Taeke Reijenga has extensive experience with the business side of Web Accessibility. As CEO of the full service digital agency Level Level, he has managed in a short amount of time to get his entire team on board when it comes to including web accessibility in their workflow.
The countdown to the European Accessibility Act (EAA) compliance deadline – June 28, 2025 – is on. If your business isn’t prepared, you could be at risk of significant fines, legal consequences, and restricted access to the EU market. But beyond compliance, ensuring accessibility is an opportunity – one that can expand your reach and strengthen your brand’s reputation.
Think back to the chaos of GDPR. Businesses that scrambled at the last minute faced higher costs and greater risks. The EAA is following a similar path, but you still have time to get ahead – if you act now.
While the EAA covers a wide range of products and services, we’re focusing on web accessibility – one of the most crucial areas of compliance. This means making your site perceivable, operable, understandable, and robust – ensuring that people with disabilities can navigate, interact with, and understand your content.
Beyond avoiding penalties, compliance is a smart business move. Over 100 million people in Europe live with disabilities, making up a vast, often underserved market. By ensuring your website is accessible, you’re opening your business to more customers, improving SEO, and enhancing user experience for everyone.
This guide will walk you through the key steps to EAA compliance, from conducting audits to fixing common accessibility issues, documenting your compliance, and preparing for ongoing monitoring. Let’s make your website ready for 2025 – without the last-minute panic.
Understanding the European Accessibility Act
The European Accessibility Act (EAA) is a major step towards standardising digital accessibility across the European Union (EU). Designed to eliminate market barriers and improve access for people with disabilities, the EAA ensures that digital products and services meet harmonised accessibility standards. Compliance is mandatory by June 28, 2025, and businesses failing to meet these requirements could face severe penalties, restricted market access, and even imprisonment in some countries.
Who needs to comply?
The EAA applies to businesses operating within the EU that have:
- 10 or more employees
- An annual turnover exceeding €2 million
Microenterprises (fewer than 10 employees and an annual turnover/balance sheet under €2 million) might be exempt under some circumstances, but they must notify national authorities if they choose not to comply. Still, the directive advises that:
… all microenterprises should be encouraged to manufacture, import or distribute products and to provide services that comply with the accessibility requirements of this Directive, in order to increase their competitiveness as well as their growth potential in the internal market. Member States should, therefore, provide guidelines and tools to microenterprises to facilitate the application of national measures transposing this Directive.
Non-EU companies offering digital services to EU consumers must also ensure compliance. This means that an eCommerce store, a mobile app, or a banking platform serving EU users must meet EAA standards, regardless of where the company is based.
What does the EAA cover?
The EAA focuses on digital accessibility and applies to:
- Websites and mobile apps of businesses covered by the regulation.
- eCommerce platforms (ensuring accessible online shopping).
- Banking and financial services, including ATMs and payment terminals.
- eBooks and digital publishing.
- Self-service terminals, payment terminals, and ticketing machines.
Exemptions: “Disproportionate Burden” clause
Some businesses may claim an exemption under the “disproportionate burden” clause. To qualify, they must document and justify that compliance would impose excessive costs relative to the benefits for people with disabilities. Factors considered include:
- Company size, resources, and financial capacity.
- Estimated costs vs. benefits for people with disabilities (which is a lot harder to win).
Enforcement and penalties
Each EU country is responsible for enforcing the EAA and will set its own penalties for non-compliance. These vary widely and include:
- Fines ranging from €1,000 to €900,000.
- Public exposure of non-compliant businesses.
- Suspension of business operations in severe cases.
Some countries like Ireland have introduced prison sentences for persistent non-compliance, making it critical for businesses to act now.
Why compliance matters
One thing we know from following similar laws like the ADA is that despite only the biggest lawsuits getting all the coverage, the reality is that 67% of them target small businesses under 25M in revenue. Unlike big corporations like Hasbro or Netflix, they rarely have the extra money to deal with all the associated costs. With the EAA, the situation will most likely be very similar.
Cases filed among businesses with less or more than 25M revenue in 2024
| Year | Percentage of lawsuits for businesses with less than 25M revenue | Percentage of lawsuits for businesses with more than 25M revenue |
|---|---|---|
| 2024 | 67% | 33% |
| 2023 | 73% | 27% |
| 2022 | 72% | 28% |
| 2021 | 70% | 30% |
| 2020 | 70% | 30% |
Aside from avoiding penalties, EAA compliance is an opportunity. Making your digital services accessible opens your business to over 100 million people with disabilities in Europe, improves SEO performance, and enhances user experience for everyone.
