Why e-learning platforms are squarely inside the EAA — and why "we sell education, not products" does not help
The EAA does not use the word "e-learning" or "online courses." It does not need to. Article 2.2(f) covers "services provided at a distance, through electronic means, at the individual request of a consumer, with a view to concluding a contract." When a learner in Berlin opens your platform, selects a course, enters payment details and clicks "Enrol," every element of that definition is met. Your platform is providing an e-commerce service to a consumer in the EU. The subject matter of the sale — education, fitness coaching, language training, professional certification — does not change the legal classification.
The enforcement implication is concrete. If a German surveillance authority inspects your checkout flow and finds no published Accessibility Statement under Art. 13.2, the non-compliance procedure starts. The authority does not care whether you sell Python tutorials or ceramic cookware. It cares whether your web interface is accessible and whether you have the documentation to prove it.
What the EAA requires from your course platform — four concrete deliverables
Under Article 13.2 of Directive (EU) 2019/882, the provider of a covered e-commerce service must produce and maintain structured accessibility documentation. For an online course platform, this means:
Accessibility Statement
Public, accessible, regularly updated. Must include a feedback mechanism for users. Required by Art. 13.2.
WCAG 2.1 AA evaluation
17 criteria across the 4 principles. Covers your course catalog, checkout, account area, and video player interface.
Remediation plan
Issues identified must be documented with priority and fix instructions. Saying "we know the video player isn't keyboard-navigable" is not enough — you need a plan.
Feedback channel
A public email or form where any user can report accessibility barriers. Required as part of the Statement.
What you receive in your 6-10 page PDF
WCAG 2.1 AA Assessment
17 official criteria evaluated with per-principle scoring and numbered WCAG reference.
Personalised Accessibility Statement
Under Art. 13.2. With your company data, website URL, country of service, contact email. Ready to publish.
HTML footer block
Copy-paste code with Accessibility Statement link, feedback mechanism and competent authority data.
Legal risk analysis
Verified fine ranges per country: Germany up to €100K, Spain up to €1M, France up to €250K, Netherlands up to €900K.
Prioritised remediation plan
Each issue with HIGH/MEDIUM priority and W3C guidance. Send it to your dev team.
Disproportionate burden template
Under Annex VI, for partial exemption claims if specific features cannot be made accessible without fundamental alteration.
Generated in your browser. No data leaves your device.
What it costs to have your accessibility documentation in order
Three accessibility mistakes every e-learning platform makes — and why the EAA catches each one
"Our videos have subtitles, so we're accessible"
Captions are one criterion (WCAG 1.2.2). The EAA evaluates 17 criteria. Can a screen reader navigate your course catalog? Can a keyboard-only user complete checkout? Is your progress dashboard operable without a mouse? Captions solve perceivability for one media type. They do not solve operability, understandability, or robustness across your entire platform.
"We use Teachable / Thinkific / Moodle — they handle accessibility"
Your LMS provides infrastructure, but you are the service provider under the EAA. Custom themes, third-party plugins, embedded widgets, checkout modifications, and marketing popups are your responsibility. The Accessibility Statement is signed by you, not by your LMS vendor.
"We'll make new courses accessible and leave the old catalog as is"
Pre-recorded content published before 28 June 2025 has a transition period until 2030. But your platform interface — catalog navigation, checkout, account settings, the video player itself — has no transition period. The interface must be accessible now. The content transition applies to the media files, not to the web application that plays them.
Enforcement is live — and B2B institutional buyers are asking too
Market surveillance authorities have started inspections across the EU. But for e-learning platforms, the first pressure often comes from B2B customers, not from regulators. European universities, corporate training departments and public sector agencies are now including EAA accessibility requirements in procurement specifications. Without a structured Accessibility Report, your platform does not qualify.
BFSG. Up to €100,000 per individual infringement. BFIT-Bund as surveillance authority.
Ordonnance 2023-859. Tribunal Judiciaire de Paris admitted EAA lawsuits against 4 supermarket chains in November 2025.
Implementatiewet. Up to €900,000 or 1-10% of annual turnover. ACM actively auditing banking and telecom since spring 2026.
Law 11/2023 + subsidiary regime RDL 1/2013. Minor up to €30K, serious up to €90K, very serious up to €1M. Repeat offences: operating ban up to 2 years.
What EAA-Report guarantees and what it doesn't
EAA-Report generates a document structured under Art. 13.2 of Directive (EU) 2019/882 based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as service provider.
We guarantee that the document structure follows Art. 13.2 of Directive (EU) 2019/882 and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.
EAA-Report is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Frequently asked questions — E-learning platforms
Is an online course platform an "e-commerce service" under the EAA?
We are based outside the EU. Does the EAA still apply?
Do we need to make all existing course videos accessible by June 2025?
Our LMS provider says they are WCAG compliant. Is that enough?
Is my data safe with EAA-Report?
Is EAA-Report legal advice?
⚠️ Important notice: EAA-Report is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. EAA-Report does not replace a qualified professional assessment.
Official legal sources
- Directive (EU) 2019/882 — European Accessibility Act — full text