EAA Compliance Requirements for Media: It’s More Than Just Websites
Disclaimer: This guide is based on publicly available information and responses received from the Europe Direct Contact Centre (EDCC) and the Directorate General for Employment, Social Affairs and Inclusion. While we have interpreted the guidance to the best of our ability, this document does not constitute legal advice. Businesses should conduct their own due diligence and consult legal professionals or relevant authorities for formal compliance advice regarding the European Accessibility Act (EAA). We assume no liability for any decisions made based on this information.
The European Accessibility Act (EAA) is a landmark directive aimed at improving accessibility for products and services within the European Union (EU). With enforcement starting on 28 June 2025, businesses operating in the EU—or serving EU customers—must comply with the standards for media set out by the EAA.
This comprehensive guide explains EAA compliance requirements for media, including its impact on videos, advertisements, social media, and other public-facing content. It also provides practical examples of covered and non-covered products and services to help businesses understand their obligations and responsibilities.
Scope of the EAA for Media and Digital Accessibility
The EAA establishes media accessibility requirements for specific products and services. While the scope is much broader, here are some of the EAA requirements for digital media products and services, ensuring that individuals with disabilities can access content equally.
As you will see, EAA goes well beyond regulating websites:
Media-Related Products Covered by the EAA:
The EAA applies to devices and technologies that enable the distribution and consumption of digital media content:
Media Product Category
Examples
TV & Digital Broadcasting Equipment
Televisions, set-top boxes with accessibility features
Streaming Devices
Apple TV, Roku, smart TVs with accessibility functions
Computers & Operating Systems
Laptops, desktops, and tablets used for media creation and consumption
Smartphones & Telecommunications Equipment
Mobile devices used for video playback, content creation, and communication
These products must incorporate media accessibility features such as screen reader compatibility, adjustable contrast, captioning support, and assistive technology.
Media-Related Services Covered by the EAA:
The EAA also establishes media accessibility standards for digital media services, ensuring digital accessibility and equal access to content:
Media Service Category
Examples
Audiovisual Media Services
Streaming platforms like Netflix, YouTube, and broadcast television
Digital Publishing
Online newspapers, e-magazines, and e-books with media accessibility features
Telephony & Video Communication
Video conferencing tools (Zoom, Microsoft Teams) with captioning and transcription options
Social Media & Content Platforms
Platforms like Facebook, Instagram, and LinkedIn that distribute public-facing video content
Businesses providing these services must ensure their platforms comply with WCAG 2.1 AA accessibility standards, offering captions, transcripts, contrast adjustments, and screen reader support where applicable.
Other Products and Services Covered by the EAA
Beyond media, the EAA also applies to various consumer-facing products and services, such as:
Payment terminals and self-service machines, including ATMs and ticketing kiosks.
Consumer banking services, ensuring accessible online and mobile banking.
E-commerce platforms, which must meet accessibility requirements for browsing and transactions.
Transport services, such as e-ticketing and digital travel apps.
Emergency communication services, ensuring equal access to the 112 EU emergency number.
While these areas are not media-related, they illustrate the broad scope of the EAA's commitment to digital accessibility across industries.
Exemptions:
Pre-recorded media published before 28 June 2025
Online maps if essential information is provided in an accessible way
Websites or archives not updated after 28 June 2025
Microenterprises (fewer than 10 employees and less than €2 million turnover)
Clarifying EAA Scope: Expert Insights and Responses
To clarify the scope and requirements of the European Accessibility Act, we consulted the Europe Direct Contact Centre (EDCC) and the Directorate General for Employment, Social Affairs and Inclusion. Below are the questions we asked and the responses received:
Questions Asked:
Does the EAA apply to pre-recorded time-based media created after 28 June 2025, such as videos, slides, and office file formats?
Does this apply to both external and internal content, such as internal events, advertising, and social media?
Who holds the responsibility for ensuring compliance—the platforms (e.g., Microsoft, Facebook) or the companies producing the content?
Key Takeaways from Responses:
Pre-recorded time-based media created after 28 June 2025 must comply if it is part of a product or service within the EAA’s scope.
Internal content (e.g., employee training videos) is not covered, but external-facing media tied to covered products or services must comply.
Responsibility lies with the economic operators providing the product or service, not the hosting platforms.
For further information, consult the official directive here.
