The European Accessibility Act (EAA) came into force on June 28, 2025. Unlike the Web Accessibility Directive — which applied only to public sector websites — the EAA targets the private sector. If your business sells products or services to consumers in the European Union and you meet the thresholds below, your website and digital interfaces are now subject to legally enforceable accessibility requirements.
With enforcement now underway across EU member states, organizations that haven't yet assessed their accessibility posture are behind. This guide covers exactly what the EAA requires, who it applies to, what the technical standards look like, and how to prepare.
What Is the European Accessibility Act?
The EAA (Directive 2019/882/EU) is a harmonization directive — it sets a common floor of accessibility requirements across all EU member states, replacing the patchwork of national laws that previously applied. Before the EAA, a business operating in Germany, France, and Poland faced three different legal frameworks for digital accessibility. The EAA creates one.
The directive is not a technical standard itself. Instead, it mandates that products and services meet accessibility requirements, and it designates technical standards — primarily EN 301 549 — as the means of demonstrating conformance.
How the EAA Differs from WCAG
You've likely heard of WCAG (Web Content Accessibility Guidelines), published by the W3C. WCAG is a technical specification, not a law. The EAA is a law that references technical standards.
The relationship is:
- EAA → legal requirement to make digital services accessible
- EN 301 549 → EU harmonized standard that specifies how to be accessible
- WCAG 2.2 Level AA → the web-specific technical criteria that EN 301 549 incorporates by reference for websites and mobile applications
In practical terms, if your website conforms to WCAG 2.2 AA, you're meeting the technical requirements of EN 301 549, which demonstrates compliance with the EAA. WCAG 2.2 AA is the technical target.
Who Must Comply?
The EAA applies to private sector businesses placing products or services on the EU market. However, it includes a micro-enterprise exemption:
You must comply if you:
- Offer services to consumers in the EU (regardless of where you are headquartered), AND
- Have 10 or more employees, OR
- Have an annual turnover exceeding €2 million
You are exempt if you are:
- A microenterprise: fewer than 10 employees AND annual turnover or balance sheet below €2 million
The exemption is narrow. Most established businesses — including SaaS companies, e-commerce platforms, financial services providers, and digital marketplaces serving EU consumers — fall within scope.
Sectors specifically covered by the EAA include:
- E-commerce (online retail, marketplaces)
- Banking and financial services (consumer banking apps, payment interfaces)
- Transportation (booking platforms, ticketing)
- Consumer electronics (computers, smartphones, TVs)
- Telecommunications
- E-books and e-book reading software
- Audiovisual media services (streaming platforms)
What the EAA Requires
The EAA requires that covered products and services are accessible to persons with disabilities. For websites and web applications, this translates to concrete technical requirements under WCAG 2.2 AA, organized under four principles:
Perceivable
Content must be presentable in ways users can perceive, regardless of disability. This includes:
- Text alternatives for all non-text content (images, icons, charts)
- Captions for all video content (prerecorded and live)
- Sufficient color contrast (minimum 4.5:1 for normal text, 3:1 for large text)
- Content that doesn't break when text size is increased to 200%
- No reliance on color alone to convey information
Operable
UI components and navigation must be operable by all users. This includes:
- All functionality accessible via keyboard (no mouse-only interactions)
- No keyboard traps — focus must be navigable through all interactive elements
- Skip navigation links for keyboard users to bypass repetitive content
- Sufficient time to read and use content (no auto-advancing carousels without controls)
- No content that flashes more than three times per second (seizure risk)
- Visible focus indicators on all interactive elements
Understandable
Content and interfaces must be understandable. This includes:
- Page language declared in the HTML
- Consistent navigation across pages
- Error identification that describes what went wrong and how to fix it
- Labels for all form inputs
Robust
Content must be robust enough to be interpreted by assistive technologies. This includes:
- Valid HTML with correct use of ARIA roles and attributes
- Name, role, and value exposed for all UI components
- Status messages programmatically determinable without receiving focus
EN 301 549: The Harmonized European Standard
EN 301 549 is the European standard that the EAA points to for technical conformance. It incorporates WCAG 2.2 AA for web content and extends requirements to:
- Non-web documents (PDFs, Word documents available for download)
- Mobile applications (iOS, Android)
- Software applications
- Hardware products (terminals, kiosks, ATMs)
For most organizations focused on their website and web application, the operative content is the WCAG 2.2 AA criteria incorporated into EN 301 549 Chapters 9 (web) and 10 (non-web documents).
