June 2025 is the deadline for businesses within the EU to meet accessibility standards outlined in The European Accessibility Act (EAA). As the deadline approaches, many B2C (including e-commerce and financial services) and software teams may begin scrambling to meet compliance. For teams that wait on driving compliance, failure to meet the EAA’s mandate will result in penalties, which can include fines. In this article, I will review what the EAA is, who the EAA applies to, steps to meet compliance, and repercussions if compliance is not met.
What is the European Accessibility Act (EAA)?
The European Accessibility Act (EAA) is a law that will require all public sector bodies to make sure their websites, mobile applications, and software are accessible to people with disabilities. This is important timing for two reasons:
- The world is moving more and more digital. Now, instead of going to a bank where accessibility laws are well established in the physical domain, many users are moving to digital applications (71% of all bankers in fact).
- According to Columbia University’s Greying Globe Theory, soon, 1/3rd of the European Population will be greater than 60 years old.
Now more than ever, people with disabilities need to have guaranteed access to the digital world, much like the physical world. With much of the European population at risk for disabilities due to age, the intent of the EAA is to tame the “wild west” that is public-sector web accessibility compliance.
Who does the EAA apply to?
To simplify, if you manage a digital interface and your organization is based in a European country or sells in the EU, the EAA applies to you.
E-commerce and online providers
- Customer-facing sites and apps
Note: Providers must publish accessibility statements indicating how they meet the EAA’s requirements.
Shops and restaurants
- If you have a website, see the e-commerce section above!
- Point-of-sale devices, self-service technologies, and kiosks
Computer and Mobile Device Companies:
- Computers and mobile phones
- E-readers
- Communication and telephony equipment with computer capability
- Point-of-sale devices and self-service kiosks
- Media equipment with computer capability
Note: Product packaging, instructions, and labeling are included in this as well, so considering your digital documents and alternative formats, such as braille, will be critical for compliance!
Airlines and transport
- Websites and Mobile apps
- Point-of-sale devices, kiosks, and self-service transaction machines
- Electronic tickets and electronic ticketing services
- Delivery of transport service information, including real-time travel information
Note: If your airline has departures in the EU, then you must comply with the EAA as well!
Financial industry
- Websites
- Consumer banking services
- Mobile apps
- ATMs, point-of-sale devices, kiosks, and self-service transaction machines
- Contact information
Media streaming and telephony providers
- Mobile apps
- Websites
- Communication and telephone equipment with computer capability
- Media equipment with computer capability
Not based in the EU?
Regardless of whether your organization is based in the EU, you must comply with the EAA’s requirements if you conduct business in any EU member state. This applies to all products and services mentioned previously. For instance, if a non-EU brand operates an e-commerce platform accessible to EU customers, it must ensure compliance with the regulations.
What is the timeline?
The law will be applied in July 2025, when each member state’s appointed body will begin enforcement and deciding penalties. Based on the confusion our team has seen, it is important to note that this is an accessibility law, not merely a recommendation or best practice.
This can be stressful for teams, as many people reading this article are likely learning about this law for the first time. It is worth noting that extensions to this law may be unlikely since the EAA was adopted in June of 2019, and EU member states were required to adopt and translate the EAA to their national laws. In the eye’s of the law, teams have had over 3 years to comply!
Are there any exceptions?
Yes, if your organization has fewer than 10 employees and makes less than 2 million euros annually, then you are exempt from the EAA—if the organization can prove such policies would create an “undue burden” on the organization
This is a welcome carve out in the EAA regulations, helping to protect small businesses.
What standards do I need to reach to meet EAA compliance?
EN 301 549 is the documented technical requirement that must be met to be in compliance with the EAA. That said, EN 301 549 is built on the Web Content Accessibility Guidelines (WCAG) 2.1 AA. The WCAG 2.1 AA guidelines are extensive and publicly available via the WCAG website.
There is some confusion rooted in the fact that the EN 301 549 standards heavily follow WCAG 2.1 AA but include some additional accessibility requirements within. Much of this is considered in the most recent update to the WCAG Success Criteria, WCAG 2.2 AA, so there is some hope and belief that perhaps the EAA or EN 301 549 standard will adopt WCAG 2.2 at some point to help harmonize requirements globally. This becomes more important than ever for global entities that operate in the US, EU and Canada with their recent adoption of EN 301 549 as well.
The first step we recommend to every organization is to establish an accessibility statement per the EAA guidelines. Teams can run simple automated accessibility checks on their own, but this automated approach alone will not bring a webpage into full compliance. Even for experienced individuals, finding, tracking, remediating, and managing an accessibility program can prove challenging. When failing to comply with the EAA can cost companies upwards of three million euros, finding an experienced partner is critical, and Allyant can help!
Can an automatically-deployed overlay ensure compliance?
This is one of the most common questions our team has received about these regulations. Our team at Allyant will defer to the European Disability Forum (EDF) and the International Association of Accessibility Professionals (IAAP) warnings that overlay technology does not, on its own, likely ensurethe necessary compliance with the EAA or EN 301 549.
Failure to Comply
At this point in the article, you may be wondering, “What if I don’t do anything? Are there repercussions?”
It’s important to answer the question of “who’s policing WCAG compliance” before digging into repercussions. The EAA mandates that member states designate national authorities to ensure that businesses offering in-scope products and services comply with its regulations. These authorities are responsible for conducting compliance checks, addressing complaints of non-compliance, and ensuring that companies rectify any identified deficiencies.
The repercussions will be different for each member state; however, if a company fails to meet its obligations under the EAA, the national authority can impose effective, proportionate, and dissuasive penalties. For instance, in Ireland, the European Union (Accessibility Requirements of Products and Services) Regulations 2023 stipulate that individuals or companies found in violation can face imprisonment for up to 18 months or fines of up to €60,000, depending on the nature of the breach.
What next?
If you feel the EAA applies to you or have questions regarding it, the best next step is to reach out to an expert. At Allyant, we support teams across the globe in ensuring their digital properties and digital documents not only meet WCAG 2.1 or 2.2 AA compliance but also build a roadmap to ensure they meet all applicable standards by the compliance deadlines.
That said, Europe isn’t the only continent passing stricter accessibility laws. The United States and Canada have both been making strides in accessibility compliance this year, with regulations like the DOJ ruling and HHS final rule passed in just the past few months.
Now more than ever, it is important to start your accessibility journey today rather than waiting until 2025 to kick off.
