European Accessibility Act (EAA)

Introduction

The European Accessibility Act (EAA) introduces common accessibility requirements for a range of digital products and services across the European Union.

Accessibility regulation reflects a real and growing need. According to Eurostat, around one in four adults in the EU lives with some form of disability, representing more than 100 million people across Europe. Many still encounter barriers when using digital services, including online banking, transport booking systems, or e-commerce platforms.

Digital accessibility ensures that people with disabilities can access and use services independently. It also improves usability more broadly. Clear navigation, readable interfaces, and structured content benefit many users, including older adults and people using assistive technologies.

The European Accessibility Act introduces a shared regulatory framework that aims to reduce digital barriers across the European market.

What is the European Accessibility Act?

The European Accessibility Act is a directive adopted by the European Union in 2019. It establishes accessibility requirements for specific consumer products and digital services across the EU.

The directive focuses on technologies that people rely on in everyday life.

Examples include:

• e-commerce services

• consumer banking services

• telecommunications services

• ticketing and transport booking platforms

• e-books and reading software

• audiovisual media service platforms

• self-service terminals such as ATMs or ticket machines

Accessible digital experiences allow people with disabilities to access these services independently and participate fully in digital society.

The directive also supports the EU single market by harmonizing accessibility requirements across member states.

National implementation of the EAA

The European Accessibility Act is a directive, which means EU countries implement it through national legislation.

Each member state translates the directive into its own legal framework.

Examples include:

• Germany - BFSG

• Austria - BaFG

• France - Law 171/2023

• Italy - Legislative Decree no. 82/2022

These laws define how accessibility requirements are enforced within each country. We explore them in more detail on their respective pages.

When does the EAA apply?

The European Accessibility Act follows a multi-year implementation timeline.

Key milestones include:

• 2019 - Directive adopted by the European Union

• 2022 - Deadline for national legislation implementing the directive

• 28 June 2025 - Accessibility requirements become enforceable

From June 2025 onwards, organizations offering covered products or services must ensure they meet accessibility requirements defined in national legislation.

Certain products already on the market before this date may benefit from transitional provisions. New services entering the market after June 2025 are expected to meet accessibility requirements from the start.

How the EAA relates to accessibility standards

The EAA defines legal obligations. Technical standards describe how accessibility requirements should be implemented in practice.

Two standards are particularly relevant.

EN 301 549

EN 301 549 is the European accessibility standard for information and communication technologies.

It includes accessibility requirements for:

• websites

• mobile applications

• software

• digital documents

• multimedia

• hardware interfaces

EN 301 549 incorporates WCAG requirements and expands them to additional digital technologies.

Together, WCAG and EN 301 549 provide the technical framework organizations typically follow when implementing accessibility requirements under the EAA.

WCAG

The WCAG (Web Content Accessibility Guidelines) are the international standard for web accessibility developed by the World Wide Web Consortium (W3C).

WCAG defines how digital content should be designed so people with disabilities can perceive, understand, navigate, and interact with it.

The guidelines address areas such as:

• keyboard navigation

• screen reader compatibility

• colour contrast

• alternative text for images

• accessible forms and interactions

Many accessibility regulations reference WCAG as the baseline for web accessibility.

Who must comply with the EAA?

The directive primarily applies to organizations offering consumer-facing products or services within the European Union.

Typical examples include:

• online retailers

• banks and financial service providers

• telecommunications providers

• e-book platforms

• ticket booking systems

• transport service providers

Companies based outside the EU still fall within scope when they offer covered services to EU consumers.

Does the EAA apply to B2B services?

Services designed exclusively for business users generally fall outside the scope of the directive.

However, many platforms combine business and consumer interfaces. When consumers interact directly with a service, accessibility requirements may apply to those parts of the platform.

organizations often review their user journeys to identify where consumer interactions occur.

Are small companies exempt?

The directive includes specific provisions for microenterprises.

A microenterprise is defined as a business with:

• fewer than 10 employees

• annual turnover or balance sheet below €2 million

Microenterprises providing services within the scope of the EAA are exempt.

Small and medium-sized enterprises above these thresholds are generally expected to meet accessibility requirements.

Are there other exemptions?

Two limited exemptions may apply.

Disproportionate burden

An organization may claim that accessibility requirements create a disproportionate burden.

Authorities evaluate several factors when assessing this claim, including:

• company size

• available financial resources

• estimated implementation cost

• expected benefits for users with disabilities

organizations must document this assessment.

