European Accessibility Act (EAA): What Website Owners Need to Know

On June 28, 2025, the European Accessibility Act (EAA) became enforceable across all EU member states. This directive — formally Directive (EU) 2019/882 — represents the most significant accessibility legislation in European history, extending mandatory accessibility requirements to a broad range of products and services, including websites and mobile applications.

If your website provides services to consumers in the EU, you need to understand whether the EAA applies to you, what it requires, and what happens if you fail to comply. This guide covers all of it.

What Is the European Accessibility Act?

The EAA is an EU directive that harmonizes accessibility requirements across member states. Unlike the GDPR (which is a regulation and directly applicable), the EAA is a directive, meaning each member state transposes it into national law. The implementation details may vary slightly between countries, but the core requirements are consistent.

Key Facts

Aspect	Detail
Legal instrument	Directive (EU) 2019/882
Adopted	April 17, 2019
Transposition deadline	June 28, 2022
Application date	June 28, 2025
Scope	Products and services placed on the EU market
Technical standard	EN 301 549 (which incorporates WCAG 2.1 Level AA)

The EAA is not about goodwill or best practices. It is binding law with enforcement mechanisms and penalties.

Who Does the EAA Apply To?

The EAA applies to economic operators that provide covered products or services to consumers (B2C) in the EU. This includes manufacturers, importers, distributors, and service providers.

Covered Digital Services

The following services fall within the EAA’s scope when provided to consumers:

E-commerce websites and apps — any website where consumers can purchase goods or services online
Banking and financial services — online banking, payment platforms, ATMs
Telecommunications services — including websites and apps of telecom providers
Audio-visual media services — streaming platforms, video-on-demand
E-books and e-readers — both the devices and the digital content
Transport services — websites and apps for booking and check-in (air, rail, bus, waterborne)
Access to public sector websites — already covered under the Web Accessibility Directive (2016/2102), now reinforced

Who Is Exempt?

Microenterprises providing services (fewer than 10 employees AND annual turnover or balance sheet total not exceeding 2 million EUR) are exempt from the service provisions. Note: this exemption does not apply to products.
Disproportionate burden — if compliance would require a fundamental alteration of the service or impose a disproportionate financial burden, a limited exemption may apply. This must be documented and reassessed regularly.

Important: The microenterprise exemption is narrower than many assume. If your company has 10 or more employees, or your annual turnover exceeds 2 million EUR, you are covered regardless of your industry.

The Technical Standard: EN 301 549

The EAA references EN 301 549 as the harmonized European standard for accessibility of ICT products and services. For websites and web applications, EN 301 549 incorporates WCAG 2.1 Level AA in its entirety.

WCAG 2.1 Level AA: The Four Principles

WCAG is organized around four principles — known by the acronym POUR:

Perceivable: Information and user interface components must be presentable in ways users can perceive.

Provide text alternatives for non-text content (images, icons, charts)
Provide captions and transcripts for audio and video content
Ensure content can be presented in different ways without losing meaning
Make it easier for users to see and hear content (contrast, text resizing)

Operable: User interface components and navigation must be operable.

All functionality must be available via keyboard
Users must have enough time to read and interact with content
Content must not cause seizures or physical reactions (no flashing)
Users must be able to navigate, find content, and determine where they are

Understandable: Information and the operation of the user interface must be understandable.

Text must be readable and understandable (language declaration)
Pages must appear and operate in predictable ways
Users must be helped to avoid and correct mistakes (form validation)

Robust: Content must be robust enough to be interpreted by a wide variety of user agents, including assistive technologies.

Maximize compatibility with current and future tools (valid HTML, ARIA)

Key WCAG 2.1 Success Criteria for Websites

Criterion	Level	Requirement
1.1.1 Non-text Content	A	All images have meaningful alt text
1.3.1 Info and Relationships	A	Semantic HTML structure (headings, lists, tables)
1.4.3 Contrast (Minimum)	AA	Text contrast ratio of at least 4.5:1
1.4.4 Resize Text	AA	Text can be resized to 200% without loss of functionality
2.1.1 Keyboard	A	All functionality available via keyboard
2.4.1 Bypass Blocks	A	Skip navigation link provided
2.4.4 Link Purpose	A	Link text describes the destination
2.4.7 Focus Visible	AA	Keyboard focus indicator is visible
3.1.1 Language of Page	A	HTML lang attribute is set correctly
3.3.1 Error Identification	A	Form errors are identified and described
3.3.2 Labels or Instructions	A	Form fields have associated labels
4.1.2 Name, Role, Value	A	Custom components have correct ARIA attributes

Beyond WCAG: EN 301 549 Additions

EN 301 549 includes requirements beyond WCAG that apply to websites:

Accessibility statement (documenting conformance level and known limitations)
Feedback mechanism for users to report accessibility barriers
Compatibility with assistive technologies (screen readers, switch devices, voice control)

Enforcement and Penalties

Each EU member state designates market surveillance authorities responsible for enforcement. The EAA requires member states to establish:

Complaint mechanisms for consumers to report non-compliance
Market surveillance procedures to check products and services
Penalties that are “effective, proportionate, and dissuasive”

Penalty Examples by Member State

The specific penalties vary by jurisdiction, as each member state defines its own sanctioning regime:

Country	Enforcement Authority	Penalty Range
Germany	Marktüberwachungsbehörden (varies by state)	Up to 100,000 EUR per violation
France	DGCCRF + Arcom	Up to 50,000 EUR per product/service
Netherlands	Authority for Consumers & Markets (ACM)	Up to 900,000 EUR or 1% of turnover
Italy	AGCOM + market surveillance	Up to 120,000 EUR per violation
Ireland	National Disability Authority	To be defined in national law

Note: Penalties for websites specifically are still being established in several member states. However, the direction is clear: non-compliance carries real financial consequences.

Timeline and Transition Period

Date	Milestone
April 17, 2019	EAA adopted at EU level
June 28, 2022	Transposition deadline (all member states must have national laws in place)
June 28, 2025	Application date (enforcement begins)
June 28, 2030	End of transition period for services using products already in the market before June 2025

If your website launched before June 28, 2025, and no significant changes have been made since, you may benefit from a transition period until June 28, 2030 for certain aspects. However, newly launched or substantially modified websites must comply immediately.

Practical Steps for Compliance

Step 1: Determine If the EAA Applies to You

Answer these questions:

Do you provide services to consumers (B2C) in the EU?
Is your organization above the microenterprise threshold (10+ employees or 2M+ EUR turnover)?
Does your service fall within the covered categories (e-commerce, finance, telecom, transport, media)?

If you answered “yes” to all three, the EAA applies.

Step 2: Audit Your Current State

Run an automated accessibility scan to identify technical issues, then complement it with manual testing (keyboard navigation, screen reader testing). Automated tools typically catch 30-40% of WCAG issues; the rest require human evaluation.

Step 3: Prioritize and Remediate

Focus on the highest-impact issues first:

Critical navigation barriers (keyboard traps, missing skip links)
Missing text alternatives for images and media
Form accessibility (labels, error messages, focus management)
Color contrast failures
Heading structure and semantic HTML

Step 4: Publish an Accessibility Statement

EN 301 549 requires an accessibility statement that includes:

Conformance level achieved (e.g., WCAG 2.1 AA, partial conformance)
Known limitations and planned improvements
Contact information for accessibility feedback
Date of the statement and last review

Step 5: Establish Ongoing Monitoring

Accessibility is not a one-time project. New content, design changes, and third-party updates can introduce regressions. Establish regular automated scans and periodic manual audits.

Compliance Checklist

Scan Your Website With Compliso

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