Does the European Accessibility Act apply to travel and transport websites?

Yes, for air, bus, rail and waterborne passenger transport services provided to consumers. Article 2(2)(c) of Directive (EU) 2019/882 lists their websites, mobile device-based services, electronic tickets, transport service information and interactive self-service terminals as covered elements, and the Directive applies to such services provided after 28 June 2025.

“the following elements of air, bus, rail and waterborne passenger transport services, except for urban, suburban and regional transport services for which only the elements under point (v) apply: (i) websites; (ii) mobile device-based services including mobile applications; (iii) electronic tickets and electronic ticketing services; (iv) delivery of transport service information, including real-time travel information […]; and (v) interactive self-service terminals located within the territory of the Union […]” (Art. 2(2)(c), Directive (EU) 2019/882, ellipses ours)

Each Member State turns the Directive into a national act, and an authority enforces that act. In Germany, § 1 Abs. 3 Nr. 2 BFSG uses the same list.

Which transport services are covered, and which are carved out?

Four modes are named: air, bus, rail and waterborne passenger transport. Urban, suburban and regional transport services are carved out of everything except the self-service terminal element (Art. 2(2)(c) and Art. 4(3)).

The Directive defines the four modes by pointing to EU passenger-rights regulations: air by Regulation (EC) No 1107/2006, bus by Regulation (EU) No 181/2011, rail by Regulation (EC) No 1371/2007 and waterborne by Regulation (EU) No 1177/2010 (Art. 3(31) to (34)). Rail and waterborne services that their own regulation excludes are outside this list as well. We have not checked which services each regulation covers. Regulation (EC) No 1371/2007 on rail was repealed with effect from 7 June 2023 by Regulation (EU) 2021/782. Under Art. 40 of that Regulation, references to the old one are read as references to Regulation (EU) 2021/782. Article 2(1) of that Regulation covers rail journeys and services provided by railway undertakings licensed under Directive 2012/34/EU, which is the same licensing test the old Article 2(1) and (2) used. Exemptions a Member State grants under Article 2 of the new Regulation concern passenger rights; whether they also narrow the Directive is not settled, so ask a lawyer if your service has one.

Urban and suburban transport services and regional transport services are defined for this Directive as covering only rail, bus and coach, metro, tram and trolley bus (Art. 3(35) and (36)). For them, Annex I Section IV(d) asks only for accessible self-service terminals used in providing the service. A metro operator’s website, app and e-ticket are therefore not among the elements named in Art. 2(2)(c). Two other routes remain. Recital 35 says the Directive makes e-commerce websites accessible, so an operator that sells tickets online may be an e-commerce service (Art. 2(2)(f) and 3(30)). The same recital notes that Directive (EU) 2016/2102 already covers public sector bodies providing transport services.

The list covers passenger transport services only. It does not name car hire, taxis, ride hailing, hotels or package tours. A travel agent or booking platform that sells tickets or trips to consumers at a distance may be an e-commerce service under Art. 2(2)(f) and Art. 3(30). Whether a particular business is in scope is a legal question for that business.

Which digital surfaces count?

Five elements count: websites, mobile device-based services including apps, electronic tickets and ticketing services, transport service information including real-time travel information, and interactive self-service terminals. For each one, check the exact wording in Art. 2(2)(c).

  • Booking website and app. A booking runs through the website or app from search to confirmation, so the whole path belongs to the check.
  • E-tickets and e-ticketing. The ticket itself and the service that issues it are named, so a file the passenger must open on the day of travel is part of the check.
  • Real-time travel information. Annex I Section IV(c) points to timetables, information about traffic disruptions, connecting services, onwards travel with other modes, staffing of stations and lifts that are out of order. On information screens, the Directive is limited to interactive screens located within the Union.
  • Self-service terminals. Ticketing machines and check-in machines are products under Art. 2(1)(b) when placed on the market, and terminals used to provide the transport service are an element under Art. 2(2)(c)(v). Terminals installed as integrated parts of vehicles, aircraft, ships or rolling stock are excluded.

Article 2(4) takes the following website and app content out of scope (points (a) to (e)):

  • pre-recorded time-based media published before 28 June 2025;
  • office file formats published before 28 June 2025;
  • online maps and mapping services, if essential information for maps intended for navigation is provided in an accessible digital manner;
  • third-party content that is neither funded, developed nor controlled by you;
  • archives, meaning content not updated or edited after 28 June 2025.

Read Art. 2(4) before treating an embedded booking engine or map as third-party content.

Does the micro-enterprise exemption apply to a transport or travel provider?

Yes, for services, if you meet the microenterprise test. Microenterprises providing services are exempt from the accessibility requirements for services (Art. 4(5)), and a microenterprise employs fewer than 10 persons and has an annual turnover of no more than EUR 2 million or an annual balance sheet total of no more than EUR 2 million (Art. 3(23)).

The test has two parts: headcount below 10, and turnover or balance sheet at or below EUR 2 million. The exemption covers services only; there is no exemption for products.

A small bus operator with six employees and EUR 1.5 million in turnover would meet the test on those numbers. How staff and turnover are counted for a company that belongs to a group is a question for your lawyer. Article 4(6) of the Directive asks Member States to provide guidelines and tools for microenterprises.

