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The European Accessibility Act Is Live: What UK Developers Need to Know About WCAG 2.2

The European Accessibility Act is now enforceable. Here's what WCAG 2.2 AA compliance means for UK developers and agencies serving EU clients.

The European Accessibility Act Is Live: What UK Developers Need to Know About WCAG 2.2

The European Accessibility Act (EAA) became enforceable in June 2025. If you're a UK developer or agency building websites or apps for EU-based clients, this affects you directly.

The EAA requires digital products and services sold in EU member states to meet accessibility standards based on WCAG 2.1 AA (with EN 301 549 as the technical standard). But here's what's changed: enforcement is now active, and businesses face real penalties for non-compliance.

Who Does the EAA Apply To?

The EAA covers a broad range of digital products and services, including:

  • E-commerce websites and apps
  • Banking and financial services
  • E-books and e-readers
  • Transport services (ticketing, check-in)
  • Telecommunications services
  • Operating systems and hardware

If your UK agency builds websites for EU retailers, financial services firms, or any business selling to EU consumers, those sites need to comply.

Micro-enterprises (fewer than 10 employees and under €2 million turnover) get some exemptions, but most commercial websites don't qualify.

What WCAG 2.2 AA Actually Requires

While the EAA references WCAG 2.1 AA through EN 301 549, smart teams are building to WCAG 2.2 AA. It's backwards compatible and addresses gaps that 2.1 missed.

Here are the WCAG 2.2 success criteria that catch developers out most often:

Focus Not Obscured (2.4.11 - AA)

When a component receives keyboard focus, it can't be entirely hidden by other content like sticky headers or cookie banners. Partially obscured is allowed at AA level, but fully hidden fails.

Fix: Test your tab order with sticky elements visible. Add scroll padding or adjust z-index so focused elements remain visible.

Dragging Movements (2.5.7 - AA)

Any functionality that uses dragging (sliders, drag-and-drop interfaces, map panning) must have a single-pointer alternative.

Fix: Add click-to-move options, input fields for precise values, or button controls alongside drag interfaces.

Target Size Minimum (2.5.8 - AA)

Interactive targets need to be at least 24×24 CSS pixels, or have sufficient spacing from other targets.

Fix: Audit your buttons, links, and form controls. Inline links in paragraphs are exempt, but icon buttons and navigation items aren't.

Accessible Authentication (3.3.8 - AA)

Cognitive function tests (like remembering a password or solving a puzzle) can't be required unless you provide an alternative. Password managers must work, and copy-paste can't be blocked.

Fix: Support password managers, allow paste in password fields, and offer alternatives to CAPTCHAs like email verification.

Redundant Entry (3.3.9 - AA)

If users have already entered information in a process, don't make them enter it again. Auto-populate or let them select previous entries.

Fix: Store form data across steps in multi-page forms. Pre-fill shipping addresses from billing where appropriate.

Practical Steps for Compliance

1. Audit Your Current Sites

Run automated scans to catch the obvious issues: missing alt text, colour contrast failures, missing form labels. Automated tools catch about 30-40% of WCAG issues, but they're a solid starting point.

2. Manual Testing Matters

Automated scans won't catch focus order problems, whether alt text is actually meaningful, or if your drag-and-drop has a working alternative. Budget time for keyboard-only testing and screen reader checks.

3. Document Everything

The EAA requires businesses to provide accessibility statements and respond to user complaints. Keep records of your audits, fixes, and testing. Dated evidence matters if enforcement bodies come asking.

4. Build Accessibility Into Your Process

Retrofitting accessibility is expensive. Adding it during development costs a fraction. Update your component libraries, design systems, and code review checklists.

Enforcement Is Real

EU member states are responsible for enforcement, and approaches vary. Some countries have designated specific regulators; others handle complaints through consumer protection bodies.

Penalties differ by country, but they include fines, mandatory remediation, and in some cases, being blocked from selling in that market.

For UK agencies, this creates a commercial reality: EU clients will increasingly require accessibility compliance as a contractual condition. Agencies that can deliver compliant work have a competitive advantage.

The Bottom Line

The EAA isn't a future concern—it's current law. If you're building for EU markets, WCAG 2.2 AA compliance is the baseline.

The good news: most accessibility fixes improve usability for everyone. Better focus states, larger touch targets, and clearer forms make sites easier to use, full stop.

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