Your ticketing app is covered by the EAA under both Art. 2.2(c) — digital elements of passenger transport services (electronic tickets, ticketing services, real-time travel information) — and Art. 2.2(f) — e-commerce services selling to consumers. This means there is no argument that the app falls outside scope.
Why transport ticketing apps have zero room for scope arguments
The EAA's coverage of passenger transport (Art. 2.2.c) explicitly includes websites, mobile applications, electronic tickets, electronic ticketing services and delivery of real-time travel information. Urban, suburban and regional transport services have a narrower scope — only the digital elements are covered, not the physical vehicles. But for your app, this distinction is irrelevant: the digital layer is exactly what you build.
On top of that, Art. 2.2(f) covers any service that sells goods or services to consumers through electronic means. A ticketing app that sells train, bus, ferry or flight tickets online to consumers is e-commerce by definition. Two independent legal bases, one software product, one report.
What the EAA requires from a transport ticketing app
Ticket purchase flow
The entire booking journey must be keyboard-navigable and screen-reader compatible. From search to seat selection to payment to e-ticket delivery.
Real-time information
Live departure boards, delays and platform changes must be accessible. Art. 2.2(c) explicitly includes real-time travel information.
E-ticket accessibility
QR codes, barcodes, PDF tickets — the e-ticket must provide text alternatives for all critical data (departure, seat, gate).
Error handling in multi-step transactions
Booking errors must be identified, described and reversible. WCAG 3.3.1, 3.3.3 and 3.3.4 all apply to ticket purchases.
What you deliver to your operator client
Cover page
Global compliance score, verification reference, date of assessment.
Service identification and evaluation scope
Software product, deployment context, evaluation method, applicable legal framework.
Criterion-by-criterion evaluation
17 WCAG 2.1 AA criteria evaluated across four principles: Perceivable, Operable, Understandable, Robust.
W3C remediation guidance
Actionable fixes per failed criterion from W3C Understanding WCAG 2.1.
Accessibility statement
Structured declaration following Annex V of Directive 2019/882.
Legal basis and scope disclaimer
Cites Directive 2019/882, EN 301 549 V3.2.1 and applicable national transposition law.
Generated in your browser.
What it costs
Three common mistakes
Misreading the urban/suburban exclusion
Art. 2.2(c) narrows the scope for urban transport — but only for the physical service. The digital elements (apps, e-tickets, real-time info) are explicitly included for ALL transport. And Art. 2.2(f) catches the app as e-commerce regardless. No exemption for ticketing apps.
Visual-only seat selectors with no keyboard alternative
Seat maps built with canvas elements or SVG without ARIA roles are invisible to screen readers and inoperable via keyboard. WCAG 2.1.1 and 4.1.2 require a keyboard-navigable, programmatically exposed alternative.
E-tickets generated as flat images inside a PDF wrapper
If your e-ticket is a rasterised image with a QR code and no selectable text for departure time, seat, gate or passenger name, it fails WCAG 1.1.1.
Enforcement
BFSG. Up to €100,000 per individual infringement.
Law 11/2023. Very serious infractions from €90,001.
Ordonnance 2023-859.
Implementatiewet. Up to €900,000 or 1-10% of annual turnover.
These fines apply to the transport operator. Your exposure is contractual — but vendor replacement is the real consequence.
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 the service provider or software vendor.
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 — transport ticketing app developers
My app serves urban bus routes. Is it exempt?
Does this report cover both Art. 2.2(c) and Art. 2.2(f)?
I build the app but the operator runs it. Who is responsible?
Does the report cover the physical ticket machine?
How long does it take?
Is this a certified audit?
⚠️ 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