European Accessibility Act 2025: What It Is and Why It Matters

June 28, 2025 was set as the official compliance deadline for the European Accessibility Act (EAA).

The accessibility expectations and legal responsibilities of the EAA directive have been known since it was first adopted in 2019. The directive sets specific accessibility requirements and expectations across the European Union (EU) for products and services. It mandates that member states must implement local laws requiring governmental bodies and businesses offering a wide range of consumer-focused products or services to meet a minimum accessibility threshold. The intention of the EAA is to enable equal access to goods and services for people with disabilities.

Regardless of where your entity currently stands in regard to accessibility, the time is now to prioritize consistent and ongoing assessment of your accessibility practices. Necessary remediation, improvement, and documentation of all of your successful advancements is essential to optimizing accessibility and remaining compliant with the EAA. This article will provide you with essential information, insights, and best practices to promote successful EAA compliance for your business.

All entities doing business in the European Union should be prioritizing the inclusive practices mandated by the EAA. In doing so, your business promotes successful engagement with the estimated 25% of EU citizens who impactfully benefit from EAA accommodations.

A Summary of EAA 2025 and Key Objectives

The European Accessibility Act is recognized as a landmark regulation to promote inclusive business operations across the European Union. Its aim is to ensure people with disabilities have equal access to goods and services. Many types of digital experiences can help enable that access. The EAA synchronizes accessibility requirements across EU member states.

The EAA applies to any organization that serves consumers in the EU. That can certainly include businesses outside of the EU as well. EAA compliance in regard to digital accessibility can be achieved via conformance to specific technical requirements outlined in EN 301 549, the universally accepted European digital accessibility standard.

All entities doing business in the EU should understand and implement the EAA expectations. Those who fail to do so will be at risk of substantial penalties.

Origin of the EAA

Over the past decade, business regulations intended to promote accessibility have become a worldwide effort. Businesses, governments, and consumers have become increasingly conscious of the importance of inclusive practices in all customer engagement, including digital offerings like websites and apps. The knowledge, techniques, and capabilities available to businesses to broaden their operational accessibility are now greater than ever before.

Prior to EAA, the EU inconsistencies relating to inclusive business practices, laws, and regulations made well-intended compliance across member state borders overly complex. Across the EU, accessibility expectations and governance had grown increasingly fragmented.

The EAA first began its legislative path toward aligned accessibility expectations in 2015. A directive was officially adopted in June of 2019, appearing in the EU’s Official Journal as Directive (EU) 2019/882. This directive would become the European Accessibility Act, designed to align accessibility standards across member states, simplifying compliance for inclusive marketplaces.

Who EAA Benefits: People with Disabilities and Broader Audiences

It is estimated that over 100 million people currently live in the EU with some form of disability. That number is considered to be a conservative estimate as it has long been known that many people are not comfortable self-identifying as disabled, regardless of the extent of their compromised abilities. Businesses prioritizing excellence within EAA expectations are positively benefiting millions of potential customers.

Certainly, EAA compliance benefits people far beyond those living with a disability as well. Elderly users of digital assets, for example, are more successful with accessible solutions. There are also those who are temporarily disabled by events that require a period of healing. Many people experience temporary eyesight, hearing, or mobility impairment following an accident, illness, or injury.

Design Philosophy: “Design for All” and Universal Accessibility

There are many business experts who believe that everyone benefits from improved accessibility because it improves overall user experience (UX). Accessibility considerations within the EAA are also recognized as best practice for consistent UX success.

“Design for all” is a universal design approach that emphasizes accessibility from the very start of business strategy. Instead of retrofitting existing goods, services, environments, and digital solutions, a large percentage of community-conscious brands have already operationalized “design for all” to advance inclusivity.

For many EU businesses, as well as global enterprises, the United Nations’ Convention on the Rights of Persons with Disabilities (CRPD) has made accessibility a non-negotiable priority for nearly two decades. CRPD was led by an Ad Hoc Committee of the UN General Assembly. Officially adopted in December of 2006, it became the UN’s fastest negotiated human rights treaty in its history. Since then, accessibility has been a consistent goal for successful global businesses.

By prioritizing successful “design for all,” businesses underscore the fact that accessibility is more than just a legal requirement, it is a foundational component of human rights.

Who Must Comply with the European Accessibility Act

The EAA applies to businesses offering products or digital services in the EU, regardless of that company’s main office headquarters being in the EU. Products or services within the European market offered to consumers after June 28, 2025 need to be compliant.

