Covered even if you’ve never set foot in the EU
Here’s the part most companies miss. The European Accessibility Act doesn’t care where your business is registered. It cares where your customers are.
Sell to a consumer in Germany, France, or Spain? You’re in scope. Even if your office sits in Austin or Manchester.
A US-based SaaS company asked us to look at their setup last year. They’d written the EAA off as “an EU thing.” Then they checked their billing data.
Roughly 40% of their paying users were in the EU. That “EU thing” had quietly become a board-level thing.
The Act became enforceable on 28 June 2025. Not a proposal. Not a draft. Live law, in all 27 member states. So if web accessibility has been sitting on your someday list, it just moved to the top.
What the EAA actually is
The European Accessibility Act is Directive (EU) 2019/882. As a directive, it didn’t apply directly. Each member state had to transpose it into national law.
That’s why the rules carry different names by country. Germany calls its version the Barrierefreiheitsstärkungsgesetz. Ireland, France, and the rest each have their own.
The goal underneath all of them is identical. Consumer-facing products and digital services have to work for people with disabilities. Vision, hearing, motor, cognitive: the whole range.
This isn’t a small audience. Around 87 million people in the EU live with some form of disability. Add temporary impairments and the simple effects of aging, and the number climbs higher.
An inaccessible checkout doesn’t just fail an audit. It turns paying customers away at the door.
Don’t confuse it with the public-sector rules
One quick clarification, because it trips people up. The EAA is not the same as the Web Accessibility Directive from 2016.
That earlier directive covers public-sector bodies: government sites, public services, state agencies. The EAA is the one that reaches into the private sector.
If you run a business that sells to consumers, the EAA is your law. The 2016 directive was never about you.
Who has to comply
Start with a simple test. Do you sell to consumers in the EU? If yes, assume you’re covered until proven otherwise.
The Act explicitly reaches businesses outside the EU. A non-EU e-commerce site that accepts orders from EU consumers falls squarely under it. The obligation rides along with the sale.
The categories of covered services are broad:
- E-commerce and online retail
- Consumer banking and payment services
- E-books and their reading software
- Electronic communications and messaging
- Passenger transport with digital ticketing, booking, or real-time information
Pure B2B usually sits outside the scope. If you genuinely only sell to other businesses and never to consumers, you likely have room to breathe. But “a consumer could plausibly buy this” is enough to pull you in.
There’s one real exemption, and it’s narrower than people hope. Microenterprises providing services are exempt: fewer than 10 employees and under €2 million in annual turnover.
Note the “and.” Both conditions, not either. And it doesn’t extend to companies placing products on the market. Nine employees and €3 million in revenue? No exemption.
What “accessible” means in practice
Accessibility under the EAA isn’t a vibe. It’s a standard you can test against.
The harmonized European standard is EN 301 549, currently version 3.2.1. It builds on the Web Content Accessibility Guidelines, and the operative benchmark is WCAG 2.1 at Level AA. (WCAG 2.2 is published, but it hasn’t been folded into the harmonized standard yet.)
Version 4.1.1 of EN 301 549 is in development: it will incorporate WCAG 2.2 AA and is expected to be referenced in the Official Journal of the EU in late 2026. Until that reference appears, v3.2.1 and WCAG 2.1 AA remain the operative compliance target.
Four principles sit at the core. Content has to be perceivable, operable, understandable, and robust.
Translated into things your developers actually do: every function works from the keyboard alone, including menus and the checkout. Text meets a contrast ratio of at least 4.5:1 against its background. Informative images carry alt text a screen reader can announce.
There’s more. Form fields need real labels, and error messages have to explain how to fix the problem. Keyboard focus stays visible as someone tabs through the page. Video and audio come with captions or transcripts.
None of that is exotic. But you can’t bolt it on with a one-line widget. Accessibility overlays that promise instant compliance tend to mask problems rather than fix them, and in the US they’ve drawn a wave of lawsuits from the very users they claimed to help. Skip the shortcut.
The deadline, and the grace period that mostly isn’t
The date to remember is 28 June 2025. Enforcement started then.
A myth has been spreading that everyone has until 2030. Read it carefully before you relax.
The transition period to 28 June 2030 is narrow. It covers self-service terminals already in lawful use before the deadline, plus certain service contracts signed beforehand. It does not hand your website a five-year reprieve.
A website or app you operate today has to be accessible today. There’s no queue to join.
What non-compliance costs
Because each country transposed the directive itself, penalties vary by member state. There’s no single EU-wide fine.
In Germany, the Barrierefreiheitsstärkungsgesetz sets fines up to €100,000, and market-surveillance authorities can order a non-compliant service withdrawn. Other member states pair fines with turnover-based penalties. The exact ceiling depends on where your customers are.
But the regulator is rarely the first knock on the door. Consumer associations, qualified enforcement bodies, and individual users can all raise complaints. In practice, the opening move tends to be a legal notice, not a government audit.
How to get there without a fire drill
The most expensive route to accessibility is the last-minute retrofit. It’s the same pattern we see with privacy work. Build it in from the start and you pay a 5 to 15% premium.
Retrofit a sprawling site under deadline pressure and the bill runs far higher. The logic mirrors what we cover in building GDPR-compliant architecture. Compliance as an afterthought is always the costly version.
Three moves, in order:
- Audit against WCAG 2.1 AA. Automated tools catch about a third of the issues. The rest surface only when a human runs real workflows with a screen reader and keyboard. Pay for the human pass.
- Fix by impact, not by page order. The checkout, the search, the booking flow, the contact paths. Start where customers actually drop off. The legal footer can wait.
- Bake it into the process. Every new feature, every campaign page, every template ships accessible from now on. Otherwise you’ll be retrofitting again in two years.
This is exactly the kind of work our design partnership is built for: accessibility designed in, not bolted on.
Accessibility isn’t a regulatory tax you grudgingly pay. Done right, it’s good engineering that also improves usability and SEO for everyone. For the wider compliance picture the EAA sits inside, see our overview of EU compliance for software teams.
Not sure whether your website would survive an EAA audit? Let’s take a look together. We’ll assess where you stand and tell you honestly what needs fixing, and what doesn’t.
