Voices - DG JUST
What was the biggest challenge in balancing ambition with practical implementation when writing the directive?
The challenge was addressing every barrier faced by persons with disabilities while building sufficient legal argumentation. Whenever the Commission takes an initiative, we must answer three fundamental questions.
First, the legal basis. We chose the internal market, which requires demonstrating that divergent national legislation creates barriers. We managed this for products and services now covered by the Act — but not for other products and services. Civil society asked us to include domestic appliances, for example, but without existing national legislation on accessibility to point to, is not possible to make the case.
Second, subsidiarity — showing that the problem must be solved at EU level because national action alone wouldn't suffice.
Third, proportionality — the cost-benefit analysis of how best to regulate. Finding equilibrium between the objective of an inclusive society and the practical justification required for shaping the legislation.
Looking back at the drafting process, what assumptions about business readiness proved most accurate or inaccurate?
During drafting, some industry voices argued the requirements were too ambitious. They preferred carrots over sticks — focusing only on procurement incentives rather than market entry requirements. Some organisations even said that that companies may withdraw products from the market or even go bankrupt.
This proved wrong. We had evidence from other parts of the world and from countries with existing accessibility legislation that it was feasible. We knew our measures were proportionate. So in that respect, our assumptions held up.
Now that member states are implementing EAA, what has surprised you most?
I expected more attention to implementation from the moment the Act was adopted in 2019. What surprised me was the late reaction from some organisation — some close to application date said "we don't have time." Well, there were six years. Perhaps I was naïve in hoping everyone would act earlier, but the delay in starting preparing for application genuinely surprised me.
What implementation approaches made you think "that's exactly what we envisioned" — and what made you think "that's not what we meant"?
On the positive side, although late, some sectors came together — raising awareness, developing guidance, reaching out to the Commission, building momentum. That collaborative dynamic is what we envisioned.
On the negative side, close to the application date, some organisations asked whether they could use the "disproportionate burden" article to avoid compliance entirely. We said: that's not what the direcctive intended. These provisions are safeguards, not escape routes. They allow alternatives when specific points create real burden that would be disproportionate — in production, investment, service delivery — but they were never meant as a mechanism to do nothing.
We were always conscious of proportionality and protecting industry, because ultimately economic operators must implement the directive. But the idea was never to provide an excuse for inaction.
Where do you see European accessibility policy heading in the next decade — is EAA the foundation for something bigger?
The Act requires the Commission to report by 2030 on what has worked and what hasn't, so it's too early to say definitively.
But the Accessibility Act is certainly not the end. It sets common requirements, and we already see other EU legislation referencing it. The AI Regulation, for example, requires high-risk AI to be accessible according to the Act's standards. We see similar references in labelling and other areas. The Act is opening doors — embedding accessibility across wider EU legislation.
Which emerging technology or social trend will most challenge the EAA framework?
In economically difficult times, accessibility is often questioned as a cost. In the context of competitiveness it gets framed as a burden. I see it differently — accessibility brings competitiveness — but that perception remains a challenge.
Regarding technology, AI is the obvious paradigm shift. Accessibility must be embedded — not just avoiding discrimination and bias, but actively using AI to create assistive solutions. Mainstream products must be accessible, and AI should also be used to develop specific tools for persons with disabilities.
What would success look like to you personally — how will you know the EAA achieved what you hoped?
Success means users with disabilities no longer face barriers, and industry sees accessibility as a competitive edge — investing because it makes business sense, not just because it's required.
The essence of accessibility is personalisation, flexibility, choice and control. These are the features that make products successful. When there are no complaints from users and industry invests because they see competitiveness, we will have succeeded.
Businesses keep asking about return on investment. Is there data?
We're working on it. Together with Accessible EU, we've launched a study asking companies to provide data on costs, benefits, and return on investment.
The challenge is that companies don't track accessibility costs. Those who haven't invested say it's expensive — but can't provide figures. Those who have invested say it's embedded in their processes and is not a major cost.
Here's what I know: thirty years ago, accessibility features like screen enlargement were separate devices, often more expensive than the computer itself. Since then, computer prices dropped exponentially while accessibility features became embedded in the computers and did not significantly impacted the prices.
Interview by Karolina Mendecka
Business Accessibility Forum Director