European Accessibility Act (EAA): What EU Businesses Must Know

On June 28, 2025, the European Accessibility Act (EAA) went into full effect across the European Union. Unlike the United States—where accessibility requirements started with government entities—the EAA applies directly to private businesses from day one.

If you operate in the EU or sell to EU customers, this law fundamentally changes how you must design your digital products and services.

Here's what you need to know.

What Is the European Accessibility Act?

The EAA (Directive 2019/882) is EU-wide legislation requiring specific products and services to be accessible to people with disabilities.

Key dates:

June 2019: EAA adopted by EU Parliament
June 2022: Member states required to transpose into national law
June 28, 2025: Compliance deadline (enforcement began)

Unlike the ADA in the United States (which relies on lawsuits to enforce), the EAA is regulatory law with government enforcement and fines.

Who Must Comply: Covered Businesses

The EAA applies to businesses providing these products and services:

Digital Services (Primary Focus)

E-commerce platforms
- Online stores selling physical goods
- Marketplace platforms (Amazon-style)
- Shopping cart and checkout processes
Banking and financial services
- Online banking portals
- Payment apps and services
- Credit card applications
- Investment platforms
E-books and readers
- Digital book platforms
- E-reader apps
- Audiobook services
Media and streaming
- Video-on-demand services
- Streaming platforms (Netflix-style)
- Podcast platforms
Transportation services
- Airline booking sites
- Train ticket platforms
- Ride-sharing apps
- Public transit information systems
Telecommunications
- VoIP services (Skype, WhatsApp calls)
- Video calling platforms
- Messaging apps with critical functions

Physical Products (Secondary Coverage)

Computers and operating systems
Smartphones and tablets
ATMs and ticketing machines
Payment terminals
E-readers

Business Size: Who Gets a Pass?

The EAA includes a microenterprise exemption:

Exempt: Companies with fewer than 10 employees AND annual turnover/balance sheet below €2 million

Not exempt: Everyone else, including:

Small businesses (10+ employees)
Medium businesses
Large corporations
Public sector entities

Important: Even if exempt, you may still need to comply if you want to participate in public procurement or government contracts.

What "Accessible" Means: Technical Requirements

The EAA requires compliance with EN 301 549, the European standard for digital accessibility. This closely aligns with WCAG 2.1 Level AA.

Core Requirements

1. Perceivable Information

Text alternatives for all images and non-text content
Captions for video content
Audio descriptions for visual information in videos
Color contrast of at least 4.5:1 for normal text
Resizable text without loss of functionality

2. Operable Interface

Keyboard accessibility for all functions
No keyboard traps (users can navigate away from any element)
Adequate time to complete tasks (or ability to extend)
No seizure-inducing content (no flashing more than 3 times per second)
Clear focus indicators for keyboard navigation

3. Understandable Content

Language identified in HTML
Consistent navigation across pages
Input assistance for forms (labels, error messages, suggestions)
Error prevention for legal/financial transactions

4. Robust Implementation

Valid HTML that assistive technologies can parse
Proper ARIA labels and roles
Compatible with current and future assistive tools

How the EAA Differs from US Accessibility Law

Aspect	European Accessibility Act	US (ADA)
Scope	Private businesses from day one	Started with government (Section 508), expanding to private
Enforcement	Government regulators	Primarily lawsuits (DOJ for government)
Penalties	Fines determined by member states	Lawsuit settlements ($10k-$100k typical)
Standards	EN 301 549 (≈ WCAG 2.1 AA)	WCAG 2.1 Level AA (as of 2026)
Exemptions	Microenterprises only	No size-based exemption
Deadline	June 28, 2025 (uniform)	Varies by entity type (gov't 2026/2027)

The big difference: The EAA is proactive regulation, not reactive litigation. You don't wait for a lawsuit—regulators will check compliance.

