The European Accessibility Act (EAA) is reshaping the way businesses approach accessibility globally. By June 28, 2025, companies must comply with specific digital accessibility standards.
For companies selling products and services in the EU, the stakes are high—not just to meet the legal requirements but to remain competitive in a market that increasingly prioritizes inclusivity.
The goal of this guide is to help you navigate the path to EAA compliance with detailed, actionable insights focusing on real-world lessons we have learned from years of front-line experience helping organizations tackle accessibility at scale.
Understanding EN 301 549 and Its Relationship to WCAG 2.2
At the heart of the EAA lies the European standard EN 301 549. Ultimately, this standard aims to harmonize the accessibility compliance of ICT (information and communication technologies).
Of note, it is unique to the commonly referenced Web Compliance standards built by the W3C, the Web Content Accessibility Guidelines (WCAG).
However, it is also not entirely unique. In fact, EN 301 549 draws from WCAG 2.1 AA but extends into other areas like software, hardware, and telecommunications devices.
With WCAG 2.2 officially adopted in October 2023, EN 301 549 is expected to eventually integrate key aspects of the updated guidelines, further tightening requirements and aligning the EAA standards with other global accessibility regulations.
How EN 301 549 Differs From WCAG
While WCAG focuses primarily on web content, EN 301 549 expands into broader areas that, in some cases, live far outside of website-specific content. These include:
- Hardware accessibility: Requirements for devices such as ATMs, ticketing machines, and mobile devices.
- Non-web software: Standards for desktop and mobile applications beyond web browsers.
- Telecommunications systems: Requirements to ensure accessibility in voice and text communication systems.
Client Use Case
A client we worked with—a global telecommunications provider—initially assumed their WCAG 2.1 compliance efforts for their mobile app were sufficient. However, EN 301 549 introduced additional criteria, such as requirements for alternative input methods and real-time text communication, which could have been overlooked by a strict adherence to WCAG 2.1 AA, which is required under many U.S. and Canadian accessibility regulations. By auditing their software against EN 301 549 and WCAG 2.2 AA, we identified gaps that could have otherwise led to non-compliance specifically relating to the EAA.
Why WCAG 2.2 AA is Globally Relevant
Throughout 2024, WCAG 2.2 AA has slowly become the de facto global accessibility testing standard.
Even with countries like the U.S. and Canada releasing accessibility regulations that point to WCAG 2.1 AA, many enterprise organizations and product teams aim to harmonize their global accessibility efforts and future-proof their products and testing results against the most up-to-date standards for accessibility.
Additionally, on the legal front, most of the high-volume plaintiffs filing demand letters and lawsuits in the U.S. – including against EU-based brands offering their products to the U.S. market – are now referencing WCAG 2.2 AA as a requirement in settlement agreements.
The updated success criteria released in WCAG 2.2 emphasize usability improvements for people with cognitive and motor disabilities. These include new success criteria such as:
- Focus appearance (2.4.11): Ensuring focus indicators are visible for keyboard users.
- Drag-and-drop functionality (2.5.7): Providing alternative methods for users unable to perform drag-and-drop actions.
As an organization supporting a large number of clients worldwide, our team at Allyant recommends that organizations adopt WCAG 2.2 AA universally—not only to meet current regulations but also to future-proof their digital properties against emerging standards like EN 301 549.
Additionally, I have heard from global leaders at various conferences throughout 2024 that part of ‘harmonizing’ the regulations and making it more streamlined for organizations deploying their products across global markets is that the EU regulations could adopt WCAG 2.2 AA as the standard in the not-so-distant future.
Within our Allyant HUB Platform and testing results, we allow your team to quickly filter on various WCAG standards (such as 2.0 vs. 2.1 vs. 2.2), allowing your team to have a full view of all accessibility requirements while still prioritizing the issues in your remediation workflows that are most applicable to the markets and vertical you operate in.
Conducting an Accessibility Audit of Your Digital Ecosystem
A thorough accessibility audit is the cornerstone of any EAA compliance effort. This audit evaluates your websites, mobile applications, digital documents and PDFs, software (including those you procure from a third party!), and other digital assets against EN 301 549.
