EAA content exclusions: what Article 2(4) leaves out

In brief

Article 2(4) of the European Accessibility Act leaves five kinds of website and mobile app content out of the Directive. Two of them depend on a date: 28 June 2025. Everything else on your site or app, including new and edited content, is still in scope.

Use this page to sort your content into "excluded" and "in scope" before you plan fixes.

The five exclusions

• Pre-recorded time-based media published before 28 June 2025. Pre-recorded video and audio published before that date are excluded.
• Office file formats published before 28 June 2025. Examples are Word, Excel and PowerPoint files.
• Online maps and mapping services, where the maps are intended for navigation and essential information is provided in an accessible digital manner.
• Third-party content that is neither funded nor developed by, nor under the control of, the economic operator concerned.
• Archives: content of websites and mobile apps that is not updated or edited after 28 June 2025.

The wording above is condensed. Read Article 2(4) for the exact text.

What is not excluded

• Live media. The exclusion covers pre-recorded media only. Live captions are still a question for criteria such as 1.2.4.
• New and updated content. A file or video published after 28 June 2025 is not covered by the date-based exclusions.
• HTML pages. Pages published before the date are not in the list of excluded items, unless the content qualifies as an archive.
• Your own interface. Navigation, forms, checkout and apps are not excluded.

How to sort your content

1. Make an inventory of videos, audio, PDFs and Office files with their publication dates.
2. Mark what was published before 28 June 2025 and has not changed since.
3. Check embedded content to see whether you fund, develop or control it.
4. Check maps. Make sure the essential information is also available in an accessible digital form.
5. Decide whether to fix content that is excluded. Fixing it is still allowed and often useful for users.

What to do

• List the content types in Article 2(4). Do this for your site and for your apps.
• Record publication and update dates. The date-based exclusions depend on them.
• Fix what is not excluded first. Start with new, edited and frequently used content.
• Review after every update. Editing an excluded item can bring it into scope.

Common mistakes

• Treating a republished or edited file as old. A new version published after 28 June 2025 is not covered by the date-based exclusions.
• Calling every embed third-party content. The exclusion applies only if you neither fund, develop nor control it.
• Assuming all video is excluded. Only pre-recorded media published before the date is excluded. Live media and newer videos are not.
• Using "archive" for anything old. Archive content is content that is not updated or edited after the date.

Sources

• Directive (EU) 2019/882, European Accessibility Act (EUR-Lex), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official text of the European Accessibility Act (Directive (EU) 2019/882) and to the national law of the Member State where you operate.