The European Accessibility Act (EAA)

Get an overview of what the European Accessibility Act means for web accessibility and how to ensure compliance.

What is the European Accessibility Act (EAA)?

Intended to introduce more accessible products and services on the market, lower prices for such services, 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 will have significant and far reaching effects for online organizations operating within the EU. Most importantly, it will provide EU member states with a set of common accessibility rules to follow, which will theoretically bring about greater cohesion and consistency to the area as a whole.

Who has to comply with the EAA?

Significantly, the new Act applies not just to public sector organizations, as was the case with previous EU legislation - the EU Web Accessibility Directive, but also to selected private organizations.

The European Accessibility Act will cover the following products and services:

Computers and operating systems
ATMs, ticketing, and check-in machines
Telephones and smartphones
TV equipment related to digital television services
Telephony services and related equipment
Audiovisual media services
Services related to air, bus, rail, and waterborne passenger transport
Banking services
E-books
E-commerce

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 said products and services are located.

Are You EAA Compliant?

Get a complimentary scan to check for your compliance with the European Accessibility Act.

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What web accessibility standards does the EAA use?

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

WCAG and the EAA

EN 301 549 covers conformance to both WCAG 2.1 level A and AA, but not level AAA, which enables a more seamless harmonization with other procurement standards. It is important to note that web authors and procurement accessibility specialists are encouraged to improve and extend the accessibility of websites and apps beyond the outlined standards where applicable and relevant, however.

WCAG 2.1’s four principles of accessibility: perceivable, operable, understandable, and robust are covered by EN 301 549.

Perceivable
The information and user interface components of websites and mobile applications must be presented in a way that enables users to perceive them clearly.

Operable
The functionality and navigation of the web and mobile user interface components must be usable.

Understandable
The information and operation of the web and mobile user interface must be easily understood by people of differing abilities.

Robust
The content of the website must have the ability to be interpreted reliable across a range of assistive technologies, and have the ability to adapt to new user agents.

EN 301 549 also specifies the functional accessibility requirements for ICT products and services, including web content, which could be used in public procurement or to support other policies and legislation.

How to comply with the European Accessibility Act

To comply with the EAA, organizations must ensure that they are taking the necessary measures to make their websites and mobile applications accessible by following the WCAG principles of perceivable, operable, understandable, and robust. The deadline for compliance is expected to be June 28, 2025.

Are accessibility overlays a good option for compliance?

The European Commission has published a statement on accessibility overlays regarding some of the challenges of using these types of accessibility 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 from their statement is that overlays and widgets cannot substitute the manual work needed to ensure full compliance with EN 301 549, which references WCAG 2.1 AA.

Not based in the EU?

It is important to note that even if your organization is not based in the EU, you will still be expected to comply with the EAA’s requirements when operating within any of its member states.

Benefits for businesses and consumers

The EAA will serve as an incentive for companies to produce more accessible products and services. As its requirements will apply to all EU member countries, and not simply to those countries who have already established their own accessibility regulations, the market for accessible offerings will greatly expand.

This, in turn, will benefit consumers, who will have more accessible products and services made available to them.

Are any organizations exempt from the EAA’s requirements?

There are some organizations, referred to as "micro-enterprises," that are exempt from the Act, based on the fact that its requirements would cause them "undue burden."

Micro-enterprises are defined as companies with fewer than 10 employees and with an annual turnover of less than two million Euros. Such organizations are exempt from the EAA’s requirements, as for them achieving compliance would either mean changing the core nature of the product or service they offer or becoming financially overburdened.

In addition, the directive does not apply to the following types of content on websites and apps:

Pre-recorded time-based media published before June 2025.
Office file format documents published before June 2025.
Online maps; though if the map is used for navigational purposes then the essential information must be provided in accessible format.
Third party content that is entirely out of the control of the website or app owner.
Reproductions of items in heritage collections which are too fragile or expensive to digitize.
The content of web sites and apps which are considered archival, meaning they are not needed for active administrative purposes and are no longer updated or edited.
The web sites of schools, kindergartens, and nurseries, except for content pertaining to administrative functions.

What happens if you fail to comply with the European Accessibility Act?

Violations of the EAA will be penalized according to national laws, however expert commentators suggest that member states will likely opt to impose fines on those who do not comply with the directive’s regulations.

How Monsido can help your website comply with the European Accessibility Act

Monsido’s Web Accessibility Module audits your entire site for digital accessibility against the WCAG 2.1 success criteria (and any subsequent updates to the guidelines).

Each audit scans your site for machine-testable issues, provides detailed reports so you can review any errors that may arise, gives you targeted recommendations on how to address these errors based on the guidelines, and shows you your compliance based on WCAG 2.1 levels A, AA, and AAA. You can track and prove your accessibility compliance progress via reports in the History Center. We also offer accessibility training to customers and support, all-inclusive, to ensure that you are well-versed in both automated and manual remediation methods, and are able to efficiently and consistently improve your website’s accessibility.

Monsido also offers free tools to complement your web accessibility efforts, including a color contrast checker for web teams to test out compliant color combinations for their web design, and an accessibility statement generator, which helps you meet the requirements of the EU Web Accessibility Directive by producing a public statement declaring your commitment to web accessibility.

Disclaimer

The information in this article is made available by Acquia Inc. and/or its subsidiaries and affiliates and is for informational purposes only so as to provide its customers with a general understanding of current legal developments. It should not be construed as providing specific legal advice, and you acknowledge that no attorney/client relationship exists between you or any third party and Acquia Inc. and/or its subsidiaries and affiliates. This article should not be used as a substitute for competent legal advice from a licensed lawyer in your jurisdiction.