The EAA: web accessibility requirements and WCAG
The European Accessibility Act mandates compliance with EN 301 549, the harmonised standard for ICT accessibility across the EU. This standard aligns closely with WCAG 2.1 Level AA, making it the benchmark for web and mobile accessibility.
To meet EAA compliance, websites and digital services must adhere to WCAG’s four core principles:
- Perceivable – Content must be available to all senses, including screen reader compatibility, alternative text for images, and clear text contrast.
- Operable – Websites must be usable by everyone, including people using assistive technologies, and provide clear navigation without time constraints.
- Understandable – Information and UI elements must be clear and predictable, avoiding overly complex language and layouts.
- Robust – Websites must work with various assistive technologies, ensuring long-term compatibility.
Regular accessibility audits are essential as both EN 301 549 and WCAG guidelines evolve. WCAG 2.2, released in October 2023, introduces updates that may soon be incorporated into the EAA. Businesses should proactively align with WCAG 2.2 to stay ahead of future updates.
Take action against noncompliance: how to prepare for EAA
Being proactive is always recommended – you shouldn’t wait for a lawsuit or a complaint to make your website EAA-compliant. This involves auditing digital accessibility, addressing WCAG failures, and maintaining ongoing compliance monitoring. If you’re not sure where to start, the following steps will help you prevent legal risks and improve usability for all users.
1. Complete an audit and test regularly
Unless you’re an accessibility expert yourself, a professional audit is the most effective way to identify and fix compliance gaps before they become legal issues. Automated tools can catch basic errors, but manual testing is essential for detecting real-world accessibility barriers.
✍️The A11Y Collective offers expert-led audits to ensure compliance, expand reach, and avoid costly lawsuits.
If you are doing it yourself – and again, we’d recommend against this unless you’re an accessibility expert – make sure to combine automated tools with manual verification.
Automated tests detect code-based issues and simple errors like missing alternative text or bad contrast, but manual testing will give you very important contextual information. For example, whether the alt text actually makes sense or if it’s even needed (which it isn’t for decorative images). You should also test with different screen readers and keyboard navigation to uncover usability barriers.
Throughout the process, you should:
- Validate against WCAG 2.1 AA success criteria – This includes colour contrast, keyboard accessibility, alternative text, error messages, and more.
- Define testing responsibilities – Developers should validate technical implementation while UX teams focus on usability and assistive technology testing.
- Maintain audit logs and conformance documentation – Keep records of testing methodologies, identified issues, and remediation actions to prove compliance.
For ongoing compliance, schedule regular audits to catch new web accessibility issues as your website evolves.
2. Fix all issues before the June 2025 deadline
Common WCAG failures that also result in EAA noncompliance include:
- Missing or inadequate alternative text – Screen reader users rely on accurate alternative text for images and non-text content. Missing descriptions or vague labels like “image.jpg” create accessibility barriers.
- Keyboard inaccessibility – All interactive elements, including menus, buttons, and forms, must be fully navigable via keyboard alone. If users cannot tab through content or if focus indicators are missing, this violates compliance requirements.
- Form input errors without clear instructions – Forms must provide clear, descriptive error messages and accessible labels. Error messages should not rely solely on colour to indicate a problem.
- Inaccessible dynamic content – Pop-ups, modal dialogs, and carousels must be operable by assistive technologies. If screen readers cannot detect or interact with them properly, they create compliance risks.
Okay, so you have identified the issues on your website, but now what? To give you an example, let’s see how you’d handle one of the most frequent accessibility issues – insufficient colour contrast. This is a big problem as it makes text difficult to read by people with low vision or colour blindness.
First, you need to confirm that there are contrast failures. You can use tools like WebAIM’s Contrast Checker to do that by putting the Hex values of the two main colours.
The minimum required ratios are:
- 4.5:1 for normal text.
- 3:1 for large text.
If that’s not the case, there are several things you could do:
- Create a pre-validated colour palette and incorporate the colours on your website.
- Directly adjust the text or background colours of the affected pages.
Whatever you do, make sure to document accessible colour combinations in a style guide to avoid future non-compliance. We also recommend that you integrate contrast checks in your design review process and train designers and developers on accessibility best practices.
Need some guidance on accessible design practices?
Enrol in our “Accessible design, the basics” course to learn more about creating inclusive website designs.
3. Continually monitor, document, and collect feedback
To be EAA compliant means to be truly accessible, and that’s not a one-time job. Instead, it requires continuous monitoring, documentation, and user feedback, otherwise, your efforts would be in vain.
