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European Accessibility Act: Ultimate Guide to Compliance

The European Union’s two digital accessibility laws, the Web Accessibility Directive and the European Accessibility Act, require digital content to meet key principles across both public and private sectors. Below, we’ll cover each law’s requirements, who must comply, and the risks of non-compliance

Author: Missy Jensen, Senior SEO Copywriter

Published: 03/10/2026

The European Union logo (a circle of 12 gold stars on a blue background) with a gold accessibility icon in the middle.

Currently, there are 87 million people in Europe living with a disability(opens in a new tab). As this number continues to grow as the population ages, the European Union (EU) has increased its focus on creating and enforcing digital accessibility laws. The European Accessibility Act(opens in a new tab) (EAA) is just one of the laws designed to increase accessibility and usability for people with disabilities.

Below, we’ll review what the EAA is, who it applies to, what the requirements are, and the benefits compliance has from both a business and user perspective.

What Is the European Accessibility Act (EAA)?

The European Accessibility Act (EAA) is legislation enforced by the European Union that requires many digital products and services (including websites, mobile apps, e-readers, and ticketing kiosks) to be accessible to people with disabilities. Its goal is to create a more inclusive environment, uniform accessibility rules across E.U. Member States, and ensure equal access to essential goods and services for all users, particularly those with disabilities.

The EAA’s June 2025 deadline required businesses operating in the EU to make their digital products and services accessible — keyboard-navigable websites, accessible device interfaces, and support for assistive technologies like screen readers. Since that deadline passed, meeting that bar is now the expectation.

Who Must Comply with the EAA?

The EAA applies to businesses selling covered products or services in the EU market, including non-EU businesses selling to EU customers. These sectors can include manufacturers, distributors, service providers, and even importers of specific products and services covered in the EAA(opens in a new tab).

These products and services may be digital (websites, apps), but can also apply to certain machines and hardware (ATMs, passenger transport).

What Products Are Covered by EAA?

To help you better understand who must comply with the new E.U. digital accessibility requirements, we’ve outlined some examples of products and services covered by the EAA.

Category

Examples of Covered Products / Services

Manufacturers

ATMs, ticket machines, self-service terminals, payment terminals, computers, tablets, laptops, smartphones, e-readers, e-books

Importers

Smartphones, tablets, laptops, payment terminals, and ATMs imported from outside the EU

Distributors

Retailers selling computers, e-readers, ATMs, payment terminals, telecom resellers providing smartphones/tablets

Service Providers

E-commerce websites & apps, online banking & mobile banking, telecom & VOIP services, passenger transport services (air, rail, bus, ferries), digital media/streaming platforms, e-books, online learning platforms

Keep in mind that this is not a comprehensive list of all applicable products and services, but rather serves as an overview of the EAA.

What the EAA means for U.S. Companies

If you’re a U.S.-based business that sells covered products or services in the EU, then you must comply with EAA accessibility standards. Failure to comply could result in fines, restricted market access, and damage to your company’s reputation. For example, if your business is headquartered in New York but you sell to EU customers, you must comply with the EAA.

EAA Exemptions

However, there are some exemptions to the EAA. Whether your business is based in the EU or outside of it, here’s how you may be exempt from EAA compliance:

  • You’re a service-based micro-enterprise with fewer than 10 employees.

  • Your annual turnover and/or your balance sheet is under 2 million euros.

  • You’ve signed a service contract before the June 2025 deadline that hasn’t yet expired.

Additionally, certain products or services may be exempt, including:

  • Self-service terminals already in use before the deadline may be able to continue operating as legacy products until the end of their economic life.

  • Any pre-recorded media published before the June 2025 deadline.

  • Archived website content updated before the June 2025 deadline.

Some companies are even able to claim exemption from specific requirements of the EAA if complying with them would impose a “disproportionate burden” on their business.

Keep in mind that this exemption operates on a case-by-case basis, and you should always check with each Member State to decide if any of these exemptions apply to you.

Think the EAA may apply to you? See how AudioEye can support EAA compliance for your business.

Next up: How EAA differs from the Web Accessibility Directive. 

A blue and gold map of the European Union, with a label that reads "The Web Accessibility Directive & the European Accessibility Act."

What is the Difference Between EAA vs. Web Accessibility Directive?

The primary difference between the EAA and the Web Accessibility Directive(opens in a new tab) (WAD) is that they apply to different sectors.

The WAD mainly applies to public sector bodies such as government, public universities, public hospitals, local authorities, and some publicly funded organizations. Additionally, this legislation is purely digital-focused, covering websites and mobile apps.

The EAA primarily applies to private-sector businesses, such as banks, e-commerce websites, telecom providers, transport services, and some manufacturers. Unlike the WAD, the EAA goes beyond digital, covering hardware and consumer services as well.

Here’s a quick side-by-side comparison of the EAA vs. WAD

Category

EAA

WAD

Who it applies to

Private businesses + manufacturers

Public sector bodies

What it covers

Products + digital services

Websites and mobile apps only

Compliance date

June 28, 2025

2019–2021 (phased)

Accessibility standard used

EN 301 549 (aligned with WCAG 2.1/2.2 AA)

EN 301 549 (aligned with WCAG 2.1 AA)

Enforcement

Market surveillance, fines, product withdrawal

National monitoring and complaint mechanisms

EAA and WCAG: Which Standard is Required for Compliance?