Short-Term Action Items
Audit Your Digital Products
The first step in building an accessibility roadmap is generally understanding where your products stand against EN 301 459 and WCAG 2.2 AA. The most effective way to grasp this understanding is what I’ve long coined as a “health assessment” (audit) of your website(s), consumer-facing mobile applications, or other digital assets, such as PDFs, that are used to interact with your EU-based customers.
Prioritize Critical Accessibility Gaps
Once you have assessed your products against relevant accessibility standards, the next step is building out a roadmap for tackling remediation. In full transparency, especially on large websites or applications, this will not happen overnight. This is where focusing on high-impact accessibility issues that affect critical user journeys, such as checkout flows or product navigation, becomes extremely important for building ‘quick wins’ among your team and scaling product accessibility as quickly as possible.
When our team delivers auditing results to our clients, we provide two key indicators that help drive efficient remediation planning.
The first is a flag for sitewide accessibility issues that will allow you to make a singular or set of fixes to resolve an accessibility issue across all pages or views of your website/mobile application – such as a Skip to Main Content or issues in your base Menu Navigation.
Second, we provide a “Priority Level” from 1 to 3 for every barrier identified in the testing process. A Priority Level 1 issue, for example, is a complete blocker of a user leveraging assistive technology and would totally prohibit that user from engaging with your brand or product.
This allows your team to focus on fixing the most critical barriers first and move through prioritized issues in a more agile remediation process.
Client Use Case
A global e-commerce retailer came to Allyant with concerns about their European market presence with the pending June 2025 deadline. Our live-user accessibility audit uncovered several critical issues, including unlabelled buttons on their PDP pages, inaccessible form labels, and an inability for screen reader users to interact with their hover menu throughout the website and checkout process. Focusing on the remediation of the most critical issues not only put them on a path to compliance with the EAA ahead of regulatory deadlines but also opened them up to a potential 15% increase in new customers. This is based on data from the EU-SILC that recently found 15-20% of the population in the EU lives with a disability – a percentage that represents 100 million people!
Embedding Accessibility into Design and Development
Building accessibility into digital products after the design and development phase can be far more expensive. Research our team has done with client projects shows that there can be upwards of a 30% reduction in development cost for accessibility in an accessibility-first design and development process. This does not even factor the downstream effects of the shorter timeline to compliance!
To realize these efficiencies, accessibility must be integrated into every stage of your design and development processes.
Tips for Building an Accessibility-First Mindset:
- One of the strongest practices your team can implement is focused reviews during the Design Phase of projects rather than waiting until the development process and/or after the product is built and put into the market. Allyant offers this for design teams, helping them build accessibility annotations into their design files, discuss design improvements in real time, and bridge the gap between design and development teams.
- Train both design and development teams on the baseline requirements and best practices for building with accessibility and WCAG conformance in mind. Our team offers live, recorded accessibility training tracks for both Designers and Developers to ensure this can become part of your team’s core skillset and also be leveraged as part of employee onboarding for these roles!
- Conduct ongoing usability testing with assistive technology users! This will give your team real-time feedback on the initial state of the products you are building and garner consistent feedback on new features or functions added to websites or applications, helping you maintain accessibility conformance.
Inventory your Digital Documents & PDF Files
The European Accessibility Act (EAA) strongly emphasizes document accessibility. It requires that all digital documents posted or sent after June 28, 2025, comply with accessibility standards.
For businesses operating in or serving the EU, this means now is the time to assess their existing document inventory, evaluate compliance gaps, and implement a structured approach to accessibility remediation.
Without a proactive strategy, organizations risk failing to meet these critical requirements, exposing themselves to penalties, lost business opportunities, and reputational harm.
Easily Inventory Your Document’s Accessibility
Conducting a comprehensive inventory of your PDF and digital documents is the first step toward compliance. With Allyant’s CommonLook Clarity testing tool, organizations can evaluate document accessibility at scale, quickly identifying inaccessible files and prioritizing them for remediation. This ensures your compliance efforts are targeted, efficient, and aligned with the most heavily utilized or customer-facing content. CommonLook Clarity provides an unmatched ability to analyze large document libraries, empowering teams to understand the full scope of work required for accessibility compliance.