So what does that include?
- Regular testing – General audits should occur at least annually and after major updates.
- Feedback mechanisms – Websites must provide easy-to-use channels for users to report accessibility issues (e.g., contact forms, dedicated accessibility emails). These should align with EN 301 549 requirements.
- Documenting compliance – Maintain records of:
- Testing methodologies used (automated + manual).
- Audit findings and remediation actions.
- User feedback and issue resolutions.
- Validation of new content and features – New pages, widgets, or site functions must be evaluated for WCAG conformance before deployment.
- User testing – Integrate feedback from real users with disabilities into compliance documentation to improve practical accessibility.
4. Add a conformance statement to your website
An EAA compliance statement serves as proof that your organisation meets accessibility standards. It also provides transparency to users about accessibility efforts and any remaining barriers.
Here’s what it should contain:
- Compliance summary – Describe how your website meets EN 301 549 and WCAG 2.1 Level AA.
- Known accessibility limitations – List any areas not fully accessible and explain why.
- Disproportionate burden claims – If applicable, justify why certain accessibility requirements cannot be met due to financial or technical constraints.
- Public accessibility – The statement should be:
- Easily discoverable, typically linked in the footer or on a dedicated accessibility page.
- Regularly updated as improvements are made.
As for the formatting, EAA does not prescribe an exact format, but many organisations use EN 301 549 templates or follow WCAG Accessibility Conformance Reports.
Common pitfalls and how to avoid them
Achieving and maintaining EAA compliance can be challenging, and many organisations fall into common traps that jeopardise their efforts.
- Starting too late: With the June 28, 2025 deadline rapidly approaching, delaying accessibility initiatives increases the risk of rushed, incomplete, or non-compliant work. Starting early allows time for thorough audits, remediation, and testing.
- Underestimating resource requirements: Accessibility is often more complex than anticipated. Beyond technical adjustments, it requires investment in tools, staff training, and external expertise. Organisations must budget for these resources to avoid project delays and incomplete compliance.
- Failing to document compliance efforts: Without detailed records of testing, remediation, and decision-making processes, organisations struggle to prove compliance during audits or legal challenges. Comprehensive documentation demonstrates good-faith efforts to meet EAA requirements.
- Neglecting ongoing maintenance: Achieving compliance isn’t a one-off task. New content, site updates, and feature rollouts can reintroduce accessibility barriers if not regularly reviewed. Failing to embed accessibility into long-term processes can undo progress.
So, what can you do to avoid all of that?
- Establish a dedicated accessibility team trained in web accessibility basics.
- Develop a detailed implementation timeline with buffer periods.
- Implement automated testing alongside regular manual audits.
- Maintain comprehensive documentation systems to track compliance efforts.
How The A11Y Collective’s training prevents compliance failures
The most effective road to full compliance is embedding accessibility knowledge across your organisation. The A11Y Collective’s specialised training helps teams not only achieve compliance but sustain it, reducing the risk of costly failures.
Teams with a deep understanding of accessibility are better equipped to:
- Anticipate issues before they become compliance risks.
- Adapt to evolving accessibility standards, including updates to WCAG 2.2 and beyond.
- Build truly inclusive digital experiences that go beyond minimum legal requirements.
The A11Y Collective’s courses include:
- Advanced Accessible Components: Perfect for developers, this course tackles complex technical requirements like dynamic content, ARIA roles, and interactive components.
- Accessible design, the basics: Focused on visual accessibility, this course teaches practical strategies for designing forms, modals, and navigation patterns that meet compliance standards.
- Writing accessible content for the web: Essential for content teams, this course ensures that ongoing content updates meet accessibility guidelines, covering everything from alt text to plain language principles.
By offering training from foundational courses to advanced masterclasses, The A11Y Collective provides a comprehensive learning pathway. This multi-role approach bridges the gaps between designers, developers, and content creators, ensuring coordinated accessibility efforts across the entire organisation.
Fast-track your EAA compliance with website accessibility audits
EAA compliance is a legal obligation, but most of all, it’s a commitment to creating inclusive digital experiences for all users. In this article, we’ve covered the key steps to achieving compliance, from conducting thorough audits and addressing common WCAG failures to maintaining ongoing accessibility through monitoring and documentation.
Regular accessibility audits are essential for staying compliant. Working with expert providers like The A11Y Collective ensures that your audits:
- Provide documented evidence of your conformance efforts.
- Identify potential barriers before they affect users.
- