The European Accessibility Act at One Year: What UK Developers Need to Know
The European Accessibility Act (EAA) hit its one-year enforcement mark on 28 June 2026. If you're building websites or digital products for clients who sell into the EU, this matters to you—regardless of where your office is based.
Here's what the first year has shown us, and what you should actually do about it.
What the EAA Covers
The EAA isn't just about websites. It applies to:
- E-commerce sites (any online shop selling to EU customers)
- Banking services and apps
- E-books and e-reader software
- Ticketing systems and travel information
- Streaming services and TV equipment interfaces
The technical standard it points to is WCAG 2.1 Level AA—the same baseline the UK public sector has been required to meet since 2018.
The key difference from UK regulations: the EAA applies to private sector businesses, not just government bodies. If your client sells products or services to EU consumers, they're in scope.
The "Non-EU Company" Question
This trips people up. The EAA applies based on where products and services are sold, not where the company is located.
A UK e-commerce site shipping to Germany? In scope.
A UK SaaS company with EU subscribers? In scope.
A UK agency building sites for EU-based clients? Your clients are in scope, which means they'll be asking you about compliance.
Post-Brexit, the UK isn't bound by the EAA directly. But if you're building for clients with EU customers, you're building to EAA requirements whether you like it or not.
What Enforcement Looks Like So Far
The first year has been quieter than some predicted. Each EU member state handles enforcement differently—some have designated market surveillance authorities, others are still setting up processes.
But "quiet" doesn't mean "safe to ignore." Several patterns are emerging:
Complaints are being logged. Users and advocacy groups are filing complaints, even if formal enforcement actions are still ramping up.
B2B contracts are tightening. Large EU companies are adding accessibility requirements to supplier contracts. If your client sells to enterprise customers in the EU, those customers are asking for compliance documentation.
The transition period is ending. Products and services already on the market before June 2025 had some grace period allowances. Those are narrowing. New products have no such buffer.
The Practical Overlap with UK Requirements
If you're already building to WCAG 2.1 AA for UK public sector clients, you're most of the way there for EAA compliance too.
The core technical requirements align:
- Perceivable content (text alternatives, captions, sufficient contrast)
- Operable interfaces (keyboard access, no seizure triggers, enough time)
- Understandable information (readable, predictable, input assistance)
- Robust markup (valid code, compatibility with assistive tech)
Where the EAA adds complexity is in documentation and process. You may need to:
- Provide accessibility statements (similar to UK public sector requirements)
- Demonstrate how you handle accessibility feedback
- Show evidence of conformance, not just intent
What to Do This Week
1. Audit your client list. Which clients have EU customers? Those sites need attention first.
2. Run a WCAG 2.1 AA check on those sites. Automated tools catch about 30-40% of issues. They're a starting point, not a finish line, but they'll flag the obvious problems: missing alt text, contrast failures, form labels, heading structure.
3. Fix the common failures. Based on enforcement data from the US (where accessibility lawsuits are more common), the same issues appear repeatedly:
- Missing or empty alt attributes on images
- Low colour contrast (below the 4.5:1 ratio for normal text, 3:1 for large text per WCAG 1.4.3)
- Form inputs without associated labels
- Links that don't make sense out of context ("click here")
- Missing skip navigation links
- Keyboard traps in interactive components
4. Document what you've done. Keep records of audits, fixes, and testing. If a client ever faces a complaint, this paper trail matters.
5. Build accessibility into your process. Retrofitting is expensive. Catching issues during development is cheaper. Add accessibility checks to your code review process, your QA checklist, your design system documentation.
The Bottom Line
The EAA isn't going away. Enforcement will increase. And even if your clients never face formal action, their customers and business partners will increasingly expect accessible products.
Treating accessibility as a one-time fix doesn't work. It needs to be part of how you build things.
WCAGCheck scans your website for WCAG compliance issues and tells you exactly what to fix. Try it free at wcagcheck.co.uk
