The short answer
The European Accessibility Act has applied since June 28, 2025. Games themselves are not directly listed, but e-commerce services are, and legal commentary says that covers the steps leading to a consumer purchase. If your game sells to consumers in the EU through a store or purchase flow, that part is likely in scope, even if your company is outside the EU. Very small service providers are exempt. This is not legal advice, so check your situation with a lawyer.
What the EAA is
The EAA is an EU directive that sets accessibility requirements for certain products and services, so disabled people can use them on an equal basis. It applies from June 28, 2025, through national laws in each EU member state. Covered services include e-commerce, banking, e-books and some transport and communication services.
How it touches games
Video games are not named as a covered product or service. However, most games sell something: premium purchases, in-game currency, cosmetics, subscriptions or season passes. Law firms that advise the games industry point out that the e-commerce category is broad, covering all the steps that lead to a consumer transaction. That means store and purchase flows are where games are most likely to be in scope.
| Part of a game business | Likely position under the EAA |
|---|---|
| Core gameplay | Not directly covered |
| Web shop selling to EU consumers | Likely covered as e-commerce |
| In-game store and purchase flow | Possibly covered as e-commerce; get advice |
| Subscription sign-up flows | Likely covered as e-commerce |
| Platform stores (Steam, App Store, Google Play) | Primarily the platform's responsibility |
Who is exempt
Microenterprises providing services are exempt from the service accessibility requirements. Under EU definitions, that means fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million. Many small indie studios fall under this exemption. Larger studios and publishers generally do not.
Does it apply to companies outside the EU?
Yes. Legal commentary notes that the EAA applies to any provider that offers covered services to consumers in the EU, wherever the provider is based. A US or Asian studio selling to EU players through its own web shop should consider it.
What accessible purchasing looks like
- Text that is readable, with enough contrast and scalable size.
- Store screens operable with keyboard, controller and assistive technology, not only precise mouse or touch.
- Clear prices, including currency, taxes and what the player receives.
- Simple steps with clear labels and confirmation before payment.
- Web stores that work with screen readers and follow web accessibility standards.
- Accessible information about the service, as required in your member state.
Beyond compliance: game accessibility
Many accessibility options cost little and widen your audience: subtitles with size and background options, remappable controls, colour-blind friendly palettes, difficulty and assist options, and avoiding information conveyed only by sound or colour. The Game Accessibility Guidelines are a good free checklist. Accessible design also helps players on small screens, in noisy places or with temporary injuries.
Practical steps for a studio
- Map every place your company sells to EU consumers.
- Check whether the microenterprise exemption applies to you.
- Get legal advice on in-game stores and your specific setup.
- Audit store and purchase flows against accessibility requirements.
- Fix the biggest barriers first: text, contrast, navigation, clear pricing.
- Test with disabled players and keep a record of what you changed.
Common barriers in game stores
| Barrier | Fix |
|---|---|
| Tiny text on store screens | Larger base text and a text size option |
| Low contrast prices and buttons | Meet contrast guidance for text and controls |
| Mouse or touch only navigation | Support keyboard and controller focus on every element |
| Unlabelled icons and buttons | Add text labels and accessible names |
| Confusing virtual currency pricing | Show real-money prices and what the player receives |
| Timers that pressure purchases | Avoid countdowns that cannot be paused or extended |
Other rules that overlap
Accessibility is not the only EU rule that touches game stores. Consumer protection authorities have also looked at virtual currencies and in-game purchases, and data protection rules apply to analytics and personalised offers. Clear pricing and honest purchase flows help with all of them at once, which is another reason to treat store accessibility as part of good design rather than a separate checklist.
Documenting what you did
Whatever your legal position, keep a short record of accessibility decisions: which flows you audited, what you changed, how you tested and with whom. It helps if a regulator, platform or customer asks, and it keeps the work from being undone in later updates. Add accessibility checks to your release checklist so store changes are reviewed before they ship.
Getting help
We build accessible UI and purchase flows as part of game and app development, and can audit existing store flows. For EU markets, see our pages for Finland and Poland, and our localization guide.
Sources: EUR-Lex: Directive (EU) 2019/882 · Taylor Wessing: accessibility in the gaming industry · Bird & Bird: navigating the EAA · Game Accessibility Guidelines. Checked October 27, 2026.
Related: Game development for Poland · Game development for Finland · Get a quote
Originally published on A Plus Games Studio, a game, AR and VR development studio in Sacramento, CA.
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