Article 2 of the EAA clearly outlines scope. It lists the following types of online and in-person business environments that offer products and services, but scope is not limited to these.

• Financial Services
• Ecommerce and Digital Services
• Transportation
• Technology and Electronics
• Public-Facing Equipment and Services like Ticketing and Vending Machines
• Digital Content and Communications

To sell goods and services within the EU, the EAA requires businesses in these sectors to be in compliance. To clarify, that includes businesses operating within B2B (business-to-business) markets as well as B2C (business-to-consumer).

EAA Exceptions

There are currently only two business exceptions outlined in the EAA. Those two refer to microenterprises and a “disproportionate burden” clause.

Microenterprise Exemption

There is a microenterprise exemption written into the EAA. While microenterprises and small businesses with fewer than 10 employees may be exempt from compliance requirements, they remain strongly encouraged to prioritize accessibility in their products and services.

Adopting accessibility practices offers significant advantages for small businesses. It not only broadens their customer base by appealing to individuals with disabilities but also competitively positions them in the marketplace. EAA compliance is required if small businesses wish to bid on public tenders.

As larger businesses adhere to accessibility regulations, microenterprises should also embrace these principles to protect ongoing community trust, secure future contracts, and thrive in competitive environments.

Reliance on a microenterprise exemption is not recommended.

Disproportionate Burden Clause

The EAA allows for a claim of "disproportionate burden." This clause provides exemptions from specific accessibility requirements for entities that can demonstrate compliance would cause excessive costs or difficulties. This clause balances the goal of widespread accessibility with the practical limitations of some organizations.

It is reasonable to assume that the documentation and justification for disproportionate burden of financial or technical strain will get harder as EAA matures. Each claim and justification may be reviewed by governing authorities. There are limited exemptions and flexibility within EAA.

Businesses currently pursuing protection under this clause should also be planning and documenting operations that maximize accessibility within a designated timeline.

EAA Responsibility Applies to Non-EU Companies

EAA is widely considered a global accessibility compliance requirement similar to what GDPR has been for privacy. When GDPR (the General Data Protection Regulation) became law across the EU in 2018, it was clear that it would impact business practices throughout the world. EAA has grown into a global consideration in much the same way.

To reiterate, all companies throughout the world who do business within the EU, even if they are not headquartered within a European nation, must comply with EAA. For example, a U.S.-based technology company that develops a payment processing application used within a German ecommerce website must be in compliance with EAA expectations. The U.S. tech was sold to the German business, bringing them into scope of the EAA.

European Accessibility Act 2025 Requirements for Digital Platforms

Digital compliance requirements within the EAA are at the forefront of prominent initiatives for business accessibility improvement. Websites, mobile apps, digital documents, ecommerce, as well as all of the assets and platforms that enable them, have accessibility obligations.

WCAG 2.1 Level AA as the Baseline Standard

WCAG is an acronym describing the Web Content Accessibility Guidelines that have been developed, tested, authored and distributed by the World Wide Web Consortium (W3C). These are recognized as the most prominent digital accessibility standards used in the world today.

WCAG 2.1 has, since it was published in 2018, led the global adoption of digital strategies to advance accessibility. The testable success criteria included in WCAG 2.1 validate three levels of compliance: A, AA, and AAA. Level AA of WCAG 2.1 is recognized as the baseline standard for EAA compliance.

The recognized European accessibility standard, EN 301 549, uses WCAG 2.1 as its digital web framework. There are additional requirements that go beyond that scope within EN 301 549, which include accessibility for hardware, software, biometrics, and support services. However, for sites and web applications, WCAG 2.1 A and AA are where businesses should start focusing their efforts.

The POUR principles of accessibility are foundational to both WCAG and EN 301 549. Understanding these four pillars of successful accessibility practices will help businesses comply with the EAA. POUR is an acronym that represents Perceivable, Operable, Understandable, and Robust.

1. Perceivable leads these four foundational principles for accessible digital solutions. Alt-text for images and transcripts for video are two examples of accommodations that make visual content perceivable for users who are sight-impaired.
2. Operable solutions engage an inclusive range of users by successfully interacting with multiple input methods, such as keyboards (not mouse-dependent), voice commands, or switch controls.
3. Understandable is the principle that ensures content remains easy to follow with predictable progression, clear instructions, and consistent layout.
4. Robust expands the accessibility aspirations beyond the bare minimum, maximizing the ways users of all range of abilities can successfully interact with digital solutions.