What does the Directive ask a transport provider to publish?

You publish information on how the service meets the accessibility requirements (Art. 13(2), Annex V). Annex V puts it in the general terms and conditions or an equivalent document, and Art. 13(2) asks for it to be public in written and oral format. An accessibility statement on your site is one way to publish it.

The information covers a general description of the service in accessible formats, the explanations needed to understand its operation, and a description of how the relevant Annex I requirements are met. Where the service does not meet the requirements, Art. 13(4) asks for corrective measures and for notice to the competent national authorities.

Services that meet the requirements on accessible information and on information on accessibility in Regulations (EC) No 261/2004, 1107/2006, 1371/2007, (EU) No 1177/2010 and 181/2011, and in acts adopted under Directive 2008/57/EC, are deemed to meet the corresponding Directive requirements (Art. 5). Where the Directive adds requirements, those apply in full.

What should a travel or transport business check first?

Start with scope, then list your digital surfaces, then test the path a passenger takes from search to ticket.

  1. Scope. Which mode do you operate, is it urban, suburban or regional, do you sell to consumers, and are you under the microenterprise limits?
  2. Inventory. List every website, app, e-ticket format, real-time information page and self-service terminal that you provide or control.
  3. Booking path by keyboard. Search, date selection, seat or fare choice, passenger details and payment without a mouse.
  4. Disruption and timetable information. Can a screen reader user find a cancellation or a platform change as easily as a sighted user?
  5. The ticket. Is the e-ticket readable by a screen reader, and does it work without scanning a visual-only code?
  6. Third-party parts. Payment pages, booking engines and maps: decide whether Art. 2(4)(d) applies or whether you control the part.
  7. The information. Is the Annex V information written, public and kept up to date?

What can automated testing show on a booking site, and what can it not?

Automated testing can flag missing text alternatives, unlabelled form fields, low contrast and many markup errors on the pages it reaches. It catches roughly 30 to 40 percent of WCAG success criteria, not 30 to 40 percent of a site’s failures, and the rest needs a person.

A scan cannot tell you whether a date picker works from the keyboard from start to finish, whether a seat map makes sense to a screen reader user, whether a payment error is announced, or whether a live departure board announces a change. It cannot read an e-ticket you receive after payment. A crawl covers the pages it can reach by following links; a booking in progress and pages behind a login need a manual test.

An Inkluso grade of 100 means nothing automated was found. It does not mean the site is accessible.

How does Inkluso help?

Inkluso checks the pages a scanner can reach, maps each finding to a standard and a law, and drafts the accessibility statement for you to review. It does not decide which national act binds you, and it does not test a booking you are in the middle of.

  • Free scan. The homepage against WCAG 2.1 AA with axe-core, no account and no card.
  • One-time audit. EUR 149, up to 100 pages. Each finding carries the WCAG criterion, the EN 301 549 clause and the paragraph of the national act you choose, with a fix block and a PDF that has a timestamp, the engine version and a SHA-256 hash. The audit includes a short keyboard walk on up to three pages, kept out of the grade.
  • Accessibility statement draft. A draft of the Annex V information, for you to review and complete before you publish it.

EN 301 549 is the technical yardstick used here. No version of it is cited in the Official Journal under Directive (EU) 2019/882, so it gives no presumption of conformity under Art. 15(1). An Inkluso report is not a certification.

Which national law do I read for my transport website?

Start with the national act of each country where you offer your service to consumers, not with the language of your site. A transport business selling to consumers in Austria starts with the Austrian BaFG, one selling in Germany with the German BFSG, and one selling in both checks both.

For a cross-border case, ask a lawyer which acts bind you. For the German BFSG paragraphs on scope, information duty and microenterprises, see the German version of this guide.

FAQ

Does the European Accessibility Act apply to travel and transport websites?

Yes, for air, bus, rail and waterborne passenger transport services provided to consumers. Article 2(2)(c) of Directive (EU) 2019/882 names websites, mobile apps, e-tickets, transport service information including real-time travel information, and self-service terminals.

Are urban, suburban and regional transport operators covered?

Only in part. Art. 2(2)(c) covers only interactive self-service terminals for urban, suburban and regional transport services, and their websites and apps are not among the named elements. An operator that sells tickets online may still be an e-commerce service, and recital 35 notes that Directive (EU) 2016/2102 already covers the websites of public sector bodies providing transport services.

Is a very small transport or travel company exempt?

A microenterprise providing services is exempt from the service requirements (Art. 4(5)). A microenterprise employs fewer than 10 persons and has turnover or balance sheet of no more than EUR 2 million (Art. 3(23)).

What can an automated scan show on a booking site?

It can flag markup problems on pages it reaches. Automated testing catches roughly 30 to 40 percent of WCAG success criteria, so keyboard use of the booking path, announcements and the e-ticket need a human check.

Sources

Where does your booking site stand?

The free scan tests the homepage against WCAG 2.1 AA with axe-core and shows the first findings with the matching reference. No signup, no card.

Run the free check

Related: EAA scope guide · Accessibility statement generator · Is WAVE enough for the EAA? · Other sectors: Online shops · Ticketing websites · Banks and fintechs

Orientation, not legal advice. Automated testing catches roughly 30 to 40 percent of WCAG success criteria. The rest needs a human.