The European Accessibility Act (EAA)
Compliance Requirements and Guidelines

Understand what the European Accessibility Act covers, how it differs from other accessibility laws, and the practical steps your organization needs to take to achieve EAA compliance across EU markets.

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Intended to introduce more accessible products and services on the market, lower prices for such offerings, and create more accessibility-related jobs, the European Accessibility Act (EAA) is a directive of the European Union that legally requires EU member states to enact various accessibility requirements.

The Act has significant and far-reaching effects for organizations operating within the EU. Most importantly, it provides EU member states with a set of common accessibility rules to follow, bringing greater cohesion and consistency to cross-border commerce and consumer-facing digital services.

Significantly, the EAA applies not just to public-sector organizations—as was the case with previous EU legislation like the EU Web Accessibility Directive—but also to selected private organizations. The EAA came into force on June 28, 2025, and enforcement is now active across EU member states.

What Is the European Accessibility Act?

The European Accessibility Act is an EU directive adopted in 2019 that harmonizes accessibility requirements across all member states. Unlike regulations that apply directly, a directive requires each member state to transpose the requirements into national law—meaning enforcement mechanisms and specific penalties vary by country.

The EAA's core purpose is threefold:

Expand market access — Create a larger EU market for accessible products and services
Reduce fragmentation — Replace country-specific accessibility rules with harmonized standards
Protect consumers — Ensure people with disabilities can access essential products and services

The directive builds on the legal foundations of the Treaty on the Functioning of the European Union, particularly provisions related to the internal market and free movement of goods and services.

What Does the EAA Cover?

The European Accessibility Act covers specific categories of products and services that are essential to daily life and economic participation.

Products Covered

Computers and operating systems — Desktop, laptop, and tablet hardware and software
Self-service terminals — ATMs, ticketing machines, check-in kiosks, and payment terminals
Telephones and smartphones — Consumer communication devices
TV equipment — Hardware related to digital television services
E-readers — Dedicated devices for reading digital books and publications

Services Covered

Telephony services — Voice communication and related equipment
Audio-visual media services — Streaming platforms, broadcast services, and related content
Transportation services — Air, bus, rail, and waterborne passenger transport (websites, mobile apps, ticketing, and real-time travel information)
Banking services — Consumer banking, including online banking and ATMs
E-books — Digital publications and the platforms that deliver them
E-commerce — Online retail and e-commerce services

It is important to note that the EAA applies to products and services sold or used within the EU—irrespective of where the businesses providing them are located. A US-based e-commerce company selling to European consumers must comply with EAA requirements.

EAA vs. ADA: What's the Difference?

Organizations operating in both the US and EU need to understand how these laws differ.

The Americans with Disabilities Act (ADA)

The ADA is a US civil rights law that prohibits discrimination against people with disabilities. For websites, courts have interpreted Title III to require accessibility for places of public accommodation, though the law doesn't specify technical standards. Most organizations reference WCAG as the benchmark, but there's no formal codification for private businesses.

Key characteristics:

Broad civil rights law covering employment, public services, and public accommodations
Primarily enforced through private lawsuits
No explicit technical standard (WCAG used as litigation benchmark)
Applies based on US presence and public accommodation status

The European Accessibility Act (EAA)

The EAA is a product-specific directive that mandates accessibility for defined categories of goods and services sold in the EU market. It explicitly references EN 301 549 and WCAG as technical standards.

Key characteristics:

Directive focused on specific product and service categories
Enforced through national market surveillance authorities
Explicit technical standards (EN 301 549 referencing WCAG 2.1)
Applies based on EU market presence, regardless of company location

Practical Differences

Aspect ADA EAA Scope Broad civil rights law Specific product/service categories Technical standard WCAG (informal benchmark) EN 301 549 / WCAG 2.1 AA (explicit) Enforcement Private lawsuits National authorities, market surveillance Penalties Court-determined damages Up to €100,000 or 4% annual revenue Geographic trigger US operations EU market sales Organizations serving both markets should target WCAG 2.1 Level AA as the baseline that satisfies both frameworks.

