EAA compliance: Understanding the scope and the impact on web accessibility

The European Accessibility Act (EAA) is a directive that standardizes accessibility requirements across EU member states, ensuring digital products and services are accessible to individuals with disabilities. Businesses operating in the EU, including e-commerce, banking, and transport, must comply with these regulations by June 28, 2025, or face penalties. Responsibility for accessibility violations lies with the website or app owners, even if third-party tools contribute to non-compliance. As the deadline approaches, businesses must take proactive steps to meet WCAG 2.1 standards and ensure compliance to avoid legal and financial consequences.

In this blog post you can read about:

1. What is the EAA
2. Which laws are based on the EAA?
3. Who does the EAA apply to?
4. How to comply with the EAA?

What is the EAA?

The European Accessibility Act (EAA), also known as Directive (EU) 2019/882, is a European Union directive that harmonizes accessibility requirements for the private sector across its member states.

The aim of the EAA

The ultimate aim is to make essential products and services accessible to persons with disabilities and those who experience functional limitations. These limitations can be permanent or temporary and include physical, mental, sensory, or age-related impairments.

By establishing consistent accessibility standards across Europe, the EAA helps small to medium enterprises (SMEs) and microenterprises compete on a level playing field. This not only promotes innovation but also provides better choices and fairer prices for all European citizens.

The deadline and consequences of non-compliance

The compliance deadline is fast approaching: 28th June 2025. By this date, all EU member states must have established processes for monitoring and filing complaints regarding non-compliant businesses. Failing to comply could lead to serious consequences, including penalties and exclusion from the market. In the Netherlands, the maximum fine is EUR 103,000. In Ireland, non-compliance could even result in a prison sentence of up to 18 months.

Who holds responsibility for accessibility violations?

Ultimately, the responsibility for accessibility violations lies with the website or app owner — even if the issue is caused by the platform itself or by a third-party tool/widget.

Let’s take a Shopify e-commerce website as an example. Ultimately, the store owner is likely to be held responsible by consumers and potentially face legal action. However, they may have recourse against theme or tool developers if their products are inherently inaccessible. Responsibility depends on several factors, such as the cause of the violation and whether the store owner has taken any steps to address accessibility.

Website’s accessibility can be broken by third-party tools:

• Payment gateways
• Live chat widgets
• Video players
• Pop-ups and modals
• Booking systems
• Interactive maps

If these tools are part of your digital experience and serve EU customers, you have to make sure they comply with the EAA’s accessibility standards too.

Another example is a business offering a third-party SaaS feature to their customers. While the business is primarily responsible for ensuring its accessibility, the SaaS provider can also face consequences. To define responsibilities clearly, businesses often include accessibility clauses in their contracts with third-party service providers.

Which laws are based on the EAA?

Almost every EU Member State has existing or draft legislation tied to the Web Accessibility Directive (WAD). The WAD applies to public sector websites and mobile apps. The EAA extends accessibility obligations to private-sector goods and services, including e-commerce, banking, e-books, transport, and more. Most countries are in the process of extending current rules to comply with the broader scope of the EAA.

Here is a partial list of national acts implementing the EAA requirements:

• Belgium: Will amend or augment its existing 2018–2019 legislation
• Italy: Further revisions are expected of the Legge Stanca (Law 4/2004)
• Poland: Passed an Act on Web Accessibility (2019) for the public sector; EAA transposition is underway to include e-commerce and private-sector services.
• Germany: Barrierefreiheitsstärkungsgesetz (BFSG)
• Sweden: Lag (2022:1851) om tillgänglighet till produkter och tjänster (Accessibility of Products and Services Act)
• Austria: already has accessibility requirements through various laws (e.g., the Bundes-Behindertengleichstellungsgesetz). An amendment or a new “Barrierefreiheitsgesetz” (Accessibility Act) is underway to implement EAA provisions.
• Finland: additional legislation or amendment to Act on the Provision of Digital Services (306/2019)

For the most up-to-date information, consult each country’s official register or the European Commission’s database on national transposition measures.

