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WCAGCheck Team

The European Accessibility Act: What Businesses Need to Know Before June 2025

The European Accessibility Act became enforceable in June 2025. Here's what it covers, who it applies to (including non-EU businesses selling to EU customers), the penalties for non-compliance, and what you actually need to do.

The European Accessibility Act: What Businesses Need to Know Before June 2025

The European Accessibility Act (EAA) has been in the pipeline since 2019. Many businesses assumed they had plenty of time to prepare. That time has now run out: the EAA became enforceable across EU member states on 28 June 2025.

If you sell digital products or services to customers in the EU — and that includes businesses based outside Europe — this legislation applies to you. The penalties for non-compliance are significant, and enforcement mechanisms are already in place in most member states.

This article explains what the EAA actually requires, who it covers, what happens if you don't comply, and the most practical path to getting into compliance.

What Is the European Accessibility Act?

The EAA (Directive (EU) 2019/882) is EU legislation requiring that a wide range of products and digital services meet accessibility standards. It was adopted in April 2019 and gave member states until June 2022 to transpose it into national law, with the compliance deadline for businesses set at June 2025.

The EAA is not the same as WCAG (Web Content Accessibility Guidelines). WCAG is a technical standard. The EAA is legislation that requires compliance with accessibility standards, and it references EN 301 549 — the European standard that incorporates WCAG 2.1 Level AA as its core technical requirement.

In practical terms: if your digital services meet WCAG 2.1 AA, you're largely meeting the EAA's technical requirements for web accessibility. But the EAA goes further than just websites.

What Products and Services Does the EAA Cover?

The EAA covers a broad range of products and services. For digital businesses, the most relevant categories are:

Digital services:

  • E-commerce websites and apps (online shopping platforms)
  • Banking and financial services delivered digitally
  • Audiovisual media services (streaming platforms, video on demand)
  • Electronic communications services (messaging, email services)
  • E-books and dedicated reading software
  • Transport services (booking interfaces, ticketing systems)

Hardware:

  • Computers, tablets, and smartphones
  • ATMs and payment terminals
  • Self-service kiosks (ticketing machines, check-in kiosks)
  • E-readers

What the EAA does NOT cover:

  • Micro-enterprises (fewer than 10 employees AND under €2 million annual turnover) are exempt for services — though not for some hardware categories
  • Public sector bodies already covered by the Web Accessibility Directive (WAD)
  • Services contracted before June 2025 have transitional provisions until 2030

If your business sells physical products with digital components (apps, interfaces, documentation), those digital elements fall under the EAA's requirements too.

Does the EAA Apply to Non-EU Businesses?

Yes. This is the part that catches many businesses off guard.

The EAA applies to services offered to consumers in the EU, regardless of where the service provider is based. If a US, UK, Canadian, or Australian business has a website that sells to EU customers and ships to EU addresses, the EAA's accessibility requirements apply to that transaction and the platform facilitating it.

This is consistent with how the EU has approached data protection under GDPR — the territorial scope is defined by where the customer is, not where the business is incorporated.

Practically speaking, enforcement against businesses with no EU presence will be more challenging. But the legal exposure is real, and as the EU develops cross-border enforcement mechanisms (which GDPR has demonstrated it can do), non-EU businesses cannot assume they're safely outside the jurisdiction.

If you have any meaningful EU customer base, treat the EAA as applicable to you.

What Are the Actual Requirements?

For digital services, compliance means meeting the functional accessibility requirements defined by EN 301 549, which maps to WCAG 2.1 Level AA for web content. This includes:

Perceivability:

  • All non-text content has text alternatives (image alt text, captions for video)
  • Content can be presented in different ways without losing information (logical heading structure, semantic HTML)
  • Sufficient colour contrast (4.5:1 for normal text, 3:1 for large text)
  • Text can be resized to 200% without loss of functionality

Operability:

  • All functionality available via keyboard
  • No content that flashes more than 3 times per second
  • Users can pause, stop, or hide moving content
  • Navigation aids like skip links and descriptive page titles

Understandability:

  • Language of page and passages is programmatically identified
  • Error messages are descriptive and suggest corrections
  • Consistent navigation and labelling

Robustness:

  • Content is compatible with current and future assistive technologies
  • ARIA used correctly, semantic HTML preferred

Beyond the WCAG technical requirements, the EAA also requires:

  • Accessibility statements — a publicly available document describing the service's accessibility compliance status, known limitations, and contact information for reporting issues
  • Feedback mechanisms — users must be able to report accessibility barriers and receive a response
  • Documentation — accessibility must be considered during product design and development, not retrofitted

What Are the Penalties for Non-Compliance?

