Navigating the European Accessibility Act (EAA)

This blog post provides information about accessibility laws and regulations, but is not legal advice. You should consult a lawyer for advice on specific legal issues or questions.

We are less than a year away from the enforcement deadline of the European Accessibility Act (EAA) on June 28th, 2025. This means that many businesses providing services in the EU have started getting their accessibility plans into gear. And with action, there also comes questions, lots of questions.

Understanding the new legislation, identifying where your digital product or service stands, translating requirements into a team-wide plan for effective remediation, and ensuring compliance moving forward, can be an overwhelming and time consuming process.

If you are wondering whether the EAA applies to your digital product, or you already know it does but don’t know where to get started, this guide will cover all the essentials for approaching accessibility compliance and crafting an action plan.

Understanding the European Accessibility Act (EAA)
Understanding requirements, standards and principles
What are some common accessibility issues?
Devising your accessibility plan
What’s next?
Resources

Understanding the European Accessibility Act (EAA)

There are more than 80 million people in the EU living with some kind of disability. With an aging population, the number of people who experience disabilities such as low vision, mobility impairments, or cognitive disabilities only continues to grow.

Ensuring equal access to as many aspects of society as possible, including digital products and services, is a responsibility we all share.

Accessibility is also the basis of any good product. Understanding what it takes to make digital experiences accessible only strengthens and improves your product and your market positioning.

Let’s break down the new legislation to understand compliance requirements, and explore how going beyond compliance can drive product success.

What is the European Accessibility Act?

The European Accessibility Act is a new EU directive, Directive (EU) 2019/882 on the accessibility requirements for products and services.

As stated in its summary, the aim of the EAA is that of “harmonizing accessibility requirements for certain products and services so the EU’s internal market operates smoothly”.

This directive addresses the fragmented landscape of accessibility laws. Until now, requirements diverged based on national legislation of the different Member States. By establishing accessibility requirements at the level of EU law, the EAA aims to “remove barriers, increase the availability of accessible products and services in the internal market, and improve the accessibility of relevant information”.

By making accessible products and services more available, it fosters a more inclusive society and facilitates independent living for people with disabilities.

From a business perspective, the EAA also makes it easier for businesses to sell their products and services across markets. With unified requirements, companies get to spend less resources on compliance and can cater to a wider, more diverse market across Europe.

What products and services are covered under the EAA?

There is a wide range of products and services covered under this new directive.

If your company has a digital product or service, a helpful first glance for you to consider is that digital and online services covered include:

consumer banking services (web portal, mobile app, online content, help desk)
e-commerce, including selling platforms, news, digital ads, social media and email marketing, entertainment, digital offerings of professional services, and free services funded by advertising
transport services (websites, mobile services, electronic tickets, information)
multimedia services, including videos, webinars, podcasts, and television.

For the legislation, the term “products” refers to manufactured goods and hardware. This includes computers, payment terminals, ticketing machines, smartphones, TV equipment, and e-readers.

Does the EAA apply to companies outside of the EU?

Yes. Even if your business is not based in the EU, if you are providing services or selling products to consumers within the EU, the European Accessibility Act applies to you. Yes, this also means US companies.

Does the EAA apply to B2B companies?

No. The EAA applies to products and services that are placed on the EU market, so consumer-facing or B2C. However, if you are a B2B2C business, meaning your product is used by a company that does provide consumer-facing services (e.g. by integrating your product into theirs), then you still need to ensure accessibility.

In the same way, even if only parts of your product are customer-facing, you still need to take care of bringing those into compliance.

Are existing products excluded? Who is exempt?

The directive contains exemptions for microenterprises (def. 23), as well as for web content and multimedia media published before June 28th 2025, and not updated or edited afterwards. Excluded products and services have a 5-year grace period and must be compliant by June 28th 2030 instead.

If you have a digital product, it is most likely not considered exempt even if it was launched before June 28th 2025. While there might be ambiguity in the definition of new or updated content, digital products require frequent software updates, altering the original content and potentially affecting the accessibility of the product.

How and when will the EAA be enforced?

All EU countries must pass their own laws and regulations for the enforcement of the EAA. Each country’s regulations will come into force on June 28th, 2025. Evaluation and surveillance, penalties, and other parameters related to enforcement and compliance will be determined by the relevant Member State’s laws.

Penalties will take into account “the extent of the non-compliance, including its seriousness, and the number of units of non-complying products or services concerned, as well as the number of persons affected”.

What are the requirements of the European Accessibility Act?

Unlike the earlier Web Accessibility Directive, the European Accessibility Act doesn’t reference a standard directly. Because of the wide range of products and services covered by the directive, Member States and their industry-specific regulatory bodies are encouraged to develop their own regulations for the enforcement of the EAA.

The accessibility requirements listed (Annex I) provide guidance in accordance with accessibility guidelines and principles, instead of referencing specific standards. These requirements intend to be technology-neutral in order to avoid over-specificity or to hamper innovation.