The EAA and WCAG are not the same. EAA is an accessibility directive in the E.U., while the Web Content Accessibility Guidelines(opens in a new tab) (WCAG)is a global standard that provides technical guidance for digital accessibility.

WCAG was developed by the World Wide Web Consortium (W3C) in 1999, and has since been adopted by governments across the world to help make digital content accessible to people with disabilities.

But do you have to comply with WCAG standards to comply with the EAA?

Not directly — but in practice, yes.

The EAA requires organizations to follow POUR principles, meaning content must be perceivable, operable, understandable, and robust. To meet these principles, EU Member States reference EN 301 549, an EU-specific accessibility standard that serves as the technical framework for meeting those principles. For digital content specifically, EN 301 549 incorporates WCAG 2.1 Level AA(opens in a new tab) as its baseline, with WCAG 2.2 considered best practice.

Because the EAA extends beyond digital content to hardware and physical interfaces like ATMs and kiosks, EN 301 549 functions as an umbrella standard, covering WCAG for digital requirements, plus additional criteria for non-digital products.

The bottom line: the EAA enforces POUR principles. EN 301 549 enforces WCAG. Businesses that meet WCAG 2.1 Level AA requirements will satisfy EN 301 549’s digital requirements and be well-positioned for EAA compliance.

Here’s a clear list of key WCAG compliance requirements, organized by the four POUR principles (Perceivable, Operable, Understandable, Robust) and aligned with Level AA:

Principle

Key Requirements

Perceivable

Text alternatives, captions, sufficient contrast, resizable text, and no flashing content

Opereable

Keyboard access, enough time, clear navigation, and focus indicators

Understandable

Clear language, consistent navigation, predictable behavior, and helpful instructions/errors

Robust

Assistive tech compatibility, proper HTML/ARIA, and cross-device support

EAA Key Compliance Deadlines

The EAA compliance deadline was June 28, 2025. 

After this date, new services or products placed on the market were required to comply with EAA requirements.

However, a transitional period exists for certain products or services placed on the market before the June 2025 deadline, and may even extend into the end of the decade. This exemption primarily exists for legacy products such as ATMs or other self-service machines that have a longer economic life.

While the EAA compliance deadline has passed, there’s one universal truth for all companies covered by the EAA: ongoing compliance is critical for avoiding penalties.

Penalties for Non-Compliance

EAA penalties for non-compliance can range from written warnings to hefty fines for your business. 

For example, say a large travel company launches a website and app in the EU without making them accessible.

Authorities may issue enforcement notices, restrict market access, and impose penalties on the company in severe cases. Meanwhile, customers with disabilities cannot use the service, leading to complaints, negative publicity, and costly fixes. 

Because the EAA itself doesn’t offer a single EU‑wide fine structure, enforcement and penalties will vary by country. Here’s an overview of some additional penalties for EAA violations:

  • Financial fines (one-time or ongoing)

  • Revenue-based penalties (dependent on country)

  • Product withdrawal or sales bans 

  • Corrective orders and audits

  • Public disclosure, leading to reputational damage

  • Legal action or criminal sanctions (serious or repeated violations)

The good news: Early accessibility planning helps you avoid these EAA non-compliance risks.

How to Comply with EAA: Your Step-by-Step Compliance Checklist

EAA compliance requires businesses to ensure their digital products and services are accessible to people with disabilities. The process starts with understanding the POUR principles, which provide the technical framework for identifying and resolving accessibility barriers. 

Here’s a step-by-step breakdown of what EAA compliance looks like in practice:

Step 1: Audit Your Existing Content

Conduct a full accessibility audit across all covered products and services. Effective audits combine automated testing tools, expert testing, and assistive technology simulations (e.g., screen readers, keyboard-only navigation, magnifiers) to surface issues that automation alone can’t catch. Document every gap and prioritize fixes by user impact.

Step 2: Evaluate Findings and Implement Fixes

Work through your findings systematically. Common fixes include adding alt text for images and buttons, providing captions for video content, ensuring keyboard navigability, and improving color contrast. Test across multiple devices, browsers, and assistive technologies as you go. Additionally, don’t wait until all fixes are done to test that they’re working.

Step 3: Validate with Real Users

Before releasing products or services in the EU market, conduct usability testing with people with disabilities. This step catches additional barriers that may have been missed in initial testing, and it’s the most reliable signal that your digital experience works as intended for the widest range of users.

Step 4: Document, Monitor, and Maintain

Accessibility is not a one-time project. Maintain records or audits, fix efforts, and accessibility practices. Review accessibility with every product or service update, and train staff on both the technical standards and the reasoning behind them. Ongoing monitoring is what separates compliant organizations from those that quietly fall out of compliance after the initial push.

Start Building for EAA Compliance with AudioEye

The EAA sets a high bar, but meeting doesn’t have to be overwhelming. AudioEye helps you audit, monitor, and fix digital content to meet accessibility standards, so you can reduce compliance risk and build more accessible experiences for every user.

If you’re ready to take the next step toward full EAA compliance, book a demo with AudioEye today.

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