The European Accessibility Act (EAA) is the most significant web accessibility regulation to hit the EU since the original Web Accessibility Directive. With enforcement beginning in June 2025 — and now fully active in 2026 — the EAA extends accessibility requirements to a much broader range of products and services than previous legislation covered.
If your business sells products or services in the European Union, your website almost certainly needs to comply. This guide covers everything you need to know: deadlines, scope, technical standards, penalties, and the step-by-step path to compliance.
Table of Contents
What Is the European Accessibility Act?
The European Accessibility Act (Directive 2019/882) is an EU law that sets common accessibility requirements for products and services across the European Union. Unlike the earlier Web Accessibility Directive (which applied only to public sector websites), the EAA covers private-sector products and services sold in the EU.
The EAA is designed to:
- Harmonize accessibility standards across all 27 EU member states
- Remove barriers for the estimated 100+ million EU citizens with disabilities
- Create a single market for accessible products and services
- Ensure that digital services — including websites, mobile apps, and e-commerce — are usable by everyone
Member states had until June 28, 2022, to transpose the directive into national law. The compliance deadline for most businesses is June 28, 2025 — which means enforcement is already active in 2026.
Key Deadlines — Is It Too Late?
The EAA's compliance timeline is already in effect. Here's where things stand as of mid-2026:
began
into national law
until June 2028
If your website isn't accessible yet, you're already past the compliance deadline. However, enforcement is rolling out gradually. Member states are prioritizing their enforcement infrastructure — market surveillance authorities, complaint mechanisms, and penalty frameworks. This creates a brief window where proactive compliance can still avoid penalties.
Key dates to know:
- June 28, 2025 — EAA compliance deadline for most businesses (already passed)
- June 28, 2028 — Extended deadline for micro-enterprises (fewer than 10 employees and turnover under €2M)
- Ongoing — Member states are standing up enforcement bodies throughout 2025–2027
Who Must Comply (and Who's Exempt)
In Scope
The EAA applies to the following services when they're offered in the EU:
- E-commerce websites and apps — any online store, marketplace, or booking platform
- Banking services — retail banking websites, mobile banking apps, online account management
- E-books and digital reading services — platforms selling or distributing digital publications
- Transport services — airline, rail, bus, and ferry booking websites
- Telecommunications services — phone, internet, and messaging service portals
- Audio-visual media services — streaming platforms, on-demand video services
- Emergency services — access to 112 (EU emergency number) communication
The following products must also comply:
- Computer hardware and operating systems
- Self-service terminals (ATMs, ticketing machines, check-in kiosks)
- Smartphones and tablets
- TV equipment and set-top boxes
- E-book readers
Key — Even US-Based Companies
If your business is based in the US or anywhere outside the EU but sells products or services to EU customers, the EAA applies to you. This is one of the most commonly overlooked requirements. Many US SaaS companies serving European customers are currently non-compliant without realizing it.
Exemptions
- Micro-enterprises (fewer than 10 employees and annual turnover/balance sheet under €2M) have until June 2028
- Disproportionate burden — compliance that would fundamentally alter a product or impose significant cost can be claimed, but this must be documented and reassessed periodically
- Security and safety — accessibility requirements that would compromise critical security features
Technical Standards: EN 301 549 and WCAG 2.2 AA
The EAA doesn't specify WCAG directly. Instead, it references EN 301 549 (the European standard for ICT accessibility), which in turn references WCAG 2.1 Level AA as its baseline. However, most member states and market surveillance authorities are now interpreting this as WCAG 2.2 AA compliance, since EN 301 549 has been updated to include WCAG 2.2 criteria.
In practice, this means your website should meet WCAG 2.2 Level AA — covering approximately 50 success criteria across four principles:
- Perceivable — Information must be presented in ways users can perceive (alt text, captions, adaptable content)
- Operable — Interface components must be operable (keyboard navigation, sufficient time, predictable behavior, input assistance)
- Understandable — Information and interface must be understandable (readable text, predictable behavior, input assistance)
- Robust — Content must be robust enough to be interpreted by current and future assistive technologies
WCAG 2.2 added several new Success Criteria relevant to EAA enforcement:
- 2.4.11 Focus Not Obscured (AA) — focused elements must not be fully hidden by other content (e.g., sticky headers)
- 2.4.12 Focus Not Obscured (AAA) — stricter version requiring no part of the focused element to be hidden
- 2.5.7 Dragging Movements (AA) — drag-and-drop operations must have a single-pointer alternative
- 2.5.8 Target Size (AA) — interactive targets must be at least 24×24 CSS pixels
- 3.2.6 Consistent Help (A) — help mechanisms must be consistently placed
- 3.3.7 Accessible Authentication (A) — cognitive function tests (like CAPTCHAs that require memorization) must have alternatives
Penalties for Non-Compliance
Each EU member state establishes its own penalty framework. While the directive sets minimum requirements, individual countries have significant discretion. The consequences can include:
- Fines — These vary by member state but can reach up to 2% of annual revenue in some jurisdictions. Germany has signaled substantial fines for repeat offenders.
- Market restrictions — Products or services found to be non-compliant can be removed from the market or have their sale restricted.
- Complaint-driven enforcement — Unlike ADA lawsuits in the US (which are plaintiff-driven), EAA enforcement is primarily handled by national market surveillance authorities. However, consumer complaints can trigger investigations.
