This is a long shot, but I hope to find someone that can help me.

I work for a company that creates digital products for healthcare professionals. Think dashboard with patient data (lab results, dossier etc.). It's for healthcare professionals, not patients

Now I know of the European accessibility act where companies have to comply to in 2025. But I can't find anywhere if this goes for my company as well. Are we e-commerce since we sell our product to healthcare providers? Or is healthcare like this excluded from the EAA?


  • 1
    Sorry but why wouldn’t it? Healthcare professionals are humans. This means they come with a wide range of disabilities. Some of these might exclude them from particular professions, more often due to inaccessible tools than to actually required abilities. The aim of the directives is to fix that.
    – Andy
    Feb 13 at 15:12
  • I totally agree with you, everyone should have access to an accessible product, no matter their function. It's just not up to me to decide.. There's a reason for the legislation and from my experiences, it's because companies simply don't want to see the value (or don't want to spend the money, time and resources). I'm not saying that's a good thing, I'm saying that's sadly how things work. Our product is already pretty accessible, but I want to take it to the next level. If the EAA is a way to motivate a company to make an accessible product, then why not use it?
    – Tessa
    Feb 14 at 10:52
  • I’m voting to close this question because it's not a UX question, it's a Legal one. The UX issue is "Should our site be accessible?" and the answer will always be 'yes'.
    – JonW
    Mar 14 at 12:22

1 Answer 1


Full disclaimer: I'm not a lawyer, you should consult one on this matter. And the answer is based on experiences with Finnish legislation, which is based on EU legislation.

There are actually two EU Directives that affect the accessibility of digital products.

The one you mentioned is 2019/882 and it will take effect in 2025. 2016/2102 is in effect already.

2016/2102 states that

Member States shall ensure that public sector bodies take the necessary measures to make their websites and mobile applications more accessible by making them perceivable, operable, understandable and robust.

Directive talks about websites but I have adopted it to include all digital products.

This means that if your product is bought by public sector body, such as a city to provide to citizens, then it should be accessible. Public sector bodies do require accessibility in tenders.

It doesn't say it so in the directive but in Finnish legislation public sector body is defined as something that receives half of their budget from public sector entities, such as the state. So hospitals that buy your product may or may not be counted as public sector bodies.

There is an exception though. Directive does not apply to

content of extranets and intranets, that is to say, websites that are only available for a closed group of people and not to the general public as such, published before 23 September 2019, until such websites undergo a substantial revision

So in your case the product may be comparable to intranet and be exempt of accessibility requirements if it is published before September 2019. If your product undergoes a substantial revision, then it will need to meet accessibility requirements.

2019/882 doesn't change anything above. It only adds new things to the scope of services that need to adhere to accessibility requirements, such as the e-commerce you mentioned.

So, if your product is used in public sector, as in comparable role to intranet and has been substantially revised after September 2019, I'd say it needs to adhere to accessibility requirements. Current accessibility requirements are laid out in the European Standard EN 301 549 V3.2.1.

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