The European Accessibility Act applies to Japanese exporters

While accessibility work inside Japan proceeds without a standard, the EU has both a standard and a date. Japanese companies are in scope.

Directive (EU) 2019/882, the European Accessibility Act, has applied since 28 June 2025.

The scope is the part that matters. It does not cover only EU based companies. It covers economic operators placing products or services on the EU market. Selling from Japan to a buyer in the EU puts you inside it.

Products and services covered

The directive lists, among others:

• E-commerce services
• Consumer banking services
• E-books and the software used to read them
• General purpose hardware such as computers, smartphones and tablets, and their operating systems
• Self service terminals including ticketing machines, ATMs and check in kiosks
• Electronic communications services
• Websites and apps relating to passenger transport

For Japanese companies the two most common categories are cross border e-commerce sites and hardware products sold into the EU.

Exemptions and transitional measures

Not every company is in scope.

Article 4(5) exempts microenterprises, defined as fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million. That exemption applies to services and not to products.

Article 32 contains transitional measures. Service contracts concluded before 28 June 2025 may continue for a defined period, and self service terminals already in use before that date have a grace period.

Checking those two articles is the fastest way to find out whether you are affected.

The relationship to Japanese requirements

As covered in the previous article, Japan has no concrete standard for private businesses. The EU does.

That makes the decision easier. If you export, meet the EAA. The EAA references EN 301 549, whose core is WCAG 2.1 level AA. Japan's JIS X 8341-3:2016 points at substantively the same level.

Preparing for the EU therefore also prepares you for reasonable accommodation at home. You do not need to maintain two standards.

The order to check things in

1. Confirm that you sell into the EU. A website being reachable from Europe is not sufficient. The question is whether you offer to customers in the EU.
2. Identify the category. Which of the list above applies. Cross border retail is an e-commerce service.
3. Check the microenterprise exemption. Article 4(5). It does not help if you place products on the market.
4. Measure against EN 301 549. Rather than the full standard, start with automated and manual checks across WCAG 2.1 level AA.

Those four steps narrow the work considerably. For most Japanese companies the actual remediation is smaller than expected, but you cannot know that without checking.

The date has passed

28 June 2025 is more than a year behind us. Where a company is in scope and has done nothing, exposure now comes from member state authorities and from customers asking.

Penalties are set nationally by each member state, so the size of the risk depends on which countries you sell into.