Guide
European Accessibility Act (EAA) Compliance Guide
Everything web agencies need to know about EAA compliance in 2026. Updated with the latest enforcement data.
What is the European Accessibility Act?
The European Accessibility Act (EAA), formally Directive 2019/882, is an EU law requiring digital products and services to be accessible to people with disabilities. It came into force on 28 June 2025 across all EU member states.
The EAA mandates compliance with EN 301 549, which references WCAG 2.1 Level AA as the technical standard for web accessibility.
Who must comply?
All businesses that sell digital products or services to consumers in the EU, except:
- Microenterprises — fewer than 10 employees AND annual turnover under EUR 2 million (for services only)
- The exemption does not apply to physical products (hardware), only services
Covered sectors include: e-commerce, banking and financial services, electronic communications, transport ticketing, e-books, and audiovisual media.
What are the fines?
Fines vary by EU member state. Here are the key ones:
| Country | Maximum Fine | Notable |
|---|---|---|
| Germany | EUR 100,000 | BFSG — Barrierefreiheitsstärkungsgesetz |
| Sweden | 10,000,000 SEK (~EUR 900K) | PTS auditing 28+ e-commerce companies |
| France | EUR 250,000 | Public "name and shame" of non-compliant companies |
| Ireland | EUR 200,000 | Only EU state with criminal penalties |
| Spain | EUR 600,000 | Escalating fines for repeat violations |
Sources: WebYes EAA Fines 2025, Deque EAA Enforcement
What does WCAG 2.1 AA require?
The 50 success criteria of WCAG 2.1 AA are organised under four principles (POUR):
Perceivable
All images have alt text. Videos have captions. Sufficient colour contrast (4.5:1 ratio).
Operable
Full keyboard navigation. No time limits without extension. No flashing content (>3 per second).
Understandable
Clear form labels and error messages. Consistent navigation. Language declared in HTML.
Robust
Valid HTML. ARIA attributes used correctly. Works with assistive technologies.
The most common violations
According to WebAIM's 2025 analysis of 1 million homepages, the six most common issues account for 96% of all detected errors:
- Low contrast text — 79.1% of pages (contrast ratio below 4.5:1)
- Missing image alt text — 55.5% of pages
- Missing form input labels — 48.2% of pages
- Empty links — 45.4% of pages (links with no text)
- Empty buttons — 29.6% of pages
- Missing document language — 15.8% of pages
Why overlays don't work
Accessibility overlay widgets (JavaScript plugins that claim to "fix" accessibility automatically) have been widely discredited:
- The FTC fined accessiBe $1 million in April 2025 for deceptive claims about their AI-powered overlay — Source: FTC
- 22.6% of accessibility lawsuits in 2025 targeted websites using overlay widgets — Source: UsableNet
- UserWay is facing a class-action lawsuit from BloomsyBox (filed July 2024) for breach of contract after their overlay failed to prevent an ADA lawsuit
How to achieve compliance
- Automated scanning — Tools like WCAGAlert detect ~57% of WCAG issues automatically. Start here to find the most common problems.
- Fix the code — Address issues at the source. Add alt text, fix contrast, add form labels. These are typically simple HTML changes.
- Manual testing — Test with keyboard navigation and a screen reader (NVDA, VoiceOver). This catches the remaining ~43% of issues.
- Ongoing monitoring — Accessibility is not a one-time fix. New content, updates, and changes can introduce new issues. Monitor continuously.
Check your clients' websites now
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