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The legal implementation of the European Accessibility Act across the EU’s 27 member states by June 2025. This concerns you even if you’re not a member of the EU, this legislation concerns you if:
- You have a branch in the EU.
- You have training for employees/contractors/clients residing in the EU.
- You are distributing any pre-recorded content to EU members (including recorded video calls, workshops, and webinars).
These are some common scenarios, but they are far from the only ones. To be on the safe side, consider EAA every time you deal with EU clients or staff from a business perspective.
In this post, we’ll tell you everything you need to know about the European Accessibility Act so that can stay compliant.
EAA: The Background
According to estimates from the World Health Organization, there are at least 135 million people with one or more disabilities living in Europe today. It’s been shown that people with disabilities face not only greater unmet health needs and poorer health outcomes but also continuing widespread barriers to online access.
That’s why the European Union (EU) created a directive titled the European Accessibility Act (EAA). The primary goal is to improve trade between EU member states by implementing local laws that require a minimum accessibility threshold for products or services that are primarily consumer-focused.
Put simply, the EAA is intended to ensure that people with disabilities have equal access to all products and services. However, it also improves the online experience for users of all abilities.
Compliance with the EAA ensures a more inclusive user experience, increased market reach, and improved brand reputation for businesses. It also reduces the risk of a myriad of legal issues.
Taken on average the spending power of people with disabilities is over 16 billion GBP in disposable income, so ensuring EAA compliance can help businesses reach new customers with considerable spending power.
In addition, evidence has shown that there is a business case for integrating accessibility requirements. Accessibility features in products and services help drive innovation and competitive advantage. For example, auto-complete was initially provided for people with disabilities but has become widely popular with all users, regardless of ability.
European Accessibility Act (EAA) 2025: Summary
Here’s a list of key facts related to the EAA and its implementation:
- EAA was built to complement the EU Web Accessibility Directive, a law implemented in 2016 in order to provide better access to public sector websites and mobile applications for people with disabilities.
- According to the EAA, “people with disabilities” are individuals with long-term physical, mental, intellectual, or sensory impairments that prevent them from full, effective, and equal societal participation due to barriers to accessing products and services; elderly people are also included under this definition.
- EAA applies to all businesses, public and private, that provide products and services within the EU (regardless of where they are based), have more than 10 employees, and have a global turnover exceeding €2 million.
- The only exception to the EAA is businesses for whom compliance would cause an “undue burden,” meaning it would financially overburden them or change the entire nature of their offered product or service.
- The law applies to both online and physical domains of businesses, including (but not limited to): e-commerce and online service providers, shops and restaurants, airlines and transport agencies, healthcare organisations, financial companies, media streaming and telephony providers, and tech manufacturers and distributors.
- The EAA requirements represent the minimum accessibility thresholds, which means that each member state is free to impose local laws that go beyond the EAA requirements.
- By June 28, 2025, each member state is required to implement the requirements of the EAA.
- By that date, businesses must audit and ensure that their products and services meet the minimum accessibility requirements as stated by local laws, under the threat of potential penalties ranging from fines up to €60,000 to imprisonment for up to 18 months.
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European Accessibility Act Audit
As mentioned above, businesses that provide products and services in the EU, even if they are not based in the EU, have until June 2025 to comply with the EAA-compliant local laws of each member state.
Businesses with fewer than 10 employees and a global turnover below €2 million are excluded from this requirement but are nevertheless strongly encouraged to comply with the EAA if this compliance does not pose an “undue burden” to their successful functioning.
To begin this process, businesses must first conduct an audit of their products or services to check whether they meet the local accessibility requirements that are EAA-compliant. If they fail that audit, businesses are then required to update those products and services so that they are fully compliant with the EAA and the local and/or regional laws.
In practical terms, this means that businesses must test their products and services, identify areas that are not EAA-compliant, assess whether the required alterations would pose an “undue burden,” and then make necessary changes to them in order to be in compliance by the June 2025 deadline. User testing may be required to ensure full EAA compliance.
European Accessibility Act Requirements
The first step in the EAA compliance audit is ensuring that your business follows the guidelines established by Web Content Accessibility Guidelines (WCAG) 2.0. These guidelines represent the golden international standard for making web content accessible to all users, including people with disabilities.
Reed Smith’s article reminds people that non-compliance can range from fines to criminal sentences. Following the WCAG 2.0 guidelines means making your content:
- Perceivable - meaning that all users of your products and services must be able to accurately see and read your content, including users with vision loss, hearing loss, and other disabilities (e.g., providing text alternatives for non-text content)
- Operable - meaning that all website content must be responsive and easy to navigate by all users, including users with motor disabilities (e.g., making every function usable by the keyboard rather than the mouse)
- Understandable - meaning that all content must be easy to use and navigate and include language that is understandable to all users, including users with cognitive disabilities (e.g., avoiding technical jargon and regional slang)
- Robust - meaning that all website content must be compatible with a wide variety of assistive technology tools that are commonly used by individuals with motor and other disabilities (e.g., the use of screen-reading software for text content)
Note that the EAA itself doesn’t include specific technical accessibility standards required for compliance. That means most businesses will use WCAG 2.1 Level AA requirements (where A is the minimum and AAA is the maximum compliance standard) to ensure their compliance.
This conformance level is already the basis for legal accessibility standards in the United States through the Americans with Disabilities Act (ADA) and Section 508.
European Accessibility Act Timeline
Here are the key dates that are important to remember in the European Accessibility Act timeline:
- EAA was originally proposed in 2011, became law in 2016, and officially took effect in April 2019
- By June 28, 2022, each member state was required to adopt and publish local laws and regulations that comply with the EAA
- This EU Commission tracker lists legislative efforts by each member state and the current status of their compliance with the EAA
- By June 28, 2025, each member state is required to implement and enforce the requirements of the EAA
- Products and services that existed before the June 2025 deadline will have an additional 5-year grace period until June 2030 to fully comply with the EAA; after that date, all products and services must be EAA-compliant
There is still much to be done to ensure that all products and services are accessible to people with disabilities.
According to WebAIM's 2024 report on the accessibility of the top million home pages, there were an average of 56.8 errors per page, a notable increase from the 2023 report.
WCAG 2 failures were found on 95.9% of home pages, and the most common errors included low-contrast texts, missing alternative text for images, missing form input labels, and empty links and buttons.
The deadline for EAA compliance is fast approaching, so businesses have no time to waste to ensure their products and services are fully accessible to all users, including users with disabilities.