Who Is Responsible for Meeting EAA Accessibility Requirements?
The EAA applies to economic operators responsible for ensuring accessibility. Below is an overview of businesses subject to compliance, their obligations, and the types of media they need to make accessible:
Economic Operators
The responsibility for EAA compliance falls on manufacturers, service providers, and other economic operators, who must:
Ensure their products and services meet accessibility requirements.
Declare compliance through official documentation.
Cooperate with national authorities for compliance checks and corrective actions.
Hosting Platforms vs. Content Creators
Platforms like YouTube, Zoom, and Instagram are digital services that must meet EAA compliance requirements for media in the EU. However, their responsibilities differ from those of content creators.
Platforms (e.g., YouTube, Zoom, Instagram) as EAA-Covered Services
Must ensure their interface, navigation, and settings meet accessibility standards (e.g., screen reader compatibility, keyboard navigation).
Not responsible for ensuring user-uploaded content (e.g., videos, ads, webinars) complies with the EAA.
Content Creators (e.g., Coca-Cola, LEGO, L’Oréal) Are Responsible for Their Content
Companies must ensure the video accessibility of their ads, promotional videos, and webinars comply with EAA standards (e.g., captions, high contrast, no flashing elements).
Responsibility rests with the content creator, not the hosting platform.
Even Non-EAA Products and Services
Any public-facing digital content (e.g., ads, social media videos, or republished media) must still meet accessibility requirements if available on an external-facing EU platform–no matter if the product or the service is typically covered by the EAA.
Type of Company/Service
Examples
Covered Media Types
Excluded Media Types
EAA-Covered Companies/Services
Amazon, Barclays Bank, Microsoft, Netflix
Social media videos, ads, public webinars, external training videos
Internal training videos, internal webinars, video calls for internal purposes.
Non-EAA-Covered Companies/Services
Small local businesses (e.g., a bakery with under €2M revenue)
None, as their products/services are not regulated
All internal or external media unless tied to EAA-covered services.
Microenterprises (Exempt)
Local service providers (less then 10 employees)
None, as they are exempt entirely.
All internal and external media.
For example:
L’Oréal Video Ads: While the EAA does not cover L’Oréal’s cosmetics, any video ad released on a digital platform targeting the EU must adhere to the video accessibility requirements. This includes captions, adequate color contrast for text and visuals, avoidance of flashing content, and alt text for key imagery.
LEGO Social Media Videos: A promotional video for LEGO toys on Instagram is not subject to the EAA. However, if it targets an EU audience, it must still comply with accessibility standards. Its inclusive design must include captions, proper color contrast, and alternative text for visuals.
Key Takeaway: Accessibility standards apply to the content itself, not just the underlying product or service. Media intended for the public must be accessible—regardless of whether the company is directly regulated under the EAA.
Specific Requirements for EAA Media Accessibility
The following requirements must be met for media, including videos, webinars, and advertisements, to comply with the EAA:
Category
Requirement
Details & Implementation
Captions & Subtitles
Mandatory for all video content
Must be accurate and support users with hearing impairments.
Ensure sufficient colour contrast (4.5:1 for normal text, 3:1 for large text) against backgrounds.
Required for videos, training materials, webinars, ads, and social media videos.
Audio Descriptions
Required for videos with visual-only information
Must provide audio descriptions for individuals with visual impairments.
Necessary when critical information is conveyed visually and not covered in audio.
Applies to training videos, webinars, and advertisements.
Colour Contrast
Text and visuals must meet WCAG 2.1 AA standards
Text overlays, captions, and subtitles must meet contrast ratio 4.5:1 for normal text, 3:1 for large text.
Text-based graphics and icons must meet contrast standards.
Interactive elements (buttons, links, player controls) must remain distinguishable for visually impaired users.
Screen Reader Compatibility
All text-based content must be accessible
Slides, images, and text within videos must be readable by screen readers.
Ensure proper alt text for images in social media videos.
Keyboard Navigation
Media controls must be fully operable via keyboard
Media players, buttons, links, and controls must support keyboard navigation.
Users must be able to play, pause, and navigate without requiring a mouse.
Flashing Content
Avoid rapid flashing visuals
Videos must not include flashing content that exceeds accessibility thresholds.
Helps prevent seizures in individuals with photosensitive epilepsy.
Audio Quality
Ensure clear and understandable audio
Audio must be clear and easy to understand, with background noise minimised.