Key Requirements Checklist
Use this as a rapid self-assessment before a full audit:
- All images have descriptive alt text (or empty alt for decorative images)
- All form inputs have associated labels (not just placeholder text)
- Color contrast meets WCAG 4.5:1 for body text, 3:1 for large text and UI components
- Site is fully navigable by keyboard alone, in a logical tab order
- No keyboard traps anywhere in the interface
- Focus indicator is visible on all interactive elements
- Videos have accurate closed captions
- Error messages identify the specific error and how to correct it
- Page language is set in the
<html lang="">attribute - ARIA landmarks used to identify page regions (header, main, nav, footer)
- Interactive components expose correct name, role, and value to screen readers
- PDFs and downloadable documents are tagged for accessibility
- Mobile application (if applicable) meets equivalent criteria
- Accessibility statement published on your website
- Feedback mechanism in place for users to report accessibility barriers
Penalties
Penalties are set by individual member states and vary considerably. The directive requires that penalties be "effective, proportionate and dissuasive." In practice:
- Germany: Fines up to €100,000 for serious violations; enforcement by market surveillance authorities
- France: Administrative fines; class actions possible through disability advocacy organizations
- Italy: Fines and potential market withdrawal orders
- Netherlands: Fines and corrective orders from the Autoriteit Consument & Markt
Beyond fines, the EAA creates private rights of action in many jurisdictions — meaning disabled users and advocacy organizations can pursue legal action directly against non-compliant businesses. This is the mechanism that has driven significant accessibility litigation in the United States under the ADA, and the same dynamic is now emerging in Europe.
How to Prepare: A Practical Roadmap
Step 1: Audit
Start with an automated scan to identify the clearest violations — missing alt text, contrast failures, missing form labels, ARIA errors. Automated tools can identify approximately 30–40% of WCAG failures. Manual testing (keyboard navigation, screen reader testing with JAWS or NVDA) is required for the remainder.
Step 2: Remediate
Prioritize fixes by impact and effort. Address the highest-severity barriers first — keyboard traps, missing form labels, and color contrast failures affect the largest number of users and are the most defensible to have unresolved. Work through the full checklist systematically.
Step 3: Document
Publish an accessibility statement on your website that discloses your conformance level, any known exceptions, and a contact mechanism for users to report issues. The EAA requires this. Update the statement after each significant change to your site.
Step 4: Monitor
Accessibility regressions are common — new features introduce new violations, third-party scripts add inaccessible widgets, content authors upload images without alt text. Continuous monitoring, integrated into your deployment pipeline, is the only way to maintain conformance over time rather than achieving it once and losing it gradually.
How ComplyTest Maps to EAA Requirements
ComplyTest includes 16 accessibility rules drawn from WCAG 2.2 AA, covering the most commonly violated and highest-impact criteria for websites:
- Image alt text presence and quality
- Form label association
- Color contrast ratios (foreground/background pairs)
- Keyboard focus visibility
- Interactive element ARIA roles and states
- Page language declaration
- Heading hierarchy
- Link purpose (descriptive link text)
- Input error identification and description
- Skip navigation presence
These 16 rules map directly to EAA requirements via EN 301 549. A passing scan doesn't guarantee full WCAG 2.2 AA conformance — manual testing is still required — but it catches the systematic, structural failures that automated detection can reliably identify, and it catches them on every deployment.
Get Ahead of EAA Enforcement
Enforcement is live. Organizations that assessed their accessibility posture before June 2025 are in a defensible position; those that haven't are accumulating risk with each month.
The fastest path to understanding your current exposure is a scan. From there, you can prioritize remediation work, track your progress, and build the monitoring infrastructure to maintain compliance going forward.
See your EAA readiness score today. Complicer runs ComplyTest accessibility checks alongside GDPR compliance scanning — one platform for your full compliance posture.