consumer banking, e-books and dedicated software, e-commerce, and selected aspects of passenger transport services (including websites, mobile apps, real-time travel information and e-ticketing). Specific provisions also apply to interactive self-service terminals used in public transport infrastructure.
Accessibility Requirements
The Law incorporates both general and product- or service-specific accessibility requirements, which are detailed in Annex I. These requirements cover a range of accessibility elements, such as:
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Provision of user instructions, support services and product or service-related information in accessible formats;
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Design of user interfaces and functionality in a perceivable, operable, understandable, and robust manner;
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Accessibility of websites, mobile apps, and other digital environments;
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Ensuring that payment systems, authentication mechanisms, and identification tools used in banking and e-commerce are accessible to persons with disabilities.
Importantly, the Law distinguishes between types of economic operators in the supply chain (e.g. manufacturers, authorised representatives, importers, distributors), allocating responsibilities accordingly under Chapter III, while Chapter IV sets uniform duties for service providers.
Enforcement and Sanctions
The Law introduces a robust compliance and enforcement framework. The competent authority may impose administrative penalties under Article 36, including fines of up to €10,000 for a first offence, and up to €20,000 for repeat offences. Where non-compliance continues beyond the issuance of a fine, additional daily penalties of up to €500 may apply, depending on the gravity of the infringement.
In parallel, Article 38 establishes criminal liability for certain acts, such as marketing non-compliant products or services, issuing or using unauthorised conformity documents, and supplying false or misleading information to the competent authority. A first conviction may result in imprisonment of up to two years, a fine up to €20,000, or both. For repeat offenders, the penalties increase to up to three years’ imprisonment, a fine up to €30,000, or both.
These dual-track enforcement measures reflect the EU’s determination to ensure that accessibility obligations are taken seriously by both manufacturers and service providers.
Conclusion
The transposition of the EAA into Cypriot law through Law 57(I)/2024 ensures that persons with disabilities—and consumers more broadly—are afforded the same level of accessibility and protection across all EU Member States for a specific range of products and services. By setting out uniform standards and enforcement mechanisms, the Law not only enhances consumer protection and legal certainty but also promotes the smooth functioning of the internal market. Businesses operating in the covered sectors should take proactive steps to ensure compliance by the 28th of June 2025 deadline, including reviewing design processes, customer service channels, and conformity documentation.
The content of this article is valid as at the date of its first publication. It is intended to provide a general guide to the subject matter and does not constitute legal advice. We recommend that you seek professional advice on your specific matter before acting on any information provided. For further information or advice, please contact Stephanos Ayiomamitis, Partner at our Limassol Office, Tel +357 25363685 or email stephanos.ayiomamitis@kyprianou.com.