EAA compliance for telecoms: scope, enforcement and the four requirements

Why telecoms is in scope

The European Accessibility Act names electronic communications directly. For a telecoms operator, that means the consumer-facing product is in scope: the website and account area, the flows for choosing a plan, signing up, topping up and paying a bill, the mobile app, and the customer-support channels around them. These are exactly the journeys the Act is concerned with. In practice that means WCAG 2.1 Level AA, the level EN 301 549 sets out. How the standard relates to the Act explains the detail, and whether EN 301 549 has been cited under the Accessibility Act is tracked and dated.

So the question for an operator is not whether the EAA applies. It is whether the consumer journeys have been evaluated against that standard, and what the operator could show if asked.

Ireland: how the process works

ComReg, the Commission for Communications Regulation, is the designated compliance authority for the accessibility of electronic communications services in Ireland, and can receive complaints and take enforcement action.

It is worth knowing how a complaint reaches ComReg at all. A consumer is expected to raise the problem with the provider first; ComReg comes in when it is not resolved. So the operator’s own complaint handling is the first thing tested, before the regulator sees anything.

Ireland is distinctive on consequences. Serious, sustained non-compliance can carry criminal sanctions here, including personal liability for company directors. That is not the likely outcome of a first complaint, and it is not the point of raising it.

There is also a second route that runs independently of the regulator: the Irish regulations allow a consumer to seek an order for compliance directly from the Circuit Court. So a complaint to ComReg is not the only way a requirement gets enforced.

What matters more than either is that enforcement is remediation-first, and a due-diligence defence is available to an operator that can show it has assessed its products and is acting on what it found. The operators exposed are the ones with nothing to show.

The Netherlands: a separate track, already running

In the Netherlands, electronic communications sit on their own enforcement track under the ACM, the Authority for Consumers and Markets. A self-reporting obligation applied from October 2025, and the ACM can act on non-conformity. For an operator serving Dutch consumers, the practical point is that the reporting obligation is already in force, not on the horizon.

Sweden: proactive, and telecoms is explicitly named

In Sweden, the PTS, the Post and Telecom Authority, supervises telecoms accessibility through the same systematic inspection programme it applies to e-commerce. Telecoms is named in that programme rather than swept up by it. The PTS also holds market-restriction powers: in the most serious cases it can act to keep a non-compliant service off the market. Its approach is proactive, so an operator does not need a complaint to come under review.

The four requirements, in a telecoms context

Across every market the substance is the same. Four things carry an operator's compliance position:

1. Accessible consumer journeys. Plan selection, sign-up, account management, top-up and billing all operable with a keyboard and a screen reader, meeting EN 301 549 (WCAG 2.1 Level AA).
2. An accessibility statement. Current, EN 301 549-referenced, honest about where conformance is partial, with a real feedback route. It is the public evidence that an assessment happened at all.
3. Accessible support, and the requirements telecoms carries alone. The customer-service and complaints channels themselves reachable by disabled customers, not just the sales journey. Electronic communications also carries obligations no other sector has: Real Time Text alongside voice for person-to-person calls and for calls to emergency services, and the ability for a customer to nominate a third party to deal with complaints or queries on their behalf.
4. Governance and evidence. A dated record that the product has been assessed and is being maintained. This is the basis of the due-diligence defence, and the thing an operator with nothing to show cannot produce.