The European Accessibility Act, explained
A lot of people outside the EU assume the European Accessibility Act is someone else's problem. It usually isn't. If you sell to consumers in the EU — an online store, a booking flow, a subscription app — the EAA reaches you, no matter where your company is registered. It's been enforceable since June 2025, and the grace period where regulators mostly sent letters is over.
Let me lay out who's actually covered, what the law asks for, and what you do about it — without the directive-speak.
What the EAA is
The European Accessibility Act is an EU directive — formally Directive (EU) 2019/882 — that sets common accessibility requirements for a range of consumer products and services across all member states. Each country wrote it into its own national law, so the details of penalties and paperwork vary by country, but the baseline obligations are the same everywhere. The date that matters: 28 June 2025, when the requirements became enforceable.
Who it covers (probably you, if you sell to the EU)
The EAA targets consumer-facing products and services. On the digital side, that includes:
- E-commerce — any website or app where a consumer buys a product or service.
- Banking and payments — consumer banking services and their apps.
- Telecoms and electronic communications.
- Transport — websites, apps, and ticketing for air, rail, bus, and waterborne travel.
- E-books, audiovisual media services, and the devices that access them — computers, smartphones, e-readers, ticketing and check-in machines, ATMs.
Here's the part that catches non-EU businesses off guard: the law follows the market, not your headquarters. If you offer an in-scope service to consumers in the EU, you're covered whether you operate from Ohio, London, or anywhere else. Selling into the single market means playing by its rules.
The test isn't "are we a European company." It's "do European consumers buy from us." For most online businesses of any size, the answer is yes.
The one real exemption
There's a narrow carve-out for microenterprises. If you provide services and you have fewer than 10 employees and under €2 million in annual turnover, you're exempt from the service obligations. Two catches: it doesn't cover product manufacturers at any size, and the moment you grow past those thresholds the exemption evaporates. Don't build your plan around staying tiny forever.
What it actually requires
The EAA itself is written in outcomes — perceivable, operable, understandable, robust. To turn that into something you can build against, it leans on a European standard called EN 301 549, which for web content incorporates WCAG 2.1 Level AA. Meet EN 301 549 and you get a "presumption of conformance" — regulators assume you're compliant unless shown otherwise.
So in practical terms, the target is familiar if you've read anything about accessibility: build to WCAG 2.1 AA, and test with real assistive technology, not just an automated scan. That means the same fundamentals I keep coming back to — keyboard operability, labeled controls, sufficient contrast, meaningful alt text, proper structure. If you've worked through a WCAG AA checklist, you already know the shape of the work. (WCAG 2.2 is a superset of 2.1, so building to 2.2 AA more than covers you.)
One more requirement people miss: you're generally expected to publish an accessibility statement describing how your service meets the requirements and how users can report problems. It's not just the code — it's saying, on the record, that you've done the work.
How it's enforced
Enforcement runs through each member state's market-surveillance authorities, and it has teeth. The early months after June 2025 focused on complaint procedures and getting authorities set up; through late 2025 and into 2026, active market surveillance picked up. Beyond fines — which vary by country — authorities can order a non-compliant service withdrawn or suspended from the market. For a business that depends on EU customers, being pulled from the market is a bigger threat than any single penalty.
This isn't identical to the U.S. situation, where private lawsuits drive most of the pressure — I covered that in the ADA compliance guide. The EAA is regulator-led. But the fix is the same on both sides of the Atlantic: make the site actually usable by people with disabilities. Do that once and you're in good shape for both regimes.
What to do this quarter
If you sell to the EU and haven't looked at this, start here:
- Run an automated scan to clear the machine-detectable WCAG failures — contrast, alt text, labels, page language.
- Do a keyboard and screen-reader pass on your core flows, especially checkout and account creation.
- Publish an accessibility statement with a way to report issues.
- Keep checking — accessibility regresses every time you ship. A page that passed in June can fail in September after a redesign.
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