NEWS & EVENT

According to Articles 31 and 32 of the European Accessibility Act (Directive (EU) 2019/882), the compliance requirements during the transitional period differ somewhat between products and services, and it is necessary to consider separately the roles and responsibilities of manufacturers and service providers.

Article 31: Transitional measures
This article states:

"Products falling under the scope of this Directive which were placed on the market before [28 June 2025], or services provided before that date, may continue to be made available on the market or provided respectively after that date."

It clearly indicates that products placed on the market or services provided before 28 June 2025 may continue to circulate or be offered, even if they do not meet the accessibility requirements set out in the Directive. Therefore, products already placed on the market by manufacturers before this date may continue to be sold without mandatory upgrades or withdrawal, forming a product-level transitional mechanism (grace period).

Article 32: Transitional period for services
This article states:

"Service providers may continue to provide services that are not in conformity with this Directive until 28 June 2030, provided that those services were prepared before 28 June 2025 and the provider has taken the necessary measures to ensure conformity of those services by that date."

This provision applies only to service providers and grants a transitional period of up to five years, allowing them to continue providing existing services prepared before 28 June 2025 until 28 June 2030. However, manufacturers are not included within the scope of this article and are not granted an equivalent five-year grace period.

Technical and practical background supplement:
In practice, the point of compliance for products is the date they are placed on the market. According to the EU Blue Guide on the implementation of EU product rules, once a product is lawfully placed on the market, subsequent regulatory changes generally do not apply retrospectively. Therefore, products placed on the EU market before 28 June 2025 may continue to be supplied and used even if they do not comply with the new regulations. This aligns with the principle stated in Article 31 and forms the legal basis for manufacturers’ transitional period regarding product compliance.

In contrast, due to the continuous and dynamic nature of services, Article 32 specifically establishes a clear five-year transitional period for service providers. This aims to give providers sufficient time to adjust their information systems, applications, or platform architectures to meet accessibility requirements. This transitional period does not apply to manufacturers or their products.

Conclusion:
Manufacturers:

• Under Article 31, products placed on the market before 28 June 2025 may continue to be sold and used without being subject to the new EAA requirements.
• Manufacturers do not benefit from the five-year transitional period set out in Article 32.

Service Providers:

• Services prepared and provided before 28 June 2025 may continue to be offered until 28 June 2030.

This distinction is important for formulating compliance strategies for products and services. Enterprises are advised to conduct compliance assessments and plan schedules in advance based on product launch dates and service rollout plans.