As high-level guidelines, products must be designed and produced to maximize their use by people with disabilities, as well as be accompanied by accessible information on their functioning and on their accessibility features.

Services are also required to provide information about the service and its accessibility features, as well as to make websites and mobile applications “accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust”.

This is a reference to the accessibility principles, also known as POUR.

Understanding requirements, standards and principles

So now that you know what the European Accessibility Act is and what it means for your digital product, it is time to understand the requirements so that you can develop an action plan.

You might have heard of the Web Content Accessibility Guidelines (WCAG) before. Maybe even the European standard EN 301 549. Do those matter here? And what do they have to do with the accessibility principles?

What are the POUR principles?

Developed by the World Wide Web Consortium (W3C), the accessibility principles provide the foundations for more accessible digital experiences. They are based on how people use web content and are represented by the acronym POUR, which stands for:

Perceivable

This principle requires you to ensure users can recognize and use your information with the senses that are available to them. This often means that information should be available via more than one sensory channel, taking into account vision and hearing impairments. Think of providing captions for multimedia, or making content accessible to a screen reader that can “read it aloud” for the user.

Operable

This principle requires you to ensure users can navigate and use your content, regardless of how they choose to access it. This often means that your interface and content can be operated via assistive technologies, like keyboard-based technologies or voice control.

Understandable

This principle requires you to ensure that your content, interface, and service are well understood. This often means paying attention to reading level and “using the same words in a consistent manner, in a clear and logical structure, so that people with cognitive disabilities can better understand them” (Annex II).

Robust

This principle requires you to ensure that your content can be interpreted reliably by a wide variety of user agents (including assistive technologies). The best way to make sure your content is compatible with current and future browsers, assistive technologies, and other user agents, is by following web standards (such as correct usage of semantic HTML or, if completely necessary, ARIA).

The POUR principles are the foundation of both WCAG and the EN 301 594 standard.

WCAG vs. EN 301 549, what’s the difference?

WCAG is the internationally recognized standard for web accessibility, and has been developed and evolved by the W3C over the past 20 years.

It is made up of a set of technology-agnostic recommendations for making websites and apps accessible to people with a wide range of disabilities, including visual, auditory, physical, speech, cognitive, language, learning, and neurological disabilities. Following these guidelines also helps make web content more usable by older individuals with changing abilities due to aging, and often improves usability for users in general.

EN 301 549 is the European standard of Accessibility requirements for Information and Communications Technology (ICT) products and services in the European Union. It is Europe’s extension to WCAG and currently references WCAG 2.1 AA (which is expected to be updated to WCAG 2.2 in the near future).

The EN 301 549 is the harmonized accessibility standard that is applied for procurement and selling to the public sector. This means that it contains the requirements for any company that wants to sell products or services to publicly funded organizations in the European Union.

It also expands beyond WCAG guidelines in certain areas, such as biometrics.

This standard is enforced through the Web Accessibility Directive (WAD).

EAA vs. WAD, what’s the difference?

The 2016 Web Accessibility Directive mainly applies to websites and apps in the public sector. The European Accessibility Act, on the other hand, extends to the private sector and goes beyond websites and apps. It covers both hardware and software, including ATMs, ticketing machines, e-readers, and e-books.

In addition, while the Web Accessibility Directive references WCAG 2.1 AA and the EN 301 549 standard, the EAA doesn’t establish a specific standard for compliance. However, the directive states that the accessibility requirements of the EAA “should be aligned to the requirements of the Web Accessibility Directive (WAD), despite differences, for example, in monitoring, reporting and enforcement”.

We can infer from this that WCAG 2.1 AA and the EN 301 549 standard will be helpful references to achieve compliance with the European Accessibility Act as well.

What are some common accessibility issues to solve for?

Once you understand the accessibility requirements and functional performance criteria listed in Annex I of the EAA, you can leverage them in your next step: assessing the current state of your accessibility support.

In order to estimate timeline, efforts, and budget for an accessibility remediation project, you want to start identifying common accessibility issues present in your product.

You can do so by considering how people interact with digital content. For example, users with different impairments (vision, hearing, mobility, cognitive) might:

use a keyboard instead of a mouse
change browser settings to make content easier to read
use a screen reader to “read” (speak) content aloud
use a screen magnifier to enlarge part of a screen
use voice commands to navigate a website.

From there, you can leverage the accessibility principles and WCAG as guidance to prevent or remove some of the following barriers:

Lack of text alternatives (“alt text”) for non-text content

Are there images on your site with information that users need in order to use your services, but can’t currently access if they have a visual impairment? These images should have alt text describing them, or they might contain the type of lengthy and relevant information that shouldn’t be an image in the first place.

The same goes for audio and video content lacking transcripts and captions, which can create barriers for people with hearing impairments.

These issues are connected to the Perceivable principle.