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EAA Accessibility Requirements: EN 301 549 and WCAG

The European Accessibility Act uses the European standard EN 301 549 as its technical foundation. EN 301 549 has adopted the Web Content Accessibility Guidelines (WCAG) 2.1, covering accessibility for web content, electronic documents, and non-web software such as native mobile apps.

Current and Future Standards

The current harmonized standard is EN 301 549 v3.2.1, which references WCAG 2.1 Level A and AA. The next version (v4.1.1), expected in 2026, is planned to incorporate WCAG 2.2.

EN 301 549 covers conformance to both WCAG 2.1 Level A and AA, but not Level AAA—enabling more seamless harmonization with other procurement standards. However, web authors and accessibility specialists are encouraged to improve and extend accessibility beyond the outlined standards where applicable.

The Four Principles of Accessibility (POUR)

WCAG 2.1's four principles of accessibility are covered by EN 301 549:

Perceivable — Information and user interface components must be presented in ways that users can perceive clearly. This includes providing text alternatives for non-text content, captions for audio-visual content, and sufficient color contrast.

Operable — Functionality and navigation must be usable by all. This includes keyboard accessibility, sufficient time to read content, and avoidance of content that causes seizures.

Understandable — Information and user interface operation must be easily understood by people of differing abilities. This includes readable text, predictable behavior, and input assistance.

Robust — Content must be reliably interpreted across a range of assistive technologies and adapt to new user agents. This requires valid code and proper ARIA implementation.

EAA Compliance Checklist

To comply with the EAA, organizations must ensure their digital products and services meet EN 301 549 requirements. Here's a structured approach:

Step 1: Assess Your Scope

Determine which products and services fall under EAA requirements:

Identify all consumer-facing digital products sold in EU markets
Map websites, mobile applications, and self-service terminals
Document third-party components and service providers

Step 2: Conduct an Accessibility Audit

Evaluate current accessibility against EN 301 549 / WCAG 2.1 Level AA:

Run automated scans to identify machine-testable issues
Conduct manual testing with keyboard navigation and screen readers
Test with actual users with disabilities where possible

Remember: Automated tools catch only 30-40% of accessibility issues. Manual testing is essential.

Step 3: Remediate Accessibility Issues

Address identified barriers systematically:

Prioritize high-impact issues affecting core user journeys
Fix perceivable issues (alt text, captions, contrast)
Resolve operable issues (keyboard access, timing, navigation)
Address understandable issues (labels, error messages, consistency)
Ensure robust implementation (valid code, ARIA)

Step 4: Create Required Documentation

The EAA requires organizations to document their accessibility efforts:

Accessibility Statement — A public declaration of your commitment to accessibility, including:

Conformance status (full, partial, or non-conformance)
Known limitations and remediation plans
Contact information for accessibility feedback
Date of last assessment

Technical Documentation — Internal records demonstrating how products meet accessibility requirements.

Step 5: Establish Ongoing Monitoring

Accessibility is not a one-time project:

Schedule regular automated scans
Conduct periodic manual audits
Train content creators and developers
Monitor and respond to user feedback

Why Accessibility Overlays Don't Work for EAA Compliance

The European Commission has published a statement on accessibility overlays regarding the challenges of using these types of solutions.

It states: "Claims that a website can be made fully compliant without manual intervention are not realistic, since no automated tool can cover all the WCAG 2.1 level A and AA criteria… In other words, overlay tools may make a website less accessible for some users."

The conclusion is clear: overlays and widgets cannot substitute the manual work needed to ensure full compliance with EN 301 549. Organizations relying on overlays risk both non-compliance and creating additional accessibility issues for users with disabilities.

EAA Exemptions and Exceptions

Micro-Enterprise Exemption

Some organizations are exempt from the EAA based on "disproportionate burden." Micro-enterprises are defined as companies with:

Fewer than 10 employees, AND
Annual turnover of less than €2 million

Such organizations are exempt because achieving compliance would either change the core nature of their product/service or create undue financial burden.

