What is the compliance deadline for the European Accessibility Act if my service already exists?

The general rule has no separate deadline for an "already existing" service: the requirements apply from 28 June 2025 for every service on Directive (EU) 2019/882's list, regardless of how long you have been offering it. Three narrower exceptions reach further into the future. They cover products lawfully used before that date, until 28 June 2030. They also cover service contracts already signed, unaltered, for at most five years after 28 June 2025; and self-service terminals, until the end of their economic life, but no more than twenty years after they entered use.

Published 24.09.2026. Checked 24.09.2026.

Does the general rule of 28 June 2025 apply to an "old" website too?

Article 2(2) of the directive sets one date for every service on its list, e-commerce, consumer banking, e-books and the rest. The service must meet the requirements from 28 June 2025 onward. The date you launched your site or started selling online does not matter. An online shop opened in 2018 is in the same position as one opened yesterday. If the service falls within the Act's scope, compliance is counted from 28 June 2025, not from the launch date.

What is exception one: products already in use before 28 June 2025?

Paragraph 4(1) of the transitional provisions in the Bulgarian law transposing the Act repeats Article 32 of the directive. Until 28 June 2030, service providers may continue to provide their services using products which were lawfully used by them to provide similar services before that date. The exception covers the product, not the service itself. If your service runs on software or hardware bought and put into use before 28 June 2025, you are not required to replace it immediately. A website you actively maintain and change is not a "product used before that date" in the sense of the provision. It is the service itself, and it follows the general rule above.

What is exception two: service contracts already signed?

Point 2 of the same paragraph gives a second, narrower extension. Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no later than five years after that date. That means no later than 28 June 2030. This covers a business that signed a contract for a service delivery (software as a service from an external provider, for instance) before the date and has not changed it. The moment the contract expires, is renewed, or is amended, the extension ends and the service must meet the requirements from then on.

What is exception three: self-service terminals?

Point 3 gives the longest window. Self-service terminals lawfully used by a service provider before 28 June 2025 may continue to be used until the end of their economic useful life. This applies for no more than twenty years after they entered into use. In practice this covers an ATM, ticketing machine or order terminal bought before the date. It can stay in service for years to come, until it is physically replaced.

What does this mean for an online shop you actively run?

If your service is the website itself, not a product or a contract signed before 28 June 2025 and left unchanged, the general rule most likely applies to you: compliance from now. The practical check is simple. Ask whether the service runs through something frozen in time before 28 June 2025 (an old terminal, an old contract), or through something you actively maintain and update. The US accessibility firm Accessible.org reaches the same distinction. The window to 2030 covers products behind the delivery of a service, servers or payment-processing systems for instance. It does not cover the consumer-facing digital services themselves, which stay in operation and keep getting updated. In the second case, which covers most active websites, the transitional provisions exempt you from nothing.

Questions

If our website launched in 2015, does that give us a longer deadline?

No. The launch year does not affect the deadline. The exceptions depend on whether the service runs through a specific product or contract frozen before 28 June 2025. They do not depend on the age of the business or the site as a whole.

Does the terminal exception protect us if we also sell online?

Not automatically. The terminal exception covers the specific physical device, not your whole service. The online part of the business, if it falls within the Act's scope, follows the general deadline of 28 June 2025.

Do the 28 June 2025 and 28 June 2030 dates apply the same way in every EU country?

Yes, for 28 June 2025 and 28 June 2030. Article 31(2) sets 28 June 2025 as the point services must meet the requirements. Article 32(1) sets 28 June 2030 as the end of the transitional period for products and contracts from before that date. The window of up to twenty years for self-service terminals is optional for each state (Article 32(2): "Member States may"). Bulgaria adopted it in § 4 of its law.

Sources

Check whether your service is in scope before you rely on an exception.

If your website is actively maintained and not tied to an old contract or an old terminal, the general rule applies: compliance from 28 June 2025. A Digital Accessibility Review shows where your website falls short of WCAG 2.2 level AA, which also covers WCAG 2.1 AA, the technical basis behind the requirements today.

Ask about a Digital Accessibility Review

or write to contact@ergostrat.com