Each EU member state sets its own penalties within the EAA framework. Enforcement and fine structures vary, but the direction is consistent:

  • Germany: Fines of up to €100,000 for violations; repeat or systemic failures can attract higher penalties
  • France: Administrative fines and potential injunctions to suspend services
  • Italy: Fines ranging from €5,000 to €40,000 depending on severity
  • Spain: Graduated penalties up to €1 million for serious violations

Beyond direct fines, non-compliant businesses face:

  • Mandatory remediation orders (fix it or stop offering the service)
  • Injunctions preventing sale of non-compliant products in the EU
  • Reputational damage as accessibility advocacy organisations publicise enforcement actions
  • Civil claims from disabled consumers who couldn't access the service

The EAA also establishes a market surveillance mechanism — national authorities are empowered to investigate complaints and conduct proactive audits, similar to how GDPR supervisory authorities operate.

How Does the EAA Compare to Other Accessibility Laws?

| | EAA (EU) | WCAG (Global standard) | ADA (US) | PSBAR (UK public sector) | |---|---|---|---|---| | Type | Legislation | Technical guideline | Legislation (civil rights) | Regulations | | Applies to | Private sector products/services | Referenced by legislation | Businesses open to the public | UK public sector bodies | | Technical standard | EN 301 549 / WCAG 2.1 AA | WCAG 2.1 or 2.2 | WCAG 2.1 AA (DOJ guidance) | WCAG 2.1 AA | | Enforcement | National market surveillance authorities | N/A | DOJ and private litigation | GDS monitoring | | Penalties | Administrative fines, injunctions | N/A | DOJ action, civil lawsuits | Publication of non-compliance |

The EAA is unusual in that it creates a positive legislative duty to be accessible, backed by administrative enforcement — rather than relying primarily on litigation from affected individuals (as in the US ADA model). This makes it more predictable but also means proactive enforcement is more likely.

Transitional Provisions: What Still Has Time

Not everything is subject to the June 2025 deadline:

  • Services contracted before 28 June 2025 — service contracts entered into before the compliance date have a transitional period until 28 June 2030 (five years). After 2030, all services must comply.
  • Micro-enterprises providing services — businesses with fewer than 10 employees and annual turnover under €2 million are exempt from the EAA's service requirements. Note this exemption does not apply to products.
  • Disproportionate burden — the EAA includes a "disproportionate burden" clause similar to other accessibility legislation. If compliance would fundamentally alter the product or impose costs that are clearly excessive relative to the benefits, businesses can document this and defer specific requirements. This is a narrow exception, not a general opt-out.

If you're a micro-enterprise, you're not immune — the exemption only applies to services, not products, and it's based on size at the time of supply. Growing businesses should plan for compliance as they scale.

Common Mistakes Businesses Make

Assuming it only applies to large organisations. The micro-enterprise exemption applies to very small businesses. If you have 15 employees, you're in scope.

Treating WCAG compliance as the whole requirement. Meeting WCAG 2.1 AA is necessary but not sufficient. The EAA also requires accessibility statements, feedback mechanisms, and documented accessibility processes.

Relying on overlay widgets. Accessibility overlay tools (like accessiBe or UserWay) do not make a site EAA compliant. They don't fix underlying code issues and have been criticised by disability organisations. Real compliance requires real code fixes.

Ignoring mobile apps. If you have an iOS or Android app serving EU customers, it falls under the EAA just as much as your website does.

Thinking "we'll deal with it if we get a complaint." The EAA creates proactive obligations. Market surveillance authorities don't need a complaint to investigate — they can audit your service at any time.

Your EAA Compliance Checklist

Here's what a practical compliance programme looks like:

Immediate priorities:

  • [ ] Conduct an accessibility audit against WCAG 2.1 AA (automated scan + manual testing)
  • [ ] Fix critical and high-severity issues (missing alt text, keyboard traps, contrast failures)
  • [ ] Publish an accessibility statement on your website

Short-term (within 3 months):

  • [ ] Remediate medium-severity WCAG failures
  • [ ] Implement a feedback mechanism for accessibility issues (email address or form)
  • [ ] Audit your mobile apps if applicable
  • [ ] Review your authentication flows for WCAG 2.2 compliance (Accessible Authentication criterion)

Ongoing:

  • [ ] Include accessibility testing in your development pipeline
  • [ ] Train developers and content editors on accessibility basics
  • [ ] Review and update your accessibility statement at least annually
  • [ ] Log and respond to accessibility complaints

Getting Started

An accessibility audit is the essential first step. You need to know where your gaps are before you can prioritise remediation.

WCAGCheck provides automated WCAG scanning with actionable issue reports, prioritised by severity and impact. It won't replace manual testing by an accessibility specialist for a full audit, but it gives you an immediate picture of your site's compliance status and the most common issues affecting your users.

Run a scan, fix the critical issues, publish your accessibility statement, and you'll be in a materially better position than the majority of businesses that still haven't started.

The deadline has passed. The question now is how quickly you can get to compliance — and how you demonstrate good faith if a regulator comes knocking.