What Is the European Accessibility Act?

The European Accessibility Act (EAA, Directive 2019/882) is an EU directive requiring Member States to harmonise accessibility requirements for key products and services. The Directive entered into force in 2019, with a transposition deadline of 28 June 2022. However, economic operators had until 28 June 2025 to bring their products and services into conformity with the new requirements.

Since 28 June 2025, EAA accessibility requirements have been fully enforceable. This means that websites and mobile applications of entities within scope must meet specific digital accessibility standards — primarily WCAG 2.1 at Level AA.

Who Does the EAA Apply To?

The EAA has a broader scope than the earlier Web Accessibility Directive for the public sector (WAD, 2016/2102), which applied only to public sector bodies. The EAA covers private sector entities offering certain products and services:

• Consumer banking services: Websites and mobile applications of banks, credit unions, and payment institutions.
• E-commerce: Online shops selling goods or services to consumers in the EU.
• Electronic communications services: Telephony, broadband, television, and related websites/applications.
• Passenger transport: Websites and applications of airlines, railways, bus and ferry services operating EU routes.
• Audiovisual media services and media: VOD platforms, streaming services.
• E-books and dedicated reading software.

Important note: microenterprises (fewer than 10 employees and annual turnover/balance sheet below €2 million) providing services are exempt from the EAA. Microenterprises manufacturing products within scope do not benefit from this exemption.

What Changed in June 2025?

Before the EAA, digital accessibility requirements for the private sector varied significantly across the EU — each Member State applied its own rules (or none at all). The EAA harmonises these requirements by establishing:

• A single standard across the EU: Websites and applications must comply with WCAG 2.1 AA (or the equivalent EN 301 549 requirements).
• Enforceable rights for consumers: Persons with disabilities can file complaints with national authorities or pursue claims in court.
• Mandatory accessibility statements: In-scope entities must publish an accessibility statement describing their compliance status and remediation measures.
• Administrative sanctions: Member States must introduce effective, proportionate, and dissuasive penalties for non-compliance.

WCAG 2.1 AA: What It Means in Practice for a Website

Web Content Accessibility Guidelines 2.1 (WCAG 2.1) is the technical accessibility standard published by the W3C. Level AA (intermediate) is required by the EAA. The standard is built on four principles (POUR):

• Perceivable:
  • Text alternatives for non-text content (alt text for images).
  • Captions for audio and video content.
  • Audio transcripts for recordings.
  • Colour contrast minimum 4.5:1 for normal text, 3:1 for large text.
  • Resizable text (up to 200% without loss of function).
• Operable:
  • Full keyboard operability without focus traps.
  • Visible focus indicator.
  • Sufficient time to read and interact (no enforced time limits).
  • No flashing animations capable of triggering seizures.
  • Breadcrumb navigation and consistent navigation across pages.
  • Link purpose understandable from the link text alone.
• Understandable:
  • Page language declared in HTML (lang attribute).
  • Consistent and predictable navigation and component behaviour.
  • Labels and instructions for form fields.
  • Error identification and description in forms.
• Robust:
  • Valid HTML (unique IDs, correct nesting).
  • ARIA attributes (aria-label, aria-describedby, role) for interactive elements.
  • Compatibility with screen readers (JAWS, NVDA, VoiceOver).

Common Accessibility Failures on Legal and Financial Websites

Accessibility audits of legal and financial sector websites consistently reveal the same categories of problems:

• Missing alt attributes: Decorative images without alt="" and semantic images without descriptive alt text.
• Insufficient contrast: Grey text on white backgrounds, links that do not stand out from surrounding text.
• Inaccessible contact forms: Missing label elements associated with fields, absent error messages.
• Focus traps in modals and mobile menus: Keyboard focus escapes the modal, making operation without a mouse impossible.
• AI chatbot without accessibility: Chatbot widgets without keyboard support and without ARIA labels.
• Missing accessibility statement: Required by the EAA (and earlier by the WAD for the public sector) — a page describing the compliance level and contact information.
• Inaccessible PDF documents: Offers, terms and conditions, contracts — scanned PDFs without an OCR layer or structural tagging.

Accessibility Statement: What It Must Contain

The EAA and EN 301 549 standard require that the website contain an accessibility statement placed in a prominent location (typically the footer). The statement must specify:

• The level of conformance with WCAG 2.1 (full conformance, partial, non-conformance).
• Exceptions — elements that are inaccessible, and the reason for the exception.
• A feedback mechanism — a contact method for persons with disabilities to report accessibility issues.
• An escalation procedure — what to do if the entity does not respond to a report.
• The date of the last review of the statement.

Supervisory Authorities and Sanctions

Each Member State was required to designate a competent authority for EAA enforcement. Supervisory authorities have the power to:

• Conduct market surveillance and audits.
• Issue administrative decisions requiring remediation of violations.
• Impose administrative fines — the amounts vary by Member State implementation.

Additionally, persons with disabilities can bring civil claims for damages resulting from EAA non-compliance, creating litigation risk for non-compliant entities in addition to regulatory sanctions.

Action Plan: How to Achieve EAA Compliance

• Accessibility audit: Conduct a WCAG 2.1 AA compliance audit — automated (Lighthouse, axe) plus manual testing (keyboard operation, screen reader testing with NVDA or VoiceOver). Identify critical gaps.
• Prioritisation: Focus on elements with the greatest impact — forms, navigation, colour contrast, text alternatives.
• Accessibility statement: Publish an accessibility statement even before achieving full compliance — describe the current status and a remediation plan.
• PDF accessibility: Reprocess key documents — add structural tagging, OCR, and alternative descriptions for images within documents.
• Continuous monitoring: Integrate accessibility testing into CI/CD pipelines — automated axe tests on every deployment to prevent regression.
• Team training: Train developers and content authors on accessibility principles — many errors arise from lack of awareness rather than deliberate omission.