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, such as contractors hired to create online portals for the websites of EU member states. Private companies are not covered.

Key features of the directive include:

• Public sector websites and apps are measured against EN 301 549, the European accessibility standard, which incorporates WCAG Level AA.

• 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 public sector websites and mobile apps. 

The Directive was rolled out in phases after its 2016 enactment: new public sector websites had to comply by September 23, 2019, existing websites by September 23, 2020, and mobile apps by June 23, 2021.

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? Unlike the Web Accessibility Directive, which applies only to the public sector, the EAA applies to private businesses that provide covered products and services to consumers in the EU. That includes:

• E-commerce sites and apps selling to EU consumers

• Banks and other consumer financial service providers

• Passenger transport providers (air, bus, rail, and water), including their websites, apps, e-tickets, and travel information

• Telecom and electronic communications providers

• Streaming and audiovisual media services

• E-book publishers and e-reader software providers

• Manufacturers of computers, smartphones, e-readers, and self-service terminals like ATMs, ticket machines, and check-in kiosks

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 exception; market access is.

The sectors most affected are e-commerce, SaaS, fintech, media streaming, and travel, since these industries typically serve cross-border EU customers through digital channels.

Exemptions

The EAA has limited exemptions. Micro-enterprises that provide services are exempt if they have fewer than 10 employees and either an annual turnover or a balance sheet total of €2 million or less. The exemption doesn't cover products, so a micro-enterprise that manufactures or sells covered products still has obligations. The EAA encourages exempt businesses to make their services accessible anyway.

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 enforcement deadline was June 28, 2025. As of that date, all organizations covered by the EAA, including non-EU businesses selling into the EU, must meet its accessibility requirements. It's important to note that compliance is ongoing: any new or updated digital product, service, or content released after the deadline must also conform.

However, 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 adopted. The European Parliament and Council adopted the EAA as Directive (EU) 2019/882 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.

June 28, 2025 wasn't the final deadline for everyone. The EAA includes transition periods for some existing services and equipment:

• Until June 28, 2030: Service providers can keep using products that were lawfully in use before June 28, 2025 to deliver their services. Service contracts signed before that date can continue unchanged until they expire, for up to five years.

• Up to 20 years: Self-service terminals like ATMs and ticket machines that were in use before June 28, 2025 can stay in service until the end of their useful life, but no longer than 20 years after they were first put into use.

New products and services launched after June 28, 2025 get no transition period. They must comply from day one.

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, and 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)(downloads a file). 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. For web content, EN 301 549 incorporates WCAG 2.1 Level AA, which is built on four 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, WCAG, and the EAA Fit Together

The EAA doesn’t include its own technical checklist. Instead, EN 301 549 serves as the reference standard for meeting its accessibility requirements. WCAG covers web content only, while EN 301 549 is broader, covering websites, software, hardware, and self-service terminals. For web content, EN 301 549 incorporates WCAG 2.1 Level AA, so a website that meets WCAG 2.1 AA meets the core web requirements most organizations face under the EAA.

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 2.1 Level AA serves as the underlying reference that shapes those criteria for web and digital content. EN 301 549 v4.1.1, published in September 2026, moves that reference to WCAG 2.2, but it is not yet the legal reference for EAA compliance.

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). 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. AudioEye, for example, pairs continuous automated monitoring with expert testing by certified testers using assistive technology, so EAA conformance is checked as content changes rather than once a year.

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. Public sector bodies must publish a formal accessibility statement under the Web Accessibility Directive. Under the EAA, service providers must publish information explaining how their services meet accessibility requirements. A clear statement is a practical way to cover both.