Content Exceptions

The directive does not apply to the following types of content on websites and mobile apps:

Pre-recorded time-based media published before June 2025
Office file format documents published before June 2025
Online maps (though navigational information must be provided in accessible format)
Third-party content entirely outside the website owner's control
Heritage collection reproductions too fragile or expensive to digitize accessibly
Archival content not needed for active administrative purposes and no longer updated
Educational institution websites (schools, kindergartens, nurseries)—except for administrative functions

EAA Enforcement and Penalties

Violations of the EAA are penalized according to national laws. Each EU member state has transposed the directive into national legislation with country-specific enforcement mechanisms.

Penalty Framework

The EAA requires that penalties be "effective, proportionate, and dissuasive." In many jurisdictions, penalties can reach:

Up to €100,000 per violation
Up to 4% of annual revenue for serious or repeated non-compliance

Enforcement Mechanisms

Member states enforce the EAA through:

Market surveillance authorities — Monitor products and services for compliance
Consumer complaints — Individuals can report non-compliant products
Administrative orders — Authorities can require remediation or remove products from market

Organizations found non-compliant may face product withdrawal from EU markets, public disclosure of violations, and ongoing regulatory scrutiny.

Multi-Market Compliance Strategy

For organizations operating across multiple EU member states—or globally—a coordinated compliance strategy is essential.

Harmonized Approach

Since the EAA creates common requirements across all member states, organizations can implement a single accessibility standard (EN 301 549 / WCAG 2.1 Level AA) that satisfies requirements everywhere in the EU.

Country-Specific Considerations

While technical requirements are harmonized, enforcement and penalties vary by jurisdiction. Organizations should:

Monitor national implementation in key markets
Understand local complaint and enforcement procedures
Maintain relationships with national accessibility authorities

Global Accessibility Program

Organizations serving both EU and US markets should build accessibility programs that satisfy both EAA and ADA requirements. WCAG 2.1 Level AA serves as the common baseline, with additional attention to:

EN 301 549 requirements for non-web software and hardware
Documentation requirements specific to each jurisdiction
Ongoing monitoring across all digital properties

Benefits of EAA Compliance

Beyond avoiding penalties, EAA compliance creates business value:

Expanded Market Access

The EAA serves as an incentive for companies to produce more accessible products and services. As requirements apply across all EU member states, the market for accessible offerings expands significantly.

Consumer Benefits

Consumers with disabilities gain access to more products and services, while accessibility improvements often benefit all users through better usability and design.

Competitive Advantage

Organizations that achieve EAA compliance early position themselves as accessibility leaders, potentially winning business from competitors who lag behind.

Cross-Border Efficiency

Harmonized requirements eliminate the need to navigate country-specific accessibility rules, reducing compliance complexity for cross-border operations.

How Acquia Can Help

Acquia Web Governance's Web Accessibility Module audits your entire site for digital accessibility against WCAG 2.1 and 2.2 success criteria (and subsequent updates to the guidelines).

Each audit scans your site for machine-testable issues, provides detailed reports for reviewing errors, gives targeted recommendations based on the guidelines, and shows your compliance status across WCAG Levels A, AA, and AAA. Track and prove your accessibility compliance progress via reports in the History Center.

We also offer accessibility training to ensure your team is well-versed in both automated and manual remediation methods, enabling efficient and consistent improvement of your website's accessibility.

Acquia provides free tools to complement your accessibility efforts:

Color Contrast Checker — Test compliant color combinations for web design
Accessibility Statement Generator — Meet EAA requirements by producing a public statement declaring your commitment to web accessibility

Disclaimer

The information in this article is provided by Acquia Inc. and/or its subsidiaries and affiliates for informational purposes only, offering a general understanding of current legal developments. It should not be construed as specific legal advice, and no attorney-client relationship exists between you and Acquia Inc. This article should not be used as a substitute for competent legal advice from a licensed attorney in your jurisdiction.