Important for videos, webinars, and advertisements.
Training Videos & Tutorials
Must follow video accessibility requirements
Captions and transcripts required.
Screen reader compatibility for slides and text-based content.
Audio descriptions for visuals that convey critical information.
Maintain proper colour contrast for text and visuals.
Webinars & Public Video Calls
Live accessibility features required
Live captions or post-event transcripts must be provided.
Use platforms with built-in accessibility tools (e.g., Zoom, Microsoft Teams).
Audio descriptions for shared visuals when necessary.
Ensure high colour contrast and avoid cluttered visuals in slides.
Video Ads
Must follow video accessibility best practices
Captions are mandatory.
Audio descriptions for non-verbal visuals.
No flashing content that may trigger seizures.
Maintain sufficient colour contrast for all text and graphics.
Social Media Videos
Ensure accessibility for diverse audiences
Captions required for all video content.
Alt text for images to assist visually impaired users.
Text overlays must have sufficient contrast for readability.
Audio descriptions for critical visuals when required.
General Checklist for WCAG 2.1 AA Audits
Here’s what you need to do when conducting WCAG 2.1 AA audits to identify accessibility gaps.
Add captions, audio descriptions, and transcripts to all public-facing media.
Ensure text overlays, captions, and visuals meet colour contrast standards.
Use accessible file formats and ensure compatibility with assistive technology.
Train marketing, content, and technical teams on creating accessible media.
Test content for keyboard navigation and screen reader compatibility.
Real-World Examples of EAA Compliance in Practice
The following tables provide real-life examples of how the EAA applies to different types of media. They illustrate which media require compliance and the specific accessibility features needed.
EAA Products/Services Compliance Table
Covers media explicitly subject to EAA requirements, outlining necessary accessibility standards.
Media Type
EAA Products/Services
Covered by the EAA?
Compliance Notes
Training Videos (Internal)
Customer support training at Vodafone
No
Not covered under the EAA, but anti-discrimination laws apply. Employers should provide reasonable accommodations for employees with disabilities (e.g., captions or transcripts).
Training Videos (External)
Software tutorials by SAP
Yes
Covered if tied to public-facing services. SAP must ensure its training videos meet WCAG 2.1 AA standards, including captions, transcripts, screen reader compatibility, colour contrast, and audio description for key visuals. Additionally, if the videos are distributed on a public platform (e.g., YouTube, corporate websites), they must meet accessibility standards regardless of whether they are promoting a covered service or not.
Webinars (Public)
Financial services webinar by Barclays
Yes
Covered if promoting financial services within EAA scope. Barclays must provide captions, transcripts, and ensure the accessibility of shared slides (e.g., proper colour contrast and screen-reader compatibility). If the webinar is made available to the public on digital platforms (e.g., YouTube, LinkedIn), accessibility compliance is required regardless of whether the underlying financial service is directly regulated by the EAA.
Webinars (Internal)
Technical strategy at IBM
No
Not covered, but IBM must provide reasonable accommodations for employees with disabilities, such as captions, alternative text for visuals, and accessible document formats.
Video Ads
Amazon Prime delivery promotions
Yes
Covered if related to EAA-covered services. Amazon must ensure its video ads comply with accessibility requirements, including captions, high-contrast text, no flashing visuals, and audio descriptions where necessary. Additionally, all Amazon Prime-related ads on public-facing platforms (e.g., YouTube, Instagram, Facebook) must meet accessibility standards, even if they promote non-EAA-regulated services.
Social Media Videos
App feature highlights by PayPal
Yes
Covered if tied to EAA-covered financial services. PayPal must ensure videos meet accessibility standards, including captions, alt text for images, proper colour contrast, and keyboard navigation compatibility. Furthermore, if the video is posted on social media platforms (e.g., YouTube, TikTok, Instagram) targeting an EU audience, accessibility compliance is mandatory, regardless of the service being advertised is directly regulated by the EAA. This includes ensuring captions, proper contrast, and alternative text for key visuals, as well as avoiding flashing content that could trigger photosensitivity concerns.
Archived Media
Archived financial reports by Deutsche Bank
No
Not covered if unchanged post-2025. However, if updated or republished in a new format (e.g., an interactive website, multimedia reports, or digital PDFs), Deutsche Bank must ensure full accessibility compliance. If these reports are made available on external-facing platforms (e.g., corporate websites, government portals, financial media sites), they must also meet EAA standards, including screen-reader compatibility, proper text contrast, and alternative text for visuals.