Enforcement and Penalties

Each EU member state enforces the EAA through designated national authorities. Penalties vary but typically include:

Germany

Fines up to €100,000 per violation
Stop-sale orders for non-compliant products
Public disclosure of violations

France

Fines up to €50,000 per violation (individuals)
Fines up to €250,000 for companies
Imprisonment possible for repeat offenders

Netherlands

Fines up to €900,000 or 1% of annual turnover
Product recall orders
Mandatory compliance audits

Spain

Fines up to €1 million for serious infractions
Temporary business suspension possible
Reputational damage through public registries

Key point: Unlike ADA lawsuits (which settle privately), EAA violations are public regulatory actions. Your non-compliance becomes public record.

Common EAA Violations to Fix

Based on early enforcement actions, here are the most cited violations:

1. E-Commerce Checkout Barriers (83% of violations)

Problem: Multi-step checkout processes that aren't keyboard-accessible or lack proper form labels.

<!-- ❌ Common violation -->
<div onclick="proceedToPayment()">
  <span>Continue to Payment</span>
</div>

<!-- ✅ EAA compliant -->
<button type="button" onclick="proceedToPayment()">
  Continue to Payment
</button>

2. Missing Alternative Text (76%)

Problem: Product images without descriptive alt text.

<!-- ❌ Violation -->
<img src="product-photo.jpg">

<!-- ✅ Compliant -->
<img src="product-photo.jpg" 
     alt="Blue cotton t-shirt with round neck, front view">

3. Inaccessible PDFs (68%)

Problem: Invoices, contracts, and product manuals distributed as image-based PDFs.

Solution: Use tagged PDFs with:

Proper reading order
Alternative text for images/graphics
Bookmarks for navigation
Form fields with labels

4. Video Without Captions (64%)

Problem: Product demos, tutorials, and advertisements without captions or transcripts.

Required: Synchronized captions for all pre-recorded video content.

5. Poor Color Contrast (61%)

Problem: Light text on light backgrounds, especially in CTAs and pricing.

Standard: 4.5:1 contrast ratio for normal text, 3:1 for large text (18pt+)

6. Broken Keyboard Navigation (59%)

Problem: Custom dropdowns, date pickers, and modal dialogs that trap keyboard focus.

Test: Try navigating your entire site using only Tab, Enter, Escape, and arrow keys.

Step-by-Step EAA Compliance Plan

Phase 1: Assessment (Week 1-2)

Action items:

Run automated accessibility scan (e.g., AccessiGuard)
Identify all digital products/services under EAA scope
Document current violations
Prioritize by user impact and legal risk

Deliverable: Baseline compliance report showing gap analysis.

Phase 2: Critical Fixes (Week 3-6)

Focus on high-impact violations:

E-commerce priority:

Checkout flow (forms, buttons, error messages)
Product search and filtering
Shopping cart functionality
Payment confirmation

Banking/finance priority:

Login and authentication
Transaction forms
Account statements (PDF accessibility)
Mobile app parity

Media priority:

Video player controls (keyboard accessible)
Captions and transcripts
Audio descriptions
Playlist navigation

Phase 3: Comprehensive Remediation (Week 7-12)

Address remaining violations:

Image alt text across all pages
Form labels and error handling
Heading structure and landmarks
Color contrast adjustments
Link text descriptiveness

Phase 4: Testing (Week 13-14)

Automated testing:

Re-scan with accessibility tools
Check for regressions

Manual testing:

Keyboard-only navigation
Screen reader testing (NVDA, JAWS, VoiceOver)
Voice control (Dragon NaturallySpeaking)
Magnification tools (ZoomText)

User testing:

Engage people with disabilities to test critical flows
Document feedback and iterate

Phase 5: Documentation (Week 15-16)

Create an Accessibility Statement (required by EAA):

Must include:

Explanation of accessibility commitment
Known limitations and workarounds
Feedback mechanism for users
Complaint escalation process
Contact information

