Compliance reference
EAA captions requirements: what the European Accessibility Act means for training video
The European Accessibility Act (Directive 2019/882) became enforceable on June 28, 2025. If you sell software, e-books, e-commerce, or online courses into the EU, the EAA applies. Here is what it says specifically about captions on audiovisual content, who is in scope, and the SMB exemption most non-EU teams don't know about.
TL;DR
The EAA references the harmonized European standard EN 301 549, which in turn incorporates WCAG 2.1 Level AA for web and mobile content. For training video and other audiovisual content, that means synchronized captions (SC 1.2.2), live captions (SC 1.2.4), and audio description (SC 1.2.5). The EAA also has a microenterprise exemption (< 10 employees, turnover or balance sheet < €2M), so a surprising share of EU SaaS and training companies are technically out of scope. Most mid-market training-content businesses are not.
What the EAA actually is
The European Accessibility Act is an EU directive — meaning each EU member state implemented it as local law by the June 28, 2025 transposition deadline. The harmonized technical standard the Act references is ETSI EN 301 549, which itself references WCAG 2.1 AA for the web and mobile portions. Video captions sit under EN 301 549 clause 7 (audiovisual services) and pick up WCAG's timed-media criteria by reference.
Unlike the ADA — which is U.S. civil rights law enforced via DOJ investigation and private lawsuit — the EAA is an EU single-market directive. Enforcement happens at the member-state level through national market surveillance authorities, typically the same agencies that handle product-safety compliance.
Who is in scope
The EAA covers "products and services placed on the EU market." For digital services relevant to training video, that specifically includes:
- E-commerce services — most LMS providers selling to the EU fall here.
- E-book and e-reader services.
- Audiovisual media services — the category that captures training video platforms and course content.
- Consumer-banking, transport-ticketing, and communication services.
- Terminals, kiosks, payment terminals, and ATMs.
Scope determination is by service offering, not company headquarters. A U.S.-based LMS that sells subscriptions into the EU is in scope. An EU-based training content provider is in scope regardless of customer location.
The microenterprise exemption
The EAA exempts microenterprises providing services: fewer than 10 employees, and either annual turnover or annual balance sheet total under €2 million. The exemption is per-entity — a microenterprise subsidiary of a larger group does not qualify. If your training-content business sits above that threshold (most do by the time they're considering dedicated captioning tooling), the EAA applies in full.
Member states are also allowed to grant "disproportionate burden" exemptions case-by-case, but this requires formal documentation and is audited. It is not a DIY workaround.
What's required for video captions under EAA
Because EAA incorporates WCAG 2.1 AA by reference (via EN 301 549), the caption requirements for training video are identical to the ADA Title II requirements — see our ADA Title II captions reference for the detail walk-through. In short:
- Synchronized captions on every prerecorded video with audio (SC 1.2.2).
- Live captions on live-streamed content (SC 1.2.4).
- Audio description on video where visual content isn't redundant with audio (SC 1.2.5).
- Reading-level and synchronization per the WCAG technique documents — typically ≤160 wpm, within ≈500 ms sync.
Member-state implementations occasionally add language-specific guidance (for example, some national standards reference the European Broadcasting Union's EBU-TT-D format), but the substantive requirements track back to WCAG.
How GlossCap helps
GlossCap's export formats — SRT, WebVTT, TTML — cover the formats EU LMS vendors accept. For EBU-TT-D specifically (a broadcast-style format used in some public-service media contexts), the TTML export is a reasonable starting point and can be post-processed. The glossary-bias mechanism is language-agnostic in architecture, though v1 is English-language first; if your EU training content is multilingual, that is a roadmap conversation rather than a v1 conversation. For the regulatory framing behind the product, the launch essay walks through both ADA Title II and the EAA as co-drivers.
Related questions
Our company is based in the U.S. — does the EAA apply?
If you sell services to EU customers, yes. Jurisdiction is by service offering, not company headquarters. The EAA applies to services "placed on the EU market," which includes subscription software, e-commerce, and audiovisual media services sold to EU users.
What's the penalty under the EAA?
Penalties are set by each member state's transposition of the directive. They range from administrative fines to service-withdrawal orders. Germany and France have published fine schedules; most other member states use a "dissuasive, proportionate" standard without a fixed schedule. Enforcement is market-surveillance-driven, so a complaint or a competitor's filing is usually what opens an investigation.
Does the EAA require translation of captions into multiple EU languages?
No. The EAA requires captions in the language the content is delivered in. It does not mandate multi-language caption tracks. That is a commercial decision, not a compliance one — though some member states have additional language requirements for public-service broadcasting.