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European Accessibility Act (EAA): Understanding EU Digital Accessibility Requirements
Introduction
The European Accessibility Act (EAA) represents the most comprehensive accessibility legislation in the world. Adopted in 2019 and enforced starting June 28, 2025, the EAA mandates that digital products and services sold or provided in the EU meet strict accessibility standards.
Unlike voluntary guidelines, the EAA is legally binding across all 27 EU member states plus Norway, Iceland, and Liechtenstein. Organizations that fail to comply face significant fines and market restrictions.
Legal Disclaimer
A11yscan is not a law firm and does not provide legal advice. We operate under best practices based on WCAG Guidelines, ADA requirements, and applicable jurisdictions. Courts don't always agree on terms and expectations for web accessibility, and legal standards can vary by jurisdiction. However, an accessible website works better for all users regardless of legal requirements. For specific legal guidance, consult with a qualified attorney specializing in accessibility law.
What is the European Accessibility Act?
The EAA is a directive that harmonizes accessibility requirements across Europe. It establishes mandatory accessibility standards for digital products and services, including websites and mobile applications.
Key Features
- Applies to all EU member states and EEA countries
- Mandatory compliance date: June 28, 2025
- Covers both B2B and B2C digital products
- Includes websites, apps, and digital services
- Enforced at national level by member states
Official information: EU European Accessibility Act page
Technical Standards: WCAG 2.1 AA + EN 301 549
The EAA mandates compliance with two related standards working together:
WCAG 2.1 Level AA
The Web Content Accessibility Guidelines Level AA requires:
- 4.5:1 color contrast for normal text
- 3:1 contrast for large text (18pt+)
- Keyboard accessible navigation
- Alt text for all images
- Captions and transcripts for multimedia
- Proper heading hierarchy and structure
- Form labels and error messages
- Page resizable to 200% without functionality loss
EN 301 549 Standard
The European standard EN 301 549 goes beyond WCAG 2.1 AA and adds requirements for:
- Document accessibility (PDF, Office files)
- Real-time communication accessibility
- Non-web applications and operating systems
- Mobile app accessibility (both iOS and Android)
- Electronic documentation
Technical specifications: ETSI EN 301 549 Standard (PDF)
Scope and Coverage
The EAA applies to organizations of all sizes providing digital products or services in the EU market.
What's Covered
- Websites and web applications
- Mobile applications (iOS, Android)
- Desktop software and operating systems
- e-Books and digital documents
- Video players and multimedia platforms
- Digital ticketing and payment systems
- Online shopping platforms
- Real-time communication tools (video conferencing, chat)
Limited Exemptions
The following are generally exempt:
- Websites and apps of public sector bodies (covered by different rules)
- Content from third parties not under service provider control
- Legacy systems (before market placement June 28, 2025)
- Significantly disproportionate burden (narrow interpretation)
Compliance Timeline and Deadlines
The EAA enforcement date is June 28, 2025—which means organizations must ensure compliance now or face penalties.
Key Dates
- June 28, 2025: EAA enforcement begins
- Before June 28: Organizations must audit and remediate
- After June 28: Non-compliance results in enforcement action
Each EU member state has designated national enforcement bodies. Learn which authority covers your country at NANDO Database.
Enforcement and Penalties
The EAA is enforced at the national level, with each member state establishing penalties for non-compliance. Penalties vary but are generally substantial:
Typical Enforcement Actions
- Administrative fines (€1,000 to €10,000+ depending on country)
- Mandatory remediation orders
- Market bans or product withdrawal
- Consumer compensation claims
- Reputational damage and loss of customers
National Enforcement Bodies
Major countries' enforcement authorities:
- Germany: Federal Office for Information Security (BSI)
- France: French Data Protection Authority (CNIL)
- UK: Equality and Human Rights Commission (post-Brexit)
- Italy: Ministry of Disability
- Spain: Secretaría de Estado de Igualdad
Steps to Achieve EAA Compliance
Organizations should take immediate action to prepare for the June 28, 2025 deadline.
Phase 1: Assessment (Now)
- Audit all digital products against WCAG 2.1 AA and EN 301 549
- Identify accessibility barriers by product
- Prioritize remediation efforts
- Engage accessibility consultants if needed
Phase 2: Remediation (By June 2025)
- Fix identified accessibility barriers
- Update documentation and accessibility statements
- Train development and QA teams
- Establish accessibility governance
Phase 3: Verification (Before June 28)
- Conduct final accessibility testing
- Generate compliance documentation
- Publish accessibility statements
- Establish complaint handling procedures
EU guidance on implementation: European Accessibility Act Implementation Guidance
Key Takeaways
- The EAA applies to all digital products and services in EU markets
- Compliance is mandatory starting June 28, 2025
- WCAG 2.1 AA and EN 301 549 are the technical standards
- Non-compliance results in significant fines and enforcement action
- Organizations should begin audits and remediation immediately
- Accessibility compliance improves user experience for everyone