Core Requirements by Digital Category

The following offers an introduction to core requirements that can significantly advance EAA compliance.

Websites

• Must be fully navigable via keyboard.
• Must provide text alternatives (alt text) for images.
• Media must have alternatives including captions, transcripts, and audio descriptions.
• Interactive elements, images, and text, must meet contrast ratio guidelines (e.g., 4.5:1 for small text with the surrounding background).
• Headings, forms, lists, and tables must follow semantic HTML structures.
• Must be flexible to account for browser magnification and text style adjustments.
• Feedback, states, and roles are provided for assistive technology including screen readers (e.g. NVDA and JAWS).

Mobile Apps

• Must provide the same level of accessibility as websites.
• Should support mobile device screen readers (e.g., VoiceOver, TalkBack).
• Must allow for text resizing and different screen orientations.
• Must include single pointer alternatives (e.g., buttons) for motion and gesture controls.
• Navigation must be touch-and keyboard-accessible.

Digital Documents (PDFs, Word, Excel, etc.)

• PDFs and downloadable documents must include:
  • Tagged content
  • Logical reading order
  • Searchable text (not scanned images without OCR)
  • Descriptive hyperlinks and headings
• Non-compliant legacy documents must be updated unless they meet specific exemption criteria.

Video and Audio Media

• Pre-recorded and live video with audio must have synchronized captions.
• Audio and video content must include descriptive transcripts.
• Sign language interpretation may be required for some public-facing or essential content.
• Video players must support different input devices and assistive technology including keyboard navigation and screen readers.

Ecommerce & Transactional Interfaces

• All stages of the customer journey — from browsing to checkout — must be accessible.
• Forms (shipping, billing, account registration) must have:
  • Proper labels and input error identification
  • Instructions available via screen readers
• CAPTCHA systems must offer accessible alternatives.

Customer Support Portals

• Live chat and help widgets must be screen-reader compatible.
• Support ticket forms must be usable via keyboard and support assistive technologies.
• Businesses must offer at least one accessible method of support (e.g., accessible webform or email).

Additional Legal and Technical Considerations for EAA 2025 Compliance

We have recognized several aspects of EAA compliance that have been often overlooked. The following bullet points list considerations that you and your business will want to be sure to include as you pursue accessibility optimization.

• Accessibility Statement: Required for all compliant websites/apps, an accessibility statement must describe the compliance level, testing method, and provide contact info for feedback.
• Feedback Mechanism: Sites/apps must offer users a way to report accessibility issues or request accessible alternatives.
• Third-Party Content: Responsibility for third-party content and assets lies with the business presenting it. This applies to third-party technology platforms, plugins, payment gateways, or embedded tools used by businesses as well.
• AI and Emerging Tech: AI-driven tools (like chatbots or voice interfaces) must also be perceivable, operable, and fully compliant with the EAA.
• Ongoing Monitoring: Accessibility is not a “set-it-and-forget-it” endeavor. It must be consistently monitored and maintained. Reassessment is especially important after significant site updates or redesigns.

EAA Penalties for Non-Compliance

Non-compliance with the European Accessibility Act can result in significant financial penalties and legal consequences. Businesses may face fines, lawsuits, regulatory enforcement actions, and even restrictions on EU market access. Beyond these financial penalties, non-compliance also damages reputation, erodes customer trust, and leads to market losses.

EAA Penalty Variance Across EU Countries

Penalties for EAA violations vary by country throughout the European Union. All penalties are put in place to follow three mandatory principles to be “effective, proportionate, and dissuasive.” Each EU member state is responsible for designating its own enforcement body. Examples of these enforcement bodies include equality commissions, consumer protection agencies, and accessibility authorities.

The most common penalties for violations are fines. Fines in Germany have been established up to €500,000. In Italy, they can be up to €40,000 or 5% of turnover for certain private entities. Continuous non-compliance can also lead to daily penalties, which can reach up to €1,000 per day. Daily fines are intended to expedite remediation.

In Ireland, imprisonment of up to 18 months can be punishment for indicted convictions of EAA non-compliance. In serious cases, businesses and individuals, including business directors and officers, can face criminal charges and imprisonment.