- Reputational damage — Non-compliant companies may be publicly listed by enforcement authorities. Several EU countries maintain public registries of inaccessible services.
One critical difference from the US: EAA enforcement is done by government bodies, not private lawsuits. But the downside is that the EAA covers more services, and non-compliance can eventually bar you from the European market entirely.
How Will Enforcement Work?
Each member state has designated one or more market surveillance authorities to enforce EAA requirements. These bodies can:
- Conduct random compliance audits of websites and services
- Respond to complaints from users or competitor organizations
- Request documented proof of accessibility efforts
- Issue compliance orders with binding deadlines
- Impose financial penalties for continued non-compliance
Documentation matters. Having a documented accessibility audit — with a clear list of issues and a remediation plan — can demonstrate good-faith compliance efforts. An audit report serves as evidence that you've assessed your site and are working toward compliance, which can influence enforcement decisions.
EAA Compliance Checklist for Websites
Use this checklist to assess your website's readiness for EAA enforcement. Each item corresponds to WCAG 2.2 AA requirements that EN 301 549 incorporates.
Phase 1: Automated Scan (Day 1)
Run an automated WCAG scan on your homepage
Use a free scanner like our Accessibility Audit Scanner — it checks 16 WCAG 2.2 checkpoints including color contrast, image alt text, form labels, heading structure, and keyboard navigation indicators. Get your baseline score in 30 seconds.
Scan your top 5 most visited pages
EAA enforcement looks at your entire service, not just the homepage. Scan checkout flows, login pages, account management, and product pages — these are where users encounter barriers.
Document your current score and issue count
Record the number of critical issues, warnings, and informational findings. This becomes your baseline for tracking progress and demonstrating good-faith compliance efforts.
Phase 2: Critical Fixes (Week 1-2)
Fix color contrast failures
WCAG 2.2 AA requires 4.5:1 contrast ratio for normal text and 3:1 for large text. This is the most common failure — automated scans typically find 3-10 contrast violations on most commercial websites.
Add missing alt text to images
Every information-carrying image needs descriptive alt text. Decorative images should have alt="" (empty alt). This is a Perceivable failure under WCAG 1.1.1 and one of the easiest to fix.
Label all form fields
Every input, select, and textarea must have an associated label — either a visible <label> element, an aria-label, or an aria-labelledby reference. Unlabeled fields are a critical WCAG 1.3.1 failure and block screen reader users from completing purchases.
Ensure keyboard navigation works
All interactive elements must be reachable and operable via keyboard alone. Check for keyboard traps (elements that capture focus without releasing it), missing tabindex on custom controls, and focus indicators that are visible during keyboard navigation.
Phase 3: WCAG 2.2 Additions (Week 3-4)
Check touch target sizes (2.5.8)
Since EAA enforcement references WCAG 2.2, any interactive target smaller than 24×24 CSS pixels is non-compliant. This commonly affects mobile navigation icons, small buttons, and inline links.
Verify focus indicators aren't hidden (2.4.11)
Sticky headers and cookie banners can obscure focused elements. Test that keyboard-focusable elements remain visible when they receive focus, even with sticky positioning.
Provide alternatives to drag-and-drop (2.5.7)
If your service uses drag-and-drop interactions (file uploads, list reordering, kanban boards), provide a single-click or button-based alternative. This is a new WCAG 2.2 AA requirement.
Replace cognitive CAPTCHAs (3.3.7)
If your login or form submission uses CAPTCHAs that require pattern recognition, image identification, or memorization, provide an alternative like email verification or WebAuthn. Cognitive CAPTCHAs fail the new Accessible Authentication criterion.
Phase 4: Documentation and Ongoing Compliance
Create an accessibility statement
EU member states are expected to require an accessibility statement on EAA-scope services, similar to the public-sector requirement. Include your current compliance level, any inaccessible content, and a contact mechanism for reporting issues.
Document your compliance process
If you need to claim disproportionate burden for any criterion, document your assessment: cost estimation, benefit to users, comparison against total development budget, and a reassessment schedule. This documentation can shield you from penalties.
Schedule quarterly re-audits
Accessibility isn't a one-time fix. New content, features, and third-party integrations can introduce new issues. A quarterly automated audit keeps you compliant and provides a continuous improvement record for enforcement bodies.
How to Get Started Today
The EAA compliance deadline has already passed, but proactive action still matters. Here's the fastest path to compliance:
- Scan your site free — Use the Accessibility Audit Scanner to check any URL against 16 WCAG 2.2 AA checkpoints. No account required, results in seconds.
- Identify critical failures — Focus on color contrast, missing alt text, unlabeled forms, and keyboard traps first. These represent the majority of WCAG failures and the most common enforcement triggers.
- Get a professional audit — For a comprehensive assessment with per-element issue mapping and fix recommendations, order a Basic Audit ($249) or Full Site Audit ($499). You'll receive a styled PDF report with every finding mapped to the exact page element.
- Document everything — Save your audit reports, remediation records, and accessibility policies. In the event of an enforcement inquiry, documented good-faith compliance efforts can significantly reduce penalties.
Run Your Free EAA Compliance Scan Now
Check any URL against WCAG 2.2 AA — the same standard referenced by EN 301 549 for EAA compliance. Free, no account, no credit card.
Scan Your Site Free →Disclaimer: This article provides general guidance on the European Accessibility Act and is not legal advice. Consult with legal counsel familiar with accessibility law in your specific EU member state for compliance requirements.