Moving from Assessment to Action
Once the assessment is complete, organizations must prioritize the remediation of high-impact documents, focusing on those most frequently accessed by customers, employees, or stakeholders. Allyant’s PDF Accessibility Assessment & Remediation services streamline this process, delivering fully accessible documents with a 100% guarantee that meet global accessibility standards, including WCAG 2.2 and EN 301 549. Our expert-led team ensures compliance while maintaining the integrity and layout of original content, providing organizations with peace of mind and the ability to meet tight deadlines.
Proactive Planning for EAA Compliance
The EAA deadline may seem distant, but the volume of work required to achieve compliance—especially for organizations with large document repositories—makes early action critical. Partnering with Allyant ensures you have the tools, expertise, and processes needed to achieve compliance while minimizing disruption. By leveraging CommonLook Clarity, targeted remediation efforts, and a proven track record of success, Allyant positions your organization to meet the June 2025 requirements with confidence.
Client Use Case
A leading financial institution in North America faced significant challenges in preparing for global accessibility regulations, including the EAA. With a vast repository of legacy documents and the need for ongoing remediation of customer-facing statements, it turned to Allyant for a comprehensive solution. Allyant deployed CommonLook Clarity to assess the accessibility of its document library and identified high-priority files for remediation.
Using the data-driven insights from Clarity, our team worked alongside the client to remediate their most heavily used documents, ensuring compliance across critical customer-facing materials.
In parallel, Allyant established a high-volume remediation process for recurring statements and documents, delivering accessible outputs in alignment with the institution’s branding, communication standards, and client expectations.
This approach enabled the client to achieve compliance with the ADA and AODA and positioned them to comply with other global regulations (such as the EAA) through a highly scalable process for future document management needs.
Accessibility in Procurement: Leveraging VPAT ACRs
One of the most significant impacts of the EAA is the emphasis on accessibility in procurement, with the focus on regulations expanding outside of websites or web content specifically.
Public and private organizations in the EU, similar to growing trends we have seen in the U.S. with the release of updated Title II and HHS regulations, must now ensure that vendors they are selecting to deploy third-party software, and applications are working to comply with EN 301 549 standards.
This has placed VPAT ACRs (Voluntary Product Accessibility Templates) at the forefront of procurement discussions.
Why VPAT ACRs Matter
A well-crafted VPAT ACR is more than a compliance document—it’s a necessary sales tool for vendors and should act as a clear roadmap to a product’s ongoing accessibility effort. However, inaccuracies or outdated information can lead to disqualification or even legal risk. Earlier this year, I wrote about this topic in detail, including how to ensure VPAT ACRs are more than just a procurement checkbox, which you can find here.
Client Use Case
A SaaS provider in the education sector partnered with Allyant after the threat of losing a very large state education client due to not having an up-to-date VPAT ACR for their product. By leveraging our live-user testing process to focus on key product components and the most heavily trafficked product workflows with results deploying in our HUB platform, they received a live, interactive VPAT ACR that not only met Title II and Section 508 requirements but also provided procurement teams with detailed remediation timelines and project roadmaps. This ensured they not only retained their large state education client but 12 months later, they have turned this into a tool to win more business by proactively outlining their accessibility progress and commitment.
This same process is starting to become more prominent in the EU, and we are seeing many EU and U.S.-based software vendors frantically looking to deploy an accessibility process.
Ultimately, large EU-based organizations are beginning to “check” with existing vendors about their product accessibility, ask for a VPAT ACR, and gain a better understanding of their accessibility-focused product roadmaps as the deadline for EAA compliance nears.
Get started on EAA Compliance!
EAA compliance isn’t just a legal obligation—it’s an opportunity to deliver better experiences to all users. By understanding EN 301 549, conducting thorough audits, and embedding accessibility into your processes, you can meet the 2025 deadline while positioning your brand as a leader in inclusivity.
Allyant’s global expertise in live-user testing, compliance strategy, and holistic document accessibility support can get your team started on building your path to EAA compliance. Reach out to our team below to chat with our expert consultants on getting started!
