Many organizations operating in Europe assume that the European Accessibility Act (Directive (EU) 2019/882) applies only to consumer-facing software. This interpretation, while partially accurate, is incomplete and potentially risky. Internal B2B systems, especially those used by employees or sold to public sector clients, may fall under national accessibility obligations that go beyond the baseline set by the EAA.

Understanding the legal landscape requires reviewing not just the directive itself, but the specific national implementations across EU Member States. Failure to do so may result in non-compliance, particularly for vendors building HR, payroll, training, or operational systems for enterprise and government clients.

The Scope of the European Accessibility Act

The European Accessibility Act (EAA) was adopted in 2019 to improve the accessibility of a wide range of products and services across the EU. The directive primarily targets services and products intended for consumers, including e-commerce, banking, e-books, and public transportation systems. The law applies to services placed on the market after June 28, 2025. The full directive text is available via EUR-Lex: Directive (EU) 2019/882

Recital 11 of the directive clarifies that it “should not apply to products and services provided by public sector bodies only to persons acting in a professional capacity.” This has led to the common belief that internal-use platforms are exempt. However, this exemption applies only to the directive at the EU level. The actual legal obligations can vary by country and may extend further. There may also be other existing laws that cover the B2B case.

National Laws That Extend Accessibility Obligations to Internal B2B Systems

France

France’s accessibility legislation goes significantly beyond the EAA. Loi n° 2005-102 du 11 février 2005 imposes accessibility obligations on both public and private entities. Notably, Article 47 requires that large private sector organizations – defined as those with annual revenues exceeding €250 million – make their digital services accessible, including intranet systems used by employees. The law is enforceable and applies to internal-use tools, not just public websites. (Full law text: Loi n° 2005-102 – Article 47)

Italy

Italy’s accessibility legislation also predates and exceeds the EAA in some areas. Law No. 4/2004, known as the Legge Stanca, applies to both public administrations and private entities that supply ICT services to them. It mandates conformance with the EN 301 549 standard, the EU’s harmonized technical specification for digital accessibility. Internal systems used by employees or systems developed for the public sector must meet accessibility criteria. (Consolidated text: Legge 4/2004 (IT))

Spain

Spain implemented the Web Accessibility Directive (2016/2102) through Royal Decree 1112/2018, which applies to public sector websites and mobile apps. However, it also extends to certain private sector entities, particularly where services are considered of general interest or where public funding is involved. Systems developed for or used by public entities—including internal platforms—are within scope. (Full text: Real Decreto 1112/2018)

Germany

Germany’s implementation of the EAA is the Barrierefreiheitsstärkungsgesetz (BFSG), enacted in July 2021. This law mirrors the scope of the directive, applying only to consumer-facing products and services. Internal-use software sold exclusively to businesses and not used by consumers is not directly subject to the BFSG. (Full law text: BFSG (DE))

However, Germany also has the Behindertengleichstellungsgesetz (BGG), which governs accessibility in public sector institutions. Section 12a mandates that IT systems used by federal public bodies must be accessible, which includes internal tools procured by those institutions. (§12a BGG (Accessible IT): BGG §12a)

Netherlands

The Netherlands enforces digital accessibility through the Tijdelijk besluit digitale toegankelijkheid overheid, which applies to all public sector bodies. It mandates compliance with EN 301 549 for websites and mobile applications. While the law does not explicitly extend to private internal-use software, vendors serving public clients are required to meet these standards. (Official text: Dutch Accessibility Decree)

Sweden

Sweden’s DOS-lagen (2018:1937) implements the Web Accessibility Directive and governs digital services provided by public bodies. While it does not directly regulate internal private-sector platforms, any organization providing digital services to public institutions is expected to comply with accessibility requirements.

Implications for B2B Software Vendors

In jurisdictions like France and Italy, internal systems are clearly within the legal scope. Even in countries where the EAA was implemented narrowly, other national laws – some of which pre-dating EAA – may impose accessibility obligations indirectly through public sector procurement rules, employee non-discrimination laws, or general principles of equal access in the workplace.

Software vendors who develop B2B platforms should assume that accessibility is a non-optional requirement when working with:

  • Government agencies or contractors
  • Public sector entities at the municipal, regional, or national level
  • Large enterprise clients subject to national accessibility laws

Compliance with EN 301 549 is increasingly treated as a baseline, not just in procurement frameworks but also in internal IT policy enforcement.

Risk of Non-Compliance

Failure to meet applicable national requirements may lead to contract termination, fines, or litigation—particularly in countries where accessibility laws are enforceable by administrative bodies or where individual complaints can trigger investigation. It also jeopardizes future eligibility for procurement contracts or partnership opportunities.

More broadly, disregarding accessibility considerations in internal platforms undermines equity in the workplace and may expose employers to liability under employment non-discrimination laws such as Directive 2000/78/EC, which prohibits discrimination on the basis of disability in the context of employment and occupation.

Recommendations

To ensure compliance and avoid costly remediation or reputational risk, organizations should:

  1. Identify applicable accessibility regulations based on the jurisdictions you operate in and the sectors you serve.
  2. Implement accessibility testing throughout the software development lifecycle, using both automated tools and expert manual review.
  3. Use EN 301 549 as the guiding technical standard, especially for systems sold to or used by public bodies.
  4. Maintain documentation of accessibility audits, exceptions, and remediation timelines to demonstrate due diligence in case of regulatory inquiry.

The assumption that the European Accessibility Act applies only to public-facing systems is inaccurate and insufficient. National laws in France, Italy, Spain, and other EU countries clearly demonstrate that internal B2B systems—particularly those used by employees or public clients—are within scope for accessibility obligations. Vendors and enterprise buyers alike must adopt a proactive, standards-driven approach to accessibility, not only to comply with current laws but to meet the growing demand for inclusive and equitable digital tools.