Non-EAA Products/Services Compliance Table
Lists media types not directly covered but that may still require accessibility features when distributed on public platforms.
Media Type
Non-EAA Products/Services
Covered by the EAA?
Compliance Notes
Training Videos (Internal)
Employee policy training at Nestlé
No
Not covered under the EAA, but anti-discrimination laws apply. Employers should provide reasonable accommodations for employees with disabilities (e.g., captions, transcripts, or sign language interpretation).
Training Videos (External)
Appliance maintenance tutorials for a home appliance by Bosch.
No
Bosch's maintenance tutorials for standard home appliances (e.g., fridges) are not covered under the EAA. However, if they are part of a smart home or IoT service (e.g., Bosch Home Connect app), they must comply with accessibility standards, including captions, transcripts, and screen-reader compatibility. Additionally, if these videos are hosted on a public-facing platform (e.g., YouTube), they must meet accessibility standards such as captioning, screen-reader compatibility, and proper colour contrast.
Webinars (Public)
Sustainability webinar by Coca-Cola
No
Not covered unless promoting an EAA-covered digital service (e.g., a sustainability tracking app). If promoting an EAA-covered service, it must meet accessibility standards, including captions, transcripts, accessible slides, and alternative descriptions for visual content. Additionally, if the webinar is made available on a public-facing digital platform (e.g., YouTube, LinkedIn), Coca-Cola must ensure the content meets accessibility requirements, regardless of whether the underlying service is covered by the EAA.
Webinars (Internal)
Corporate goals webinar at Unilever
No
Not covered, but Unilever must provide accessibility accommodations for employees with disabilities, such as captions, accessible slide formats, and screen-reader compatibility for digital content. If the webinar is later published or made available externally on a public-facing platform (e.g., a company YouTube channel, LinkedIn), it must comply with accessibility standards under the EAA.
Video Ads
Product ads by L’Oréal
No
L’Oréal’s physical product ads (e.g., cosmetics) are not covered under the EAA. If the ad promotes an EAA-covered digital service (e.g., an online consultation platform), then full accessibility compliance is required. Regardless of the underlying product or service, any digital ad published on an external platform (e.g., YouTube, Facebook, Instagram) must meet accessibility standards, including captions, high colour contrast, no flashing elements, and alternative text for critical visuals.
Social Media Videos
Brand awareness videos by LEGO
No
Not covered under the EAA if promoting physical LEGO products (toys, sets, merchandise). However, if the video promotes an EAA-regulated digital service (e.g., LEGO’s online store, educational apps, digital subscriptions), it must comply with accessibility standards, including captions, proper colour contrast, alternative text for visuals, and screen-reader compatibility. Regardless of whether the video promotes a covered service, if it is published on a public platform (e.g., YouTube, Instagram, TikTok) targeting an EU audience, it must still meet accessibility standards. This includes captions, colour contrast compliance, alternative text for key visuals, and avoiding flashing content.
Archived Media
Archived marketing campaigns by P&G
No
Not covered if unchanged post-2025. However, if republished in a new format (e.g., as an interactive digital experience, a redesigned online campaign, or reposted on a public website or video platform), accessibility compliance would be required. This includes ensuring screen-reader compatibility, captions for video-based content, proper contrast for visuals, and alternative text for images. Even if the content was originally exempt, republishing or modifying it for an EU-facing audience means accessibility requirements apply.
Legal Framework: Risks, Consequences, and Legal Obligations
Failing to meet accessibility standards under the European Accessibility Act (EAA) and broader anti-discrimination laws can have far-reaching consequences. Beyond legal penalties, businesses risk:
Loss of partnerships and contracts (companies prefer accessible vendors)
Missed market opportunities (global expansion hindered by non-compliance)
Prioritising accessibility is not just a regulatory requirement—it is a business imperative that impacts long-term growth, brand reputation, and operational success.
Immediate Consequences of EAA Non-Compliance
Non-compliance leads to fines, reputational risks, and lost business opportunities. Accessibility is a competitive advantage that enhances brand credibility and long-term operational success.
