The European Accessibility Act (EAA) has been in force since June 28, 2025, and the landscape has shifted dramatically. What was once a looming deadline is now the reality for businesses operating in or selling into the EU market. Seven months into enforcement, we’re seeing a clearer picture of what compliance actually means and what happens when organizations fall short.
What Is the European Accessibility Act?
The EAA (Directive 2019/882) is EU legislation that mandates accessibility requirements for a wide range of products and services across all 27 member states. Its goal is straightforward: to ensure that people with disabilities have equal access to essential products and services while harmonizing accessibility requirements across Europe.
The Act affects far more than you might expect. E-commerce platforms, banking services, smartphones, computers, e-readers, ticketing systems, ATMs, telecommunications services, passenger transport, audiovisual media, and e-books all fall under its scope. If your business provides any of these products or services to EU consumers, the EAA applies to you, regardless of where your company is based.
Who Does It Impact?
The EAA applies to any organization selling products or services to consumers in the EU, whether or not it is located in the EU. If you operate an e-commerce site accessible to EU customers, you’re in scope. If you provide digital services to European clients, you need to comply.
The only exemptions are:
- Microenterprises with fewer than 10 employees and annual revenue under €2 million
- Cases where compliance would impose a disproportionate burden (though this requires detailed documentation and can be challenged by authorities)
- Legacy content published before June 28, 2025, that remains unchanged (though updates after this date must meet requirements)
For existing services and certain equipment, such as self-service terminals, transitional provisions exist to extend compliance deadlines to June 28, 2030, or up to 20 years for some hardware already in use.
The Technical Foundation: EN 301 549 and WCAG
The EAA’s accessibility requirements are based on EN 301 549, the European standard aligned with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. The standard is currently being updated to include WCAG 2.2.
This means your digital products and services need to be:
- Perceivable: Content must be presentable in ways users can perceive (alt text for images, adequate color contrast, text alternatives for non-text content)
- Operable: Users must be able to navigate using keyboard, assistive technologies, and other input methods
- Understandable: Information and interface operation must be clear and predictable
- Robust: Content must work reliably across different technologies and assistive tools
But achieving EN 301 549 conformance alone isn’t enough. National laws implementing the EAA have additional requirements, particularly around accessibility statements, ongoing monitoring, employee training, and establishing procedures for maintaining compliance.
What Enforcement Actually Looks Like
Each EU member state enforces the EAA through national legislation, and penalties vary significantly by country:
- Germany: Fines up to €100,000 per violation, with authorities able to order product recalls or service withdrawals
- France: Up to €75,000 or 4% of annual revenue
- Sweden: Maximum fines of €900,000
- Ireland: Up to €60,000 and/or 18 months imprisonment
- Belgium: Up to €200,000 per violation, with business suspension for repeat offenses
- Italy: €5,000 to €40,000, or up to 5% of annual turnover for severe cases
Beyond fines, the real risk is market access. National surveillance authorities can remove non-compliant products from the market and suspend a company’s right to do business in their jurisdiction. Enforcement mechanisms are now active across all member states.
Current Compliance Reality
Recent research reveals a troubling and significant gap between awareness and action. Among those who claim to be prepared, many haven’t actually integrated accessibility into their core development processes. They’re retrofitting rather than building accessibility in from the start.
This reactive approach is costly and unsustainable. Organizations that treat the EAA as a checkbox exercise rather than a fundamental shift in how they build products and services will struggle with ongoing compliance and face higher long-term costs.
The Third-Party Trap
One of the biggest misconceptions is that third-party content falls outside EAA scope. It doesn’t. All website plugins, widgets, chatbots, embedded maps, payment processors, and other third-party tools must meet accessibility requirements. You’re responsible for the accessibility of your entire digital experience, regardless of who built which components.
Smart organizations are now making accessibility a non-negotiable requirement in their procurement processes, asking vendors for documented proof of compliance before integrating any third-party tools or services.
Where to Start: A Practical Implementation Path
If you’re behind on compliance, here’s how to begin:
1. Conduct a Comprehensive Assessment
Use both automated testing tools and manual evaluation to understand where you stand. Automated tools catch obvious issues like missing alt text, insufficient color contrast, and broken ARIA labels. Manual testing reveals real-world navigation problems that automated tools miss: issues with keyboard navigation, screen reader compatibility, and logical content structure.
Don’t just test your main website. Assess all digital touchpoints: mobile apps, customer portals, PDFs, web-based tools, and any self-service systems.
2. Prioritize Strategically
Not all barriers are equal. Focus first on issues that completely block access to essential content or functionality. A checkout process that’s inaccessible to keyboard-only users? That’s a critical barrier. A decorative image missing alt text? Less urgent.
Start with WCAG Level A and AA violations. Group similar fixes together for efficiency. If you have multiple forms with the same accessibility problems, fixing the pattern once and applying it across the board is more efficient than addressing each instance individually.
3. Create an Accessibility Statement
Businesses subject to the EAA are required to publish an accessibility statement explaining:
- How your products or services meet accessibility requirements
- Contact information for users to report accessibility issues
- Information about any exemptions claimed
- Details of your accessibility features and how to use them
This statement must be available in the languages in which you provide services. If you serve customers in Germany, France, and Spain, you need statements in German, French, and Spanish.
4. Embed Accessibility Into Your Process
This is where most organizations fail. They audit, remediate, and then continue building new features the same way they always have: creating new accessibility issues as fast as they fix old ones.
Train your entire team on accessibility principles. Developers need to understand semantic HTML and ARIA. Designers need to know about color contrast and touch target sizes. Content creators need to write accessible copy and provide proper alt text. Product managers need to include accessibility requirements in feature specifications.
Make accessibility testing part of your definition of done. No feature ships until it passes accessibility checks. Establish accessibility guidelines and code-review processes to catch issues before they reach production.
5. Maintain Ongoing Compliance
The EAA isn’t a one-time project. Implement regular audits for high-traffic or frequently updated properties. Integrate accessibility checks into your release cycles. Create clear channels for users to report accessibility issues and respond to them promptly.
Monitor changes in standards and enforcement. EN 301 549 will be updated to include WCAG 2.2, and you’ll need to adjust accordingly.
The Business Case Beyond Compliance
While avoiding fines and market exclusion is motivation enough, forward-thinking organizations see the EAA as an opportunity. The EU has approximately 101 million people with disabilities, that’s one in four people over 16. These aren’t just potential customers; they’re currently underserved customers.
Many leading e-commerce sites in Germany and major brand websites in Ireland continue to have accessibility barriers. The businesses that fix this first gain a competitive advantage. They’re not merely avoiding penalties; they’re capturing market share.
Accessible design also benefits everyone. Clear navigation helps people in a hurry. Good color contrast helps users viewing content in bright sunlight. Keyboard accessibility helps power users who prefer keyboard shortcuts. Captions benefit people watching videos in quiet offices or noisy environments. When you design for disability, you improve the experience for all users.
The Path Forward
The EAA represents a fundamental shift in how digital products and services must be built. Seven months into enforcement, the message is clear: accessibility is no longer optional for businesses operating in the European market.
Organizations that approach this as a creative opportunity and a chance to build better products for a wider audience will come out ahead. Those who treat it as a burden to be minimized will struggle with ongoing compliance costs, potential penalties, and lost market opportunities.
The foundation is in place. The enforcement mechanisms are active. The question now isn’t whether to comply, but how quickly you can adapt your product development approach to meet this new standard. The organizations writing the next chapter of digital inclusion are those building accessibility into everything they create from day one.
Need help getting started with EAA compliance? Our team can assess your current state, identify gaps, and create a practical roadmap for achieving and maintaining compliance. Don’t hesitate to reach out.