A disproportionate burden cannot be used as a blanket justification to avoid accessibility altogether. It may apply to specific features, or components, but not to an entire service.

Even where certain requirements are not implemented, organizations are still expected to address accessibility where it is reasonable to do so.

In practice, accessibility also has a direct impact on user experience. Services that remain difficult to use can lead to lost customers, reduced engagement, and lower trust, regardless of whether a specific requirement falls within the scope of the regulation.

Fundamental alteration

Accessibility requirements may also be waived if they would fundamentally change the nature of a product or service.

These cases are relatively rare and require clear justification.

What does EAA compliance require for digital services?

For websites, applications, and digital interfaces, compliance is defined through the four principles of accessibility: content and functionality must be perceivable, operable, understandable, and robust.

These principles describe the expected outcome. WCAG provides the criteria used to meet these requirements in practice, applied based on the specific features and context of each service.

A service is considered accessible when users, including those relying on assistive technologies, can access it, navigate it, understand it, and complete key actions independently.

Accessibility requirements apply to a service as a whole. This means that all digital touchpoints, including websites, mobile applications, and related platforms, need to be accessible, as well as third-party integrations such as login systems, payment flows, or customer support tools.

Embedding accessibility into design, development, and content processes helps organizations maintain accessibility as digital products evolve.

What happens if you do not comply with the EAA?

If an organization provides products or services covered by the European Accessibility Act but fails to meet accessibility requirements, national authorities may take enforcement action.

Because the directive is implemented through national laws, enforcement happens at the member state level.

Authorities can:

• investigate complaints from users

• conduct regulatory reviews

• require organizations to remove accessibility barriers

• impose penalties or corrective measures

Consumers and disability organizations may also report inaccessible services to national enforcement bodies.

Accessibility barriers can also create commercial risks. Users who cannot access services may abandon a platform or choose an alternative provider.

What fines can apply under the EAA?

The EAA does not define a single EU-wide fine structure.

Each EU member state establishes penalties through its national legislation.

Possible consequences may include:

• administrative fines

• corrective action orders

• restrictions on selling products or services

• regulatory investigations

organizations operating across multiple EU countries may therefore face different enforcement frameworks depending on the national laws implementing the directive.

Steps organizations can take to prepare for the EAA

Preparing for accessibility requirements often begins with understanding the current accessibility status of digital services.

1. Assess accessibility

Accessibility assessments identify barriers affecting users with disabilities.

Common issues include:

• missing alternative text

• navigation problems

• inaccessible forms

• colour contrast issues

• incompatibility with assistive technologies

Accessibility audits and automated scanning tools can help organizations identify common issues and establish an initial baseline. However, it is important to keep in mind that automated tools, including those using advanced AI, cannot provide a complete accessibility evaluation. Many barriers can only be identified through expert testing and real use with assistive technologies.

2. Remediate accessibility barriers

Once accessibility barriers are identified, remediation is prioritised based on their impact and scope.

Issues are typically addressed first when they affect critical user actions, such as registering, logging in, completing a purchase, or accessing key information like contracts or terms. Priority is also influenced by how widespread the issue is across the service and how many users it affects.

For each identified barrier, an appropriate solution should be implemented. In some cases, this involves fixing the issue directly. In others, it may require providing an accessible alternative, ensuring that users can still access the content or complete the task without barriers.

Remediation often requires coordination between designers, developers, and content teams to ensure that solutions are effective and consistent across the service.

3. Integrate accessibility into development workflows

Accessibility becomes easier to maintain when it is integrated into everyday digital processes.

organizations often introduce:

• accessibility testing during development

• accessibility checks before product releases

• internal accessibility guidelines for design and development

4. Monitor accessibility continuously

Digital services evolve through updates, new content, and product changes.

Continuous monitoring helps ensure accessibility remains part of the development lifecycle.

How Accessiway supports organizations preparing for the EAA

Meeting accessibility requirements often involves multiple teams across design, development, compliance, and product management.

Accessiway works alongside organizations to help integrate accessibility into digital workflows and maintain compliance with accessibility standards.

This support includes:

• automated accessibility monitoring

• expert accessibility audits

• remediation guidance for development teams

• accessibility training

• ongoing accessibility compliance monitoring

Learn more about how we support accessibility on our solutions page.

These capabilities help organizations align with standards such as WCAG and EN 301 549, which underpin many accessibility regulations including the European Accessibility Act.

Accessibility improves when it becomes part of everyday digital practice. With the right processes and tools in place, organizations can build digital experiences that work for everyone.