European Accessibility Act, Explained

Currently, there are 87 million people in Europe living with a disability(opens in a new tab). That’s roughly one in four adults — people who encounter unnecessary barriers every day when trying to use websites, apps, and digital services that weren’t built with them in mind. The European Accessibility Act(opens in a new tab) (EAA) was designed to change that, setting enforceable standards that require organizations to make their digital products accessible.

Below, we’ll review what the EAA is, who it applies to, and why compliance is worth prioritizing.

How the EAA Differs from the Web Accessibility Directive

The Web Accessibility Directive(opens in a new tab) predates the EAA and has a narrower scope. 

Signed by the Member States in 2016, this 15-page document applies exclusively to public sector agencies and organizations financed through public contracts — for example, contractors hired to create an online portal for the websites of EU member states. Private companies are not covered.

Key features of the directive include:

• Each Member State must develop accessibility standards based on guidance from the European Standards Organization (ESO), which in turn is based on WCAG Level AA requirements.

• Organizations must publish an accessibility statement on their websites and mobile content.

• Users must have a way to provide feedback about accessibility issues.

• The Directive applies to websites, mobile apps, payment terminals, ticket dispensers, and other electronic communications technologies. 

The Directive was rolled out gradually after its 2016 enactment. As of September 2020, all new and existing websites covered by it must meet its requirements.

Because the Web Accessibility Directive only covers public organizations, it left a significant gap in EU accessibility law. In 2019, Member States passed the EAA to address that gap — extending accessibility requirements to private companies and broadening the scope of digital accessibility across the EU.

Who Needs to Comply with the EAA?

So, who must comply with the EAA? The EAA applies to both public and private companies, a key difference from previous accessibility laws, such as the Public Sector Bodies Accessibility Regulations(opens in a new tab) (PSBAR), which applied only to public sector organizations.

Below are some examples of organizations that must comply:

• E-commerce sites and online service providers, including consumer-facing websites and mobile apps.

• Shops and restaurants and their point-of-sale devices, such as kiosks or mobile apps.

• Business-to-business (B2B) and business-to-government (B2G) organizations that sell or provide services in the public or private sector.

• Media streaming companies and their media, telephony, and communication equipment with computer capabilities.

• Transportation companies with electronic ticketing companies.

Does the EAA Apply to Non-EU Companies?

Yes. The EAA applies to any organization selling products or services to EU customers, regardless of where that organization is based. A U.S., UK, or Australian company with no physical presence in the EU must still comply if it serves EU customers digitally. Put simply, location is not an exemption — market access is.

Sectors most impacted by this include e-commerce, SaaS, fintech, media streaming, and travel, as these industries typically serve cross-border EU customers through their digital channels.

Exemptions

The EAA has limited exemptions. Micro-enterprises with fewer than 10 employees and an annual turnover rate below €2 million are not required to comply. However, the EAA does encourage these businesses to provide accessible products and services regardless. Beyond legal compliance, building accessible products broadens audience reach, reflects company social values, and strengthens brand reputation.

What Products and Services Does the EAA Cover?

The EAA covers a broad range of digital products and services — any product or service that involves a digital interface or electronic interaction with the end user falls within the EAA’s scope. Below is a breakdown of what’s covered:

Digital Products:

• eBooks and eReading devices and software

• Smartphones and other consumer electronics

• Televisions with digital or interactive features

• Self-service terminals, ATMs, and other banking service devices

• Check-in machines and electronic ticketing devices

Digital Services

• E-commerce experiences and applications

• Digital rights management (DRM) software

• Banking and financial services accessed digitally

• Telephony and communication services

• Media streaming platforms and their associated software

An important distinction to make here: who provides these products and services matters too.

The EAA doesn’t just define what’s covered — it determines who is responsible. For example, if an organization manufactures, sells, or distributes any of the above products or services to EU customers, it must comply with the EAA, even if that organization is not headquartered in the EU.

EAA Compliance Timeline and Enforcement Milestones

The EAA wasn’t introduced overnight — it was rolled out in phases to give EU Member States and organizations time to prepare. Understanding the timeline helps clarify where the law stands today and what ongoing EAA deadlines and obligations look like.

Key Milestones

• 2019 — the EAA is passed. The EAA was formally adopted by EU Member States in April 2019, establishing the legal framework for accessibility across the EU.

• 2022 — Member States transpose the EAA into national law. By June 28, 2022, each EU Member State was required to transpose the EAA into its own national legislation. This means that individual countries began developing their own enforcement mechanisms in line with the EAA’s requirements.

• June 28, 2025 — enforcement begins. As of June 28, 2025, organizations covered by the EAA are required to meet its accessibility standards. This applies to both EU-based organizations and non-EU businesses selling into the EU market.

Ongoing Compliance

Meeting the June 2025 deadline was not a one-time event. The EAA requires organizations to maintain compliance on an ongoing basis — meaning accessibility obligations apply to new content, updated products, and any new digital services introduced after the deadline. Regular auditing and testing are necessary to sustain compliance as products and technology evolve.

Illustration of a webpage layout with a magnifying glass showing accessibility issues, indicated by red X marks on a checklist.

