EU European Accessibility Act 2025: What Website Owners Need to Know

# EU European Accessibility Act 2025: What Website Owners Need to Know

The European Accessibility Act (EAA) became enforceable across all EU member states on June 28, 2025. If you sell products or services to customers in the European Union, this regulation likely applies to you, and non-compliance carries real financial penalties. Unlike earlier EU directives that primarily targeted government websites, the EAA extends accessibility requirements to the private sector, covering e-commerce platforms, banking services, telecommunications, and a wide range of digital products and services.

This guide explains what the EAA requires, which businesses fall within its scope, how it relates to WCAG standards, and the concrete steps you should take to comply.

What Is the European Accessibility Act?

The European Accessibility Act (Directive 2019/882) is an EU directive adopted in 2019 that establishes common accessibility requirements for a defined set of products and services. Each EU member state was required to transpose the directive into national law by June 28, 2022, with enforcement beginning on June 28, 2025.

The EAA is not a regulation that applies directly across the EU from Brussels. Instead, each member state has enacted its own national law implementing the directive's requirements. This means the specific enforcement mechanisms and penalties vary by country, but the core accessibility requirements are harmonized across the entire EU.

The directive's goal is to remove fragmentation in accessibility regulation across member states and create a consistent framework that improves market access for people with disabilities while reducing compliance complexity for businesses operating across borders.

Who Must Comply With the EAA?

The EAA applies to economic operators that place products on the EU market or provide services to EU consumers. The scope covers:

Products

Computers and operating systems
Self-service terminals (ATMs, ticketing machines, check-in kiosks)
Consumer telecommunication equipment (smartphones, tablets)
E-readers
Routers and modems

Services

E-commerce services (any website or app where consumers can purchase products or services online)
Electronic communications services
Services providing access to audiovisual media
Passenger transport services (air, bus, rail, waterborne) including websites and mobile apps for booking and ticketing
Banking and financial services for consumers
E-books and dedicated software

If your business operates an e-commerce website that sells to EU customers, you are within scope regardless of where your company is headquartered. A US-based online retailer shipping to Germany or a UK-based SaaS company with EU subscribers is subject to the EAA through the national laws of the member states where their customers reside.

Microenterprise Exemption

The EAA provides a limited exemption for microenterprises providing services. Under EU definitions, a microenterprise has fewer than 10 employees and annual turnover or balance sheet total not exceeding 2 million euros. Microenterprises that provide covered services are encouraged but not legally required to meet the EAA requirements. This exemption does not apply to product manufacturers regardless of size.

What Are the Technical Requirements?

The EAA does not prescribe a specific technical standard in the directive text itself. Instead, it defines functional accessibility requirements that products and services must meet. In practice, the European Commission has designated the harmonized European standard EN 301 549 as the presumption-of-conformity standard for the EAA.

EN 301 549 directly incorporates WCAG 2.1 Level AA for web content. This means that if your website conforms to WCAG 2.1 AA, you are substantially aligned with the EAA's technical requirements for web-based services.

The key accessibility requirements in the EAA include:

Perceivability: Information and user interface components must be presentable in ways all users can perceive. This includes providing text alternatives for non-text content, captions for audio, and sufficient color contrast.
Operability: Users must be able to navigate and interact with the interface using various input methods including keyboard, voice, and assistive devices.
Understandability: Content and navigation must be clear and predictable. Forms should provide clear instructions and error messages.
Robustness: Content must be compatible with assistive technologies and different user agents, including screen readers and magnification software.

These map directly to the four WCAG principles (POUR), which is not a coincidence. WCAG has been the de facto global web accessibility standard for over a decade, and the EU standards framework deliberately aligns with it.

How the EAA Differs From the Web Accessibility Directive

You may already be familiar with the EU Web Accessibility Directive (Directive 2016/2102), which required public sector websites and mobile applications to be accessible starting in 2019-2020. The EAA is a separate directive with a different and broader scope.

The Web Accessibility Directive applies to public sector bodies: government websites, public university sites, and public institution digital services. The EAA applies to the private sector across the specific product and service categories listed above.

If your organization is a private company, the Web Accessibility Directive probably did not apply to you. The EAA almost certainly does, assuming you provide covered services to EU consumers.

Penalties for Non-Compliance

Enforcement and penalties are determined at the national level by each EU member state. The EAA requires member states to establish "effective, proportionate, and dissuasive" penalties. While the specific penalty structures vary, they typically include:

Administrative fines that can reach significant amounts depending on the member state. Several countries have established fine structures ranging from thousands to hundreds of thousands of euros.
Market surveillance actions that can restrict or prohibit the sale of non-compliant products within the member state.
Consumer complaints and legal actions brought by individuals or disability advocacy organizations under national implementation laws.

Germany, France, the Netherlands, and several other member states have already begun active enforcement. Market surveillance authorities can request documentation demonstrating compliance, conduct inspections, and impose corrective actions.

Steps to Comply With the EAA

Step 1: Determine If You Are in Scope

Review the list of covered products and services. If you operate an e-commerce website, provide banking services, sell digital content, or offer any of the other covered services to EU consumers, you are in scope unless you qualify for the microenterprise exemption.

Step 2: Audit Your Current Accessibility Status

Run a comprehensive accessibility audit against WCAG 2.1 Level AA. Start with an automated scan to identify the most common violations, then supplement with manual testing including keyboard navigation and screen reader verification.

AccessGuard's free scanner can give you an immediate baseline assessment of your WCAG 2.1 compliance status. The scan identifies specific violations, maps them to WCAG success criteria, and provides remediation guidance.

Step 3: Remediate and Prioritize

Address critical and serious violations first: missing alternative text, broken keyboard navigation, missing form labels, and insufficient color contrast. These are the issues most likely to block users entirely and the ones regulators will focus on during enforcement actions.

Step 4: Document Your Compliance Efforts

The EAA requires economic operators to be able to demonstrate compliance. Maintain records of your accessibility audits, the issues identified, remediation actions taken, and your ongoing monitoring practices. This documentation is essential if a market surveillance authority or consumer requests evidence of compliance.

Step 5: Establish Ongoing Monitoring

Accessibility is not a one-time fix. Every code deployment, content update, and design change can introduce new barriers. Schedule regular automated scans and periodic manual audits to maintain compliance over time.

AccessGuard's Pro plan provides scheduled weekly scans, historical trend reporting, and exportable compliance reports that serve as documentation for regulatory purposes. Ongoing monitoring is the only reliable way to prevent regression and demonstrate continuous compliance.

The EAA and Non-EU Businesses

If your business is based outside the EU but provides covered services to EU consumers, you are subject to the EAA through the national laws of the member states where your customers are located. The directive applies based on where the service is consumed, not where the provider is established.

This means US, UK, and other non-EU businesses with EU-facing websites need to comply. The practical approach is the same: align with WCAG 2.1 AA, document your compliance, and monitor continuously.

Start Your EAA Compliance Assessment Today

The enforcement deadline has already passed. If you have not assessed your website's accessibility, the time to act is now. Run a free AccessGuard scan to identify your current WCAG 2.1 violations and get a clear picture of the remediation work ahead. For ongoing compliance monitoring and audit-ready documentation, explore AccessGuard's pricing plans.