What the EAA Exempts on Your Website: Old PDFs, Videos, Maps and More
Not every old PDF or video on your site needs fixing under the European Accessibility Act. The law does not require you to go back through years of content and make everything accessible. But the exemptions have defined edges, and those edges matter.
The cut-off date is 28 June 2025. That is when Member States had to start applying their national EAA laws, and it is the benchmark Article 2(4) uses. Content published before that date may qualify for an exemption. Content published on or after that date does not. That distinction matters more than most vendor claims suggest.
Here is what the five exemptions actually cover, and where each one runs out.
The Five Exemptions Under Article 2(4)
The EAA lists five types of content outside the scope of its accessibility requirements for websites and mobile applications. They are written into Article 2(4), points (a) through (e).
1. Pre-recorded time-based media published before 28 June 2025
This covers video and audio files — training videos, product demonstrations, promotional clips — that were published before the deadline. A video embedded on your site before 28 June 2025 is not automatically subject to the EAA's accessibility rules.
The limit is the publication date. If you re-upload that video, move it to a new page, or publish any new time-based media after 28 June 2025, the exemption no longer applies. Captions, audio descriptions and transcripts become required for anything new.
2. Office file formats published before 28 June 2025
This is the one shop owners ask about most. PDFs, Word documents, Excel spreadsheets, PowerPoint files and similar office formats that were published on your site before 28 June 2025 are exempt. A product manual uploaded before the deadline, a price list published as a PDF before the deadline, a downloadable terms document from before the deadline — none of these need to be rebuilt to meet the EAA standard.
Again, the date is the boundary. Any office file uploaded or republished after 28 June 2025 falls outside the exemption. If you refresh your terms and republish them as a PDF after the deadline, that new file must be accessible.
3. Online maps and mapping services
This exemption has a specific condition attached. Online maps are exempt if essential information is provided in an accessible digital manner elsewhere. If your store locator uses a visual map but also lists every location with an address and postcode in plain text on the same page, the map itself may be exempt. The key is that users who cannot see the map must still be able to find the information they need through an alternative accessible path.
4. Third-party content
This covers content that is neither funded, nor developed, nor under the control of your company. The most common examples on an e-commerce site are social media posts embedded via widget, customer reviews uploaded by users, and advertising banners or videos served by third-party networks.
If you did not pay for it, did not build it, and do not manage it, it is generally not your responsibility under the EAA exemption. This is similar to the approach taken under the Web Accessibility Directive for public sector bodies, as Recital 46 of the EAA notes.
The limits here are practical. If you commissioned a video from a supplier, paid for a product tour to be produced, or edited and uploaded someone else's content to your site, it is not third-party content under the exemption's definition.
5. Archives
Content that has not been updated or edited since 28 June 2025 qualifies as an archive under the EAA. This means a PDF manual for a product you no longer sell, a press release from before the deadline, a page that sits in an archive section — all may remain exempt as long as they are truly static.
The moment you edit, republish, or refresh any of these files, the clock restarts. An updated copyright year on an old PDF, a corrected link in a historical page — any edit removes the archive exemption and brings the content under the EAA requirements.
What the Exemptions Do Not Cover
Exemptions reduce your workload. They do not remove your obligations for content published after 28 June 2025. The EAA applies to services provided to consumers after that date, and anything new you publish falls squarely in scope.
The exemptions also do not protect you from using overlays or widgets as a shortcut. As we cover in Accessibility overlays and the EAA: why a widget does not make your site compliant, an overlay placed on top of content does not make that content compliant with the EAA.
Under Article 15(1) of the EAA, products and services that conform to harmonised standards whose references have been published in the Official Journal are presumed to conform to the accessibility requirements covered by those standards. The current cited standard is EN 301 549 v3.2.1 (2021), which is based on WCAG 2.1 Level AA. No later version has been formally cited yet. We explain what that means in practice in EAA compliance tools: what automated checks catch, and what they never will.
The Limits of Each Exemption
Each exemption has a clear trigger — the date, the source, or the update history — and crossing that trigger brings the content into scope immediately.
For time-based media and office files, the date is absolute. For maps, the condition is that essential information must be available another way. For third-party content, the line is whether you funded, developed or control the content. For archives, it is whether the content has been edited since 28 June 2025.
These are not vague allowances. They are conditions, and failing to meet them means the content must be made accessible just like any other in-scope content.
What to Do Now
Work through this in order, starting with what matters most to your customers.
1. Audit your pre-deadline content. List the PDFs, videos and documents on your site that were published before 28 June 2025. Note which ones are still actively served to users — a file that receives regular downloads matters more than a page nobody visits.
2. Apply exemptions selectively. Check each piece of content against the five categories. Where an exemption applies, document it. Your accessibility statement should reflect which content falls under Article 2(4) and why.
3. Fix your post-deadline content. Any PDF, video or document you publish or republish after 28 June 2025 must meet the accessibility requirements. Set an internal rule: no new inaccessible file goes up.
4. Check your maps. If you rely on a visual map for essential information — store locations, delivery coverage — make sure that information is also available in a text-based, screen-reader-friendly format. The map itself may be exempt. The data behind it cannot be.
5. Review third-party embeds. Social widgets, review platforms, advertising iframes. If you did not build or fund them, note them as third-party content. If you did, treat them as your own content and apply the same standards.
6. Write it down. The EAA requires an accessibility statement. Listing which exemptions you apply, and why, is part of showing that you have looked at the requirements seriously. It demonstrates the kind of documented approach a regulator or court would expect to see. We cover how to build that statement in EAA accessibility statement: template and real example.
No badge, tool or overlay certifies a site. What the law asks is that you understand the requirements, apply them to what is in scope, and document the decisions you made about what is not.