Member State Transposition
Each EU Member State must transpose the EAA into national law. Operators comply with the national transposition, not the directive directly. Penalties, exemption procedures, and (in some cases) the scope of covered services vary between Member States.
Each EU country turns the directive into its own national law — so the exact rules and penalties can differ from country to country.
The EAA's transposition deadline was 28 June 2022; the application date for products and services was 28 June 2025. National laws name the competent authority, set the penalty range, define the complaint mechanism, and may grant transitional periods (e.g., for self-service terminals already in service).
Why this matters
An EAA-compliant operator can still be non-compliant in a specific Member State. Germany's Barrierefreiheitsstärkungsgesetz (BFSG), France's adapted Code de la consommation, the Netherlands' Toegankelijkheidswet, and Ireland's European Union (Accessibility Requirements of Products and Services) Regulations all differ in detail. Multi-market operators need a per-market compliance map.