European Accessibility Act: cosa cambia davvero per le aziende di product design
Il 28 giugno 2025 è una data che molte aziende manifatturiere hanno segnato in agenda come scadenza burocratica. Un anno dopo, quelle stesse aziende si trovano ad affrontare una domanda che non avevano previsto: perché la conformità non è sufficiente?
Cosa prevede l’EAA: una sintesi per i non-giuristi
The European Accessibility Act (EU Directive 2019/882) requires manufacturers, importers and distributors to ensure that certain categories of products and services are accessible to people with disabilities by 28 June 2025. The categories covered include computers, smartphones, TVs, e-book readers, payment terminals, ticket machines, banking services, e-commerce, transport services and electronic communications.
In technical terms, the directive refers to the principles of Design for All: products and services must be perceivable, operable, understandable and robust for people with various types of disabilities — motor, visual, hearing and cognitive.
Compliance is not voluntary. Non-compliant products may be withdrawn from the market. Penalties vary by Member State, but the principle is consistent: accessibility is a legal requirement, not an ethical option.
Which products are affected — and which aren’t
The directive explicitly covers: self-service terminals (ATMs, ticket machines, kiosks), e-reader hardware, computers and operating systems, smartphones, televisions with digital services, e-commerce services, retail banking services, electronic communications services, and passenger transport (websites, apps, e-tickets).
The following are not directly covered: furniture, cosmetics, clothing, kitchen utensils, and industrial products not intended for the end consumer. However — and this is the point that many companies have not yet grasped — the EAA does not exhaust the legal issue: Legislative Decree 82/2005 (Consumer Code), Presidential Decree 503/1996, UNI EN standards and public procurement legislation already impose accessibility requirements in many contexts not covered by the European directive.
The critical issue that many companies underestimate
In the year following the EAA’s entry into force, a recurring pattern emerged: companies consulted their legal departments, which produced a compliance checklist. The checklist was passed on to the technical department, which added attributes to the documentation and revised the user instructions. The product remained unchanged.
This approach has a specific name: retrofitting. It is the most expensive — and least effective — way to address accessibility. The reasons are structural.
A product that has not been designed with human diversity in mind cannot become accessible through minor modifications. Accessibility is not added at the end of a design process: it is incorporated in the early stages, when fundamental decisions on form, function, materials and interaction are still open.
Anyone who has worked with Design for All knows this from direct experience: integrating accessibility principles during the brief and concept phases reduces subsequent adaptation costs, improves usability for all users — not just those with disabilities — and generates more competitive products, not less.
From compliance to competitive advantage: the role of Design for All
The market for people with disabilities in Europe comprises over 87 million people. If we include older people (by 2050, a third of the European population will be over 64), people with temporary disabilities, and family members who influence purchasing decisions, the scope expands enormously.
Companies that integrated Design for All into their R&D process before the EAA are not facing a compliance crisis: they are reaping the benefits of a choice made well in advance. Their products do not require emergency updates because user diversity was already part of the original brief.
The competitive advantage is not theoretical. It is measurable in: a reduction in the number of product variants needed to cover different market segments; a reduction in returns and after-sales service requests; increased customer loyalty; and an expansion of the customer base without increasing production costs.
What does it mean to design for the EAA from the very beginning?
Integrating EAA principles right from the start of the process essentially means doing three things:
- First: involving users with different abilities in the research and testing phases. Not as a token statistical sample, but as the primary source of design requirements. It is the difference between knowing that an older person ‘might have difficulty’ and understanding exactly where, why and how to modify the concept.
- Second: define accessibility criteria in the project brief — not in the final specifications. The question ‘is this product accessible?’ must be asked before the product’s design has been finalised, not when it is already in production.
- Third: verify compliance through prototypes and test models before final production, not through post-production legal checklists. A prototype tested with real users is worth more than ten compliance audits.
Now is the time to act
For companies developing new products or re-evaluating existing ranges, the time is now — not because the EAA imposes it as a bureaucratic urgency, but because the market demands it as a prerequisite for competitiveness.
Companies that treat accessibility as a compliance issue are tackling the wrong problem. Those that treat it as a design opportunity are building the competitive advantage of the next decade. The distinction is not semantic. It is strategic.
For 20 years, we have been working with companies — from bathroom furnishings to cosmetics, from electronics to cultural venues — to translate this distinction into better products, environments and services. Not because it is ethically right.