Example location: yoursite.com/accessibility

Phase 6: Ongoing Monitoring

Accessibility isn't one-and-done:

Monthly automated scans
Quarterly manual testing
Annual comprehensive audit
Training for content editors and developers

How AccessiGuard Helps with EAA Compliance

AccessiGuard provides tools specifically useful for EAA compliance:

✅ EN 301 549 / WCAG 2.1 AA Scanning
✅ Multi-page scanning (check entire site, not just homepage)
✅ Scheduled monitoring (catch regressions before regulators do)
✅ Email reports (share compliance status with legal/management)
✅ Fix guidance (specific recommendations, not generic advice)

For EU businesses:

Documentation trail for regulatory compliance
Baseline scans before remediation
Progress tracking over time
Export reports for accessibility statements

Real-World EAA Enforcement Examples

Case 1: German E-Commerce Platform (October 2025)

Violation: Checkout process not keyboard-accessible
Fine: €45,000
Required action: 60-day remediation + third-party audit

Case 2: French Banking App (November 2025)

Violation: Mobile app missing VoiceOver support for iOS
Fine: €120,000
Required action: App update + accessibility statement

Case 3: Dutch Streaming Service (December 2025)

Violation: Videos lacking synchronized captions
Fine: €200,000
Required action: Caption all content within 90 days

Pattern: Regulators are targeting high-traffic consumer services first. If you serve millions of EU users, you're a priority target.

Frequently Asked Questions

Q: Does the EAA apply to non-EU companies?

A: Yes, if you sell products or services to EU customers. It's similar to GDPR—if you target EU markets, you must comply.

Q: What if we only sell B2B, not B2C?

A: The EAA still applies. B2B services (banking, software platforms, e-commerce) must be accessible.

Q: Can we use an accessibility overlay widget?

A: No. Overlays do not achieve EAA compliance. You must fix the underlying code. (See our article on why overlays don't work.)

Q: What about legacy products sold before June 2025?

A: Products placed on the market before June 28, 2025 can continue to be sold without modification until they're withdrawn from service. But new contracts and updates must comply.

Q: How often do we need to audit for compliance?

A: The EAA doesn't specify, but best practice is quarterly manual audits and monthly automated scans.

Q: What if our site is accessible in English but not in local languages?

A: All language versions must be accessible. If you operate in France, your French content must meet the same standards as English content.

The Business Case for EAA Compliance

Beyond avoiding fines, accessibility benefits your business:

1. Market Expansion

87 million people in the EU have disabilities
Accessible sites have higher conversion rates
Better SEO (search engines reward accessible markup)

2. Legal Protection

Avoid fines (€50k-€1M)
Avoid stop-sale orders
Avoid reputational damage

3. Better UX for Everyone

Clear navigation helps all users
Good contrast improves mobile experience
Keyboard support helps power users

4. Future-Proofing

Compliance positions you for upcoming regulations
Accessible code is more maintainable
Reduces technical debt

Take Action Today

The EAA compliance deadline has passed. If you're not compliant, you're at risk.

Immediate steps:

Run a free scan at accessiguard.app to see where you stand
Review your compliance gap (what violations exist, what they cost to fix)
Prioritize critical fixes (checkout, forms, navigation)
Create a remediation timeline (share with legal/management)
Set up ongoing monitoring (monthly scans to catch regressions)

For EU businesses: Document everything. Regulators want to see good-faith efforts and progress, not perfection overnight.

Need help achieving EAA compliance?

AccessiGuard provides scanning, monitoring, and fix guidance for EU businesses:

✅ Free scan to establish baseline compliance
✅ WCAG 2.1 AA / EN 301 549 alignment
✅ Email reports for documentation
✅ Ongoing monitoring to maintain compliance

Get Started | Run Free Scan

Disclaimer: This article provides general information and should not be considered legal advice. Consult with an EU accessibility law specialist for compliance guidance specific to your business.