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The European Accessibility Act is Now in Effect — What You Need to Know

On June 28, 2025, the European Accessibility Act (EAA) became enforceable across all EU member states. This landmark regulation requires that digital products and services — including websites, mobile apps, e-commerce platforms, and online banking — meet the WCAG 2.1 Level AA accessibility standard.

What is the European Accessibility Act?

The EAA (Directive 2019/882) was adopted in 2019 and gave member states until June 2025 to transpose it into national law. Unlike the Web Accessibility Directive, which only applied to public sector websites, the EAA extends to private sector businesses that provide products or services to EU consumers.

The scope is broad. It covers:

  • E-commerce websites and apps
  • Banking and financial services
  • Telecom services
  • Transport ticketing and check-in systems
  • E-books and e-readers
  • Operating systems and hardware

Who needs to comply?

Any business offering covered products or services to consumers in the EU must comply, regardless of where the business is headquartered. There is a micro-enterprise exemption for companies with fewer than 10 employees and annual turnover under EUR 2 million, but this exemption is narrow and does not apply to businesses that are part of larger groups.

If you run an agency with clients who sell to EU consumers, those client websites need to comply. This makes accessibility a business-critical concern, not a nice-to-have.

What are the penalties?

Each EU member state sets its own enforcement mechanism and penalties. Here are some examples:

  • Germany (BFSG): Fines up to EUR 100,000 per violation. The market surveillance authority can order products and services to be withdrawn.
  • Sweden (PTS): The Post and Telecom Authority has already begun auditing 28 e-commerce companies for compliance.
  • France: Fines up to EUR 50,000 per violation, with potential criminal liability for repeated offenders.

The penalty structure is intentionally similar to GDPR — significant enough to make non-compliance a financial risk.

What does WCAG 2.1 AA require?

WCAG 2.1 Level AA is the technical standard referenced by the EAA. It requires websites to be:

  • Perceivable: All content must be presented in ways users can perceive — alt text for images, captions for video, sufficient colour contrast.
  • Operable: All functionality must work with a keyboard. No content should cause seizures. Users must have enough time to read and interact.
  • Understandable: Text must be readable. Forms must have clear labels and error messages. Navigation must be consistent.
  • Robust: Content must work with assistive technologies like screen readers and be compatible with current and future user tools.

How to prepare

If you have not started yet, here is a practical path forward:

  1. Audit your current state. Use automated scanning to identify the most common violations — missing alt text, contrast issues, form labels, keyboard traps. Automated tools catch roughly 57% of WCAG issues.
  2. Fix critical and serious issues first. Prioritize by impact. A missing skip-to-content link affects every keyboard user on every page.
  3. Set up ongoing monitoring. Accessibility is not a one-time project. Code changes, content updates, and third-party widgets can introduce new issues at any time.
  4. Plan for manual testing. Automated scanning cannot catch everything. Test with keyboard navigation, screen readers, and real users with disabilities.

The EAA is not going away, and enforcement will only increase. The businesses that treat accessibility as a continuous practice — rather than a checkbox — will be the ones that avoid fines and build better products for everyone.

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