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EAA Enforcement Has Started: What UK Digital Teams Need to Know

The European Accessibility Act deadline passed in June 2025. Here's what the first year of enforcement means for UK agencies serving EU clients.

EAA Enforcement Has Started: What UK Digital Teams Need to Know

The European Accessibility Act (EAA) deadline came and went in June 2025. We're now a year into enforcement, and the picture is becoming clearer for UK developers and agencies who build products for EU markets.

If you're working with EU-based clients or your products are sold to EU consumers, here's what the first year of enforcement tells us—and what you need to do about it.

What the EAA Actually Requires

The EAA mandates that certain products and services sold in the EU must be accessible. For digital teams, the relevant categories include:

  • E-commerce websites and apps
  • Banking services
  • E-books and e-readers
  • Transport services (ticketing, check-in)
  • Telecommunication services

The technical standard? WCAG 2.1 Level AA. If you're already building to this standard, you're largely covered. If you're not, you have a compliance gap.

Unlike the UK's Equality Act, which relies on individual complaints and court cases, the EAA creates a structured enforcement framework across all 27 EU member states. Each country has designated market surveillance authorities who can investigate, issue fines, and in some cases, block non-compliant products from the market.

What We've Seen in Year One

Enforcement has varied by country, which isn't surprising given that each member state implements the directive through national law. Germany and France have been more active, with market surveillance authorities conducting audits of major e-commerce platforms. The Netherlands has focused on banking services.

The pattern so far:

  1. Large platforms first: Authorities are prioritising high-traffic e-commerce sites and financial services. If you're building for a major retailer or bank with EU customers, expect scrutiny.

  2. Complaints trigger investigations: Several enforcement actions started with user complaints rather than proactive audits. Accessibility advocates in the EU are organised and filing formal complaints.

  3. Fines are real but not catastrophic yet: Early penalties have been in the tens of thousands of euros, with orders to remediate. The bigger risk is being blocked from the market entirely.

  4. Documentation matters: Authorities are asking for accessibility statements, audit reports, and evidence of ongoing monitoring. "We're working on it" isn't an acceptable response.

Why This Matters for UK Teams

Brexit didn't make the EAA irrelevant for UK businesses. If you're building digital products or services that:

  • Are sold to consumers in EU countries
  • Are used by EU-based employees of multinational companies
  • Are part of a supply chain serving EU markets

...then EAA compliance applies to you.

Many UK agencies build sites and apps for clients with EU operations. If your client sells products to German consumers or provides banking services to French customers, the EAA applies to what you build.

This isn't theoretical. We've heard from agencies whose clients have received compliance enquiries from EU authorities. The question "is your website EAA compliant?" is now part of procurement conversations.

What You Need to Do

1. Audit Against WCAG 2.1 AA

The EAA references the EN 301 549 standard, which incorporates WCAG 2.1 Level AA for web content. Run a proper audit—automated scanning plus manual testing with assistive technologies.

Pay particular attention to:

  • Keyboard navigation (Success Criterion 2.1.1): Every function must be operable via keyboard
  • Colour contrast (Success Criterion 1.4.3): Minimum 4.5:1 for normal text, 3:1 for large text
  • Form labels and error handling (Success Criteria 1.3.1, 3.3.1, 3.3.2): Forms must be properly labelled with clear error messages
  • Alternative text (Success Criterion 1.1.1): All non-decorative images need meaningful descriptions

2. Create an Accessibility Statement

The EAA requires an accessibility statement that includes:

  • Current conformance level
  • Known limitations and workarounds
  • Contact information for accessibility feedback
  • Date of last assessment

This isn't optional documentation—it's a legal requirement for covered services.

3. Build Accessibility Into Your Process

One-off audits aren't enough. The EAA expects ongoing compliance, which means:

  • Accessibility checks in your CI/CD pipeline
  • Regular manual testing
  • A process for handling accessibility feedback
  • Training for developers and designers

4. Document Everything

Keep records of your audits, remediation work, and testing. If an authority asks how you ensure compliance, you need evidence, not assurances.

The Bottom Line

The EAA has teeth, and enforcement is happening. For UK digital teams serving EU markets, WCAG 2.1 AA compliance isn't a nice-to-have—it's a market access requirement.

The good news: if you're already building accessible products, you're most of the way there. If you're not, now is the time to close the gap before your clients start asking difficult questions.

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