Non-compliant products and services can also be removed from the European markets. Those products and services may be eligible for reintroduction to EU markets when EAA compliance is proven and ongoing practices for accessibility are documented, but that is not guaranteed.

Non-compliant products and services are ineligible for public sector tenders and contracts with EU member states.

Public listings of all businesses guilty of non-compliance with the EAA is a penalty in many EU member states as well. This can lead to negative publicity via media scrutiny, social media backlash, and poor customer reviews.

Reporting and Complaint Mechanisms

With the EAA in place, citizens can file complaints with regulatory bodies of any EU member state. Individuals and advocacy groups can also bring lawsuits against a business for non-compliance.

Because the EAA follows a decentralized enforcement approach, each EU member state is responsible for establishing its own reporting mechanisms. National enforcement bodies, local courts, and designated government agencies for consumer protection are the most commonly established mechanisms to report EAA violations. Businesses must also provide information regarding the reporting of EAA violations in their published accessibility statement.

Businesses must be prepared to respond to formal complaints with documentation and transparency. In doing so, a records history of accessibility assessments and testing is extremely important. If remediation is necessary, an expedited plan with detailed timelines and strategies to successfully remove the identified accessibility barrier may limit penalties or escalation.

Businesses Win with the European Accessibility Act

The EAA has been widely celebrated for bringing clarity and consistency across EU member states in regard to business accessibility requirements. Prior to its adoption, it was extremely difficult for entities to comprehensively understand and implement accessibility-compliant operations across European borders.

Certainly, the uniformity of the EAA expectations for accessibility has helped businesses reduce their ongoing business risk. However, the business benefit of EAA compliance goes far beyond the avoidance of fines, legal actions, and reputational damage.

Compliance literally expands the market for businesses in the EU. By engaging up to 25% more potential customers, those who were previously limited by barriers to accessibility, businesses are realizing immediate gains in reach, engagement, and conversions.

Tangential benefits of EAA compliance include improved search engine optimization (SEO) as well. The alt-text used on images, for example, is also indexed by search bots and improves placement within search engine result pages.

Best practices for accessibility also improve user experience for all people. This improved UX builds positive brand relationships, consumer trust, and ultimately business growth.

Frequently Asked Questions about the European Accessibility Act 2025

What is the European Accessibility Act?

The European Accessibility Act (EAA), officially Directive (EU) 2019/882, is an EU regulation aimed at improving accessibility to goods and services for people with disabilities by setting common inclusive standards across all member states. It promotes equal access and removes market fragmentation.

What is the European Accessibility Act 2025?

The European Accessibility Act 2025 refers to the enforcement phase of the EAA, effective June 28, 2025. From this date, businesses offering digital services or products in the EU must be compliant with accessibility standards such as WCAG 2.1 Level AA and EN 301 549.

Who does the European Accessibility Act apply to?

The EAA applies to most organizations offering products or services to consumers in the European Union, including ecommerce businesses, B2B service providers, mobile app developers, banks, and media platforms. Exemptions apply to microenterprises and well-documented cases of disproportionate burden.

What are the key requirements of the European Accessibility Act 2025?

Key requirements include ensuring websites, mobile apps, e-documents, and digital content are accessible to users with disabilities. This involves consistent compliance with WCAG 2.1 AA, EN 301 549, support for screen readers, keyboard navigation, accessible multimedia, and publishing an accessibility statement.

What penalties can businesses face under the EAA?

Penalties vary by country but are intended to be “effective, proportionate, and dissuasive.” They may include financial fines, removal of non-compliant products from the market, or bans on offering services in the EU.

Does the EAA require websites to follow WCAG guidelines?

Yes, to comply with the European Accessibility Act 2025, websites and apps must follow the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, aligning with the EN 301 549 standard.

Does the European Accessibility Act apply to mobile apps?

Yes, mobile apps used by EU consumers must also comply with EAA requirements. This includes features like screen reader compatibility, resizable text, and accessible navigation structures.

Is there a checklist for EAA 2025 compliance?

Yes, organizations can use EAA compliance checklists that outline key areas such as text alternatives, contrast ratios, form labeling, keyboard access, and accessible documentation. Tools like Siteimprove and WCAG checklists are commonly used.

Where can I find the official European Accessibility Act 2025 guidelines?

You can find the official EAA 2025 text and requirements in the European Union’s EUR-Lex Portal and supporting documents such as the EN 301 549 standard and WCAG 2.1 from W3C. Downloadable PDFs and summaries are also available online.