Content that can’t be used with a keyboard or other assistive technologies

If a user doesn’t have the mobility or dexterity to use a mouse, they might use a keyboard or voice commands to navigate your website. These users frequently encounter that some of the essential functionality of a website or app can’t be accessed through a keyboard or other forms of assistive technologies. This can include form controls, input and other user interface components.

You can test this by tabbing through your content and assessing if it can be operated with a keyboard in a way that makes sense. Does tabbing happen in a logical order? Can you see where the keyboard is focused on (known as “active focus”)?

Minimizing the use of mouse events or dynamic interactions (like swiping or dragging), and making sure there are alternatives to complex interactions, are also common accessibility improvements.

This is covered by the Operable principle.

Form fields that lack visible and meaningful labels, and difficulties recovering from errors

Another challenge that users frequently face when accessing digital content is filling out forms.

Form fields often lack clear labels and proper markup in HTML. Labels are important for screen readers to be able to “read them aloud”, or for someone to operate them through voice commands.

When the information entered is incorrect, users also face barriers identifying what went wrong and how to correct the error.

Labeling and grouping controls, making form controls keyboard-accessible, providing meaningful form instructions, validating user input, and providing clear notification about successful task completion or errors (and how to recover from them), are some of the steps to take in order to create accessible forms.

These are all part of the Understandable principle.

Content or interface elements that aren’t compatible with assistive technologies

Your website or application might contain important status messages or modal dialogs that “pop up” while navigating the content. If this type of interface elements aren’t marked up in a way that informs assistive technologies (e.g. a screen reader) of their presence and purpose, users that rely on these technologies for access might completely miss out on these messages, or be unable to take action.

When you ensure your content can be interpreted reliably by a wide variety of user agents (including assistive technologies), you are making your website or app compliant with the Robust principle.

Devising your accessibility plan

Now that you understand the European Accessibility Act and how it will affect your digital product, it’s time to plan your organization’s accessibility efforts to achieve compliance before June 28th 2025.

Your accessibility plan will depend on various factors, such as the size, purpose, tech stack, and audience of your product. While there is no one-size-fits-all approach, there are a few common steps every organization should follow.

Achieving compliance

Identify core parts of your digital product: Start by assessing your website or app against WCAG 2.1 to determine your level of conformance. Since it’s not feasible to audit all content, focus on a representative sample of critical user journeys, interactive features, and known problem areas.
Get an accessibility audit: If you don’t have an in-house expert, hire a professional auditor. They can identify accessibility issues, test your service with assistive technologies, and provide a comprehensive report detailing the problems and necessary fixes.
Develop a remediation plan: Use the audit results to estimate the design and development work needed for compliance. Apply an agile approach by first addressing the most serious issues and those affecting global components (elements present across your whole website or application).
Implement accessibility improvements and fixes: This one might be obvious, but addressing accessibility issues can only be done through manual intervention and development work in your product. Automated tools and accessibility overlays can’t ensure compliance or fix of most of the issues present in digital products. Read the Overlay FactSheet for more context.

Staying compliant

Upskill and get the whole team onboard: Accessibility encompasses all aspects of your digital presence, including the user interface, code, content, and interactions. Educate your team on the ways people interact with content to achieve and maintain compliance as your product evolves.
Think about accessibility from the start, and budget for it: Users have different needs in different circumstances. Avoid designing for perfect scenarios, and instead design, test, and budget for real life.
Research and test with disabled users: Gain insights into how disabled users and those using assistive technologies interact with your service. Hire disabled research participants and professionals who can help you carry out accessible product design and development.

Going beyond compliance

The EAA states that “accessibility should be achieved by the systematic removal and prevention of barriers, preferably through a universal design or ‘design for all’ approach, which contributes to ensuring access for persons with disabilities on an equal basis with others”.

Accessibility is not a one-time fix. In fact, it can be very expensive to audit and fix a product if the team designing and developing it hasn’t integrated accessibility in its processes from the start.

It is not a “problem” to solve either. Delivering equivalent experiences regardless of the device or ability of your users is an essential part of good product development.

Accessibility is one of the pillars of any long-term product strategy. Considering permanent and temporary disabilities, circumstance, and underlying biases makes for stronger, more successful products.

Accessibility beyond compliance can be achieved by consistently strengthening your process and educating your team.

What’s next

It might seem daunting to tackle accessibility on top of everything else your company does. But it doesn’t have to be.

The same focused, agile approach that is usually recommended for planning and development in the integration of security, reliability or scalability, can be applied for an efficient integration of accessibility into your software.

To ensure your digital presence is accessible to everyone, we offer comprehensive services to support your team. Let’s chat about how we can help you:

understand your current accessibility status
create an accessibility plan
remediate and improve accessibility
strengthen your organization’s skills and processes
develop inclusive solutions that work for all users, regardless of their device or ability.

Reach out to thoughtbot today to start creating a plan for your organization. Together we can create a more inclusive society where everyone has access to the services they need.