What Happens if You Don’t Comply With the EAA

Because the EAA is an enforceable directive — not a set of guidelines — organizations that don’t meet its requirements can face consequences across several areas, from financial penalties to market access restrictions. We’ll explore these in more detail below.

Financial Penalties

Non-compliance with the EAA can result in fines and penalties determined by individual EU Member States. Organizations that delay compliance may also face higher costs over time. Retrofitting digital services after the fact is typically much more expensive than building accessibility in from the start.

Market Access Restrictions

In more severe cases, organizations found to be non-compliant can be restricted from selling products or services in the EU market. For non-EU businesses in particular, maintaining EAA compliance is directly tied to continued access to EU customers.

Enforcement Actions by Member States

Each EU Member State is responsible for enforcing the EAA within its own jurisdiction. More simply, this means enforcement approaches, investigation processes, and penalty structures can vary by country. Organizations operating across multiple EU markets should account for this variation in their compliance planning.

Reputational Risk

Failing to meet EAA requirements can erode trust with customers, partners, advocacy groups — particularly as consumer expectations around inclusion and accessibility continue to rise. Organizations that demonstrate a proactive approach to accessibility are better positioned to build lasting trust with the 87 million Europeans living with a disability.

Procurement Exclusion

Non-compliant organizations may be excluded from public-sector procurement opportunities within the EU. For B2B and B2G organizations in particular, EAA compliance is increasingly necessary when doing business with public institutions.

How EN 301 549 and WCAG Fit into the EAA

Rather than creating entirely new technical standards, the EAA builds on existing ones — most notably EN 301 549. Here’s how it and WCAG’s POUR principles work together to define what compliance looks like in practice.

What is EN 301 549?

EN 301 549 is the European standard for digital accessibility, formally titled Accessibility Requirements for ICT Products and Services(opens in a new tab). It serves as the technical backbone of both the Web Accessibility Directive and the EAA, defining what accessible digital products and services must look like. 

How EN 301 549 References WCAG

EN 301 549 draws on WCAG standards as a reference point for its web accessibility criteria. What EN 301 549 enforces — and what the EAA requires — is that digital content meet the POUR principles: content must be perceivable, operable, understandable, and robust. In practice, this means addressing common accessibility barriers such as:

• Poor color contrast, which makes text difficult to read for people with visual disabilities.

• Misused semantic HTML, which makes content difficult to navigate for keyboard users and assistive technologies like screen readers.

• Missing alt text, which excludes people who cannot perceive content visually. 

• Keyboard accessibility issues, which affect people who navigate without a mouse.

• Excessive flashing or blinking content, which can trigger reactions in people with photosensitivity conditions.

It’s worth noting that POUR standards also apply to mobile content as well.

How EN 301 549 Differs from WCAG

WCAG was originally designed for web content. EN 301 549 goes further — it extends accessibility requirements to non-web ICT products and services, including software, hardware, self-service terminals, ATMs, and other electronic systems. This broader scope reflects the EAA’s wider reach beyond websites and apps, and is one of the key reasons EAA compliance involves more than aligning with web content standards alone.

How This Connects Back to the EAA

Bringing it all together: The EAA does not have its own technical checklist; instead, it mandates compliance with EN 301 549 to meet its accessibility requirements. More simply, organizations wanting to meet EAA compliance standards should use EN 301 549 as the operative standard. The POUR principles are the criteria that must be met in practice, and WCAG 2.2 Level AA serves as the underlying reference that shapes those criteria for web and digital content.

Left: How to COmply With the EAA & Web Accessibility Directive. Right: The 4 ways that will be explored next.

How to Comply with the EAA

 EAA compliance starts with building accessibility into digital products and content from the ground up. The POUR principles provide the framework for identifying and fixing accessibility issues and form the foundation for what the EAA requires organizations to meet.

Here’s how to get started.

1. Test Content Against POUR Principles

The first step in your journey to compliance is testing your existing content for alignment with POUR standards (which follow many of the success criteria included in WCAG 2.1 Level AA). You can use accessibility tools to help you meet POUR principles.

For example, common accessibility issues can be identified through automated testing. However, some accessibility issues — such as non-descriptive links or unhelpful alt text — cannot be detected solely by automation. To find more complex issues, you may need to use a team of human testers.

Free accessibility checkers (like this one from AudioEye) are a great starting point.

2. Fix Accessibility Issues

Once the audit results are in hand, the next step is to prioritize fixes. Starting with quick wins and straightforward issues before moving on to more complex remediation is generally the most efficient approach. For larger issues, a structured remediation plan helps minimize disruption to existing content and development workflows. For organizations navigating multiple issues across a large site or application, working with an accessibility expert can help sequence fixes effectively and maintain alignment with evolving requirements.

3. Build an Ongoing Testing and Fix Strategy

Accessibility compliance isn't a one-time project. New content, product updates, and technology changes can introduce barriers even after an initial remediation effort — which is why ongoing testing is essential for sustained compliance.

4. Publish an Accessibility Statement

An accessibility statement demonstrates an organization's commitment to accessibility and gives users information about the site's current state, testing tools, known barriers, and remediation goals. Accessibility statements should follow a standard format and are a requirement under both the Web Accessibility Directive and the EAA.