Who does the EAA apply to?

The short answer is: If your business provides a digital product or service to consumers within the EU, the EAA likely applies to you.

A wide range of products and services, including websites, mobile apps, and digital interfaces, are impacted. While most of these requirements focus on customer-facing products and services, some business-to-business (B2B) situations may also fall under the scope. It is important to note that more and more procurement processes include an accessibility requirement for web service providers.

Are businesses not based in the EU affected?

Any business that markets or sells goods or services to consumers in the EU must comply with EU laws, including the EAA’s accessibility requirements. It does not matter where your company is headquartered. If you’re providing products or services to EU consumers, you must ensure compliance with the national-level implementations of the EAA in the countries where you operate or sell.

Which digital services does the EAA cover?

The EAA specifically covers the following digital services:

• E-commerce: Online shopping, marketplaces, and product services.
• Online banking and financial services: payment systems, electronic signatures, and banking transactions.
• E-books and related distribution services
• Electronic communications: Messaging, telephony, and other services.
• Video-on-demand services: Accessible streaming platforms.
• Transport: Airlines, bus, ferry, and train operators with online booking and check-in services.

All websites, mobile apps, or other digital interfaces related to these sectors have to meet EAA standards.

Sectors that can be indirectly affected

While some sectors are explicitly listed in the EAA, others that provide digital interfaces (e.g., booking systems) may also be affected. These sectors include:

• Hospitality and tourism: Hotels, resorts, and travel agencies with online booking services.
• Entertainment, ticketing, and events: Concerts, sports, museums, and theaters selling tickets online.
• Healthcare and wellness services: Telehealth providers, fitness services, and clinics offering digital appointment scheduling.
• Education and e-learning: Platforms selling courses or digital learning materials in the EU.
• Professional services and Software-as-a-Service (SaaS): (SaaS) solutions that require accessible platforms for sign-up, payments, and dashboards.

Are there any exemptions from the EAA?

While the EAA applies to many businesses, there are certain exceptions:

• B2B: The EAA primarily applies to consumer-facing interactions, but businesses providing services to other businesses (B2B) might also be subject to compliance in some cases. For example, if a business provides services to a client with disabilities, it must ensure accessibility.
• Micro-enterprises: Companies with fewer than 10 employees and an annual turnover of less than EUR 2 million are exempt, provided they offer services (not manufacture products).
• Fundamental alteration and disproportionate burden: Exemptions may apply if implementing accessibility requirements would significantly alter the product or service or cause a disproportionate burden.
• Grace period for unaltered services: Service contracts agreed before June 28, 2025, may continue without alteration until they expire, but no longer than five years after that date.
• Archives: The EAA does not apply to certain content, such as:
  • pre-recorded media published before June 2025
  • office file formats published before June 2025
  • online maps, if navigational information is accessible
  • third-party content that is neither funded, developed by, or under the control of the economic operator concerned
  • content of websites and mobile applications that is not edited after 28 June 2025

How to comply with the EAA?

The EAA states that businesses must meet the minimum accessibility requirements outlined in the Web Accessibility Directive (WAD). That means adopting the ICT procurement standard EN 301 549. It incorporates WCAG 2.1 Level A and AA guidelines but also includes additional requirements.

With the June 2025 deadline approaching fast, businesses must take proactive steps to ensure they comply with the EAA. Don’t wait until the last minute—start preparing today to avoid penalties and ensure your digital services are accessible to all users.

For detailed advice on how to prepare for the deadline, check out the next blog in this series: EAA compliance: How to prepare for the deadline.

Need help navigating the complexity of the EAA compliance?

An expert partner can accelerate your efforts.

Whether you want to start with a solid foundation or update an existing product, having an accessible experience is fundamental. Let’s chat about how we can help you understand the current state of your accessibility support, opportunities for improvement, guidance towards strengthening your process, and how to best make solutions that work for everyone, regardless of their device or ability.