Regulatory and Legal Risks
Fines, audits, and enforcement measures: The EAA (effective June 2025) mandates strict accessibility compliance, with financial penalties for non-adherence. In Germany, potential fines for non-compliance can go up to €50,000 per violation, and other EU countries have fines based on national regulations.
Increased oversight: Regulatory bodies will conduct audits and enforce corrective measures, increasing compliance urgency.
Customer and Stakeholder Expectations
Growing demand for inclusivity: Customers expect accessible content, not just for compliance but for equitable access.
Business partnerships at risk: Organisations increasingly favor vendors with strong accessibility practices, making compliance a competitive differentiator.
Brand and Reputation Damage
Avoiding reputational harm: Non-compliance—or perceived exclusionary practices—can lead to negative press, social media backlash, and diminished brand trust.
Aligning with corporate values: A commitment to accessibility enhances corporate responsibility efforts and credibility.
Operational and Financial Burdens
Costly retroactive fixes: It is more efficient to address accessibility early in content creation than to make expensive post-production corrections.
Scalable and future-proof content: Embedding accessibility best practices from the outset ensures long-term efficiency as regulations evolve.
Missed Market Opportunities
Expanding beyond compliance: Accessible content benefits not just users with disabilities, but also international audiences, non-native speakers, and diverse user demographics.
A competitive edge in global markets: Accessibility ensures better positioning for growth, international expansion, and broader consumer engagement.
Legal Frameworks Beyond EAA Compliance Requirements for Media
While the EAA primarily regulates public-facing products and services, accessibility obligations extend beyond it. Employers and organisations must also comply with anti-discrimination laws, workplace regulations, and national accessibility policies.
Law / Directive
Key Accessibility Obligations
EU Employment Equality Directive (2000/78/EC)
Requires employers to provide reasonable accommodations for employees with disabilities. Includes ensuring accessible training materials, digital tools, and workplace resources.
National Legislation
Many EU countries have additional workplace accessibility laws, extending obligations for employers and service providers.
Workplace Accessibility & Employee Rights
Employers must proactively address accessibility to avoid legal disputes, reputational harm, and regulatory penalties. Employees can legally challenge inaccessible workplace content if:
Training materials (videos, documents, or digital tools) lack captions, transcripts, or screen-reader compatibility.
Employers fail to provide reasonable accommodations after being informed of an accessibility barrier.
Complaint Procedures & Escalation Pathways
Ensuring accessibility compliance requires a clear and structured complaint resolution process. If accessibility issues arise, the following steps outline the path to resolution:
Internal Complaint Submission
Employees file complaints with HR or an accessibility officer.
Consumers report accessibility concerns via company feedback channels.
Investigation & Response
The company must assess the complaint, provide a resolution timeline, and implement corrective measures.
If unresolved, the complaint may escalate.
Escalation to National Authorities
If internal complaints are ignored or inadequately addressed, individuals can escalate issues to national authorities.
Authority
Role
National Equality Bodies
Enforce anti-discrimination laws and workplace accessibility policies.
Regulatory agencies
Monitor and enforce EAA compliance.
Legal Actions & Litigation
Employees or consumers can take legal action if a company fails to address accessibility barriers.
Cases may be handled by national courts or administrative enforcement agencies.
Final Takeaway: Why EAA Matters for Media
Accessibility is no longer optional—it is a fundamental requirement for businesses operating in the EU or serving EU customers. The European Accessibility Act (EAA) extends far beyond websites, covering digital media, advertisements, streaming services, and social platforms.
Companies must take proactive steps to ensure their public-facing content complies with WCAG 2.1 AA standards, including captions, audio descriptions, color contrast, and screen reader compatibility.
Failing to meet accessibility standards carries serious risks: regulatory fines, reputational damage, lost partnerships, and increased operational costs due to retroactive compliance fixes.
Beyond legal obligations, accessibility fosters brand trust, customer loyalty, and business growth by ensuring accessible content, inclusive for all users, including individuals with disabilities
By meeting EAA compliance requirements and inclusive design for media into content creation from the outset, businesses can future-proof their operations, reduce compliance risks, and tap into new markets. A commitment to accessibility demonstrates corporate responsibility, enhances user experience, and positions businesses as leaders in inclusivity and innovation.
Companies prioritising inclusive design and accessible content today will not only meet legal requirements but also gain a competitive edge in an increasingly digital and diverse global market.
Are you prepared for the new EAA legislation?
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