All articles
WCAGCheck Editorial

EAA Compliance: What UK Agencies Need to Fix for EU Clients Before Audits Start

The European Accessibility Act is now being enforced. Here's what UK agencies building sites for EU clients need to fix before audits begin.

EAA Compliance: What UK Agencies Need to Fix for EU Clients Before Audits Start

The European Accessibility Act (EAA) enforcement deadline passed on 28 June 2025. If you're a UK agency building websites for clients who sell to EU customers, this affects you directly.

The EAA requires WCAG 2.1 Level AA compliance for e-commerce sites, banking services, and other digital products serving EU consumers. Member states are now setting up enforcement mechanisms, and audits are coming.

Here's what you actually need to fix.

Who's affected?

If your client sells products or services to customers in any EU country, their website likely falls under the EAA. This includes:

  • E-commerce sites shipping to EU addresses
  • SaaS products with EU subscribers
  • Booking platforms serving EU travellers
  • Financial services accessible to EU residents

The EAA doesn't care where your client is headquartered. It cares where their customers are.

The specific issues auditors will look for

Based on early enforcement guidance and the WCAG 2.1 AA requirements baked into the EAA, here are the areas most likely to trigger compliance failures:

1. Product page barriers

Product pages are where most e-commerce accessibility issues live. Auditors will check:

Image alt text (WCAG 1.1.1): Every product image needs descriptive alt text. Not "IMG_4523.jpg". Not "product image". Actual descriptions like "Navy blue wool jumper, crew neck, shown from front".

Colour-only information (WCAG 1.4.1): If you're showing colour variants as swatches alone, you need text labels. A red dot doesn't help someone who can't see red.

Price and availability announcements: Screen reader users need to know when prices change or items go out of stock. Use ARIA live regions (aria-live="polite") for dynamic updates.

2. Checkout process failures

Checkout is where accessibility failures cost money twice: once in lost sales, again in compliance penalties.

Form labels (WCAG 1.3.1, 3.3.2): Every input needs a programmatically associated label. Placeholder text doesn't count. Use the for attribute pointing to the input's id.

<label for="email">Email address</label>
<input type="email" id="email" name="email">

Error identification (WCAG 3.3.1): When validation fails, tell users what went wrong and where. "Please fix the errors below" isn't good enough. "Email address: Please enter a valid email format" is.

Error suggestions (WCAG 3.3.3): If you know what's wrong, suggest how to fix it. "Postcode must be in the format AA1 1AA".

3. Keyboard navigation

This is where most sites fail without realising it.

Focus visibility (WCAG 2.4.7): Every interactive element needs a visible focus indicator. If you've written outline: none anywhere in your CSS, you've probably broken this. Add a proper focus style instead:

:focus {
  outline: 2px solid #005fcc;
  outline-offset: 2px;
}

Keyboard traps (WCAG 2.1.2): Modal dialogs, dropdown menus, and custom widgets are common trap points. Users must be able to navigate in and out using only the keyboard. Test by tabbing through your entire checkout flow without touching the mouse.

Logical tab order (WCAG 2.4.3): Tab order should follow visual order. If you're using CSS Grid or Flexbox to reorder elements visually, the DOM order still determines tab sequence.

4. Contrast failures

Text contrast (WCAG 1.4.3): Normal text needs a 4.5:1 contrast ratio against its background. Large text (18pt or 14pt bold) needs 3:1. Grey text on white backgrounds is the most common failure.

Check your:

  • Body text
  • Form labels
  • Placeholder text (which still needs to meet contrast requirements)
  • Error messages
  • Footer links

Non-text contrast (WCAG 1.4.11): Form field borders, icons, and focus indicators need 3:1 contrast. That light grey border around your input fields? Probably failing.

5. Mobile accessibility

Touch targets (WCAG 2.5.5): Interactive elements need to be at least 24×24 CSS pixels, with 44×44 recommended. Small "X" buttons to close modals and tightly packed navigation links are common failures.

Orientation (WCAG 1.3.4): Don't lock your site to portrait or landscape mode unless absolutely necessary.

What enforcement actually looks like

Each EU member state is implementing its own enforcement approach. Germany's BMAS is already accepting complaints. France's ARCOM has published audit criteria. Other countries are following.

Penalties vary by country, but expect:

  • Formal warnings requiring fixes within set timeframes
  • Fines for continued non-compliance
  • Public disclosure of non-compliant businesses

Your action plan

  1. Audit now: Don't wait for a complaint. Run automated scans to catch the obvious issues, then do manual testing for keyboard navigation and screen reader compatibility.

  2. Fix high-impact issues first: Checkout flows, forms, and navigation affect the most users.

  3. Document your efforts: The EAA includes provisions for "disproportionate burden". If you can demonstrate ongoing accessibility work, you're in a better position than if you've done nothing.

  4. Build it into your process: Accessibility bolted on at the end costs more than accessibility built in from the start.

WCAGCheck scans your website for WCAG compliance issues and tells you exactly what to fix. Try it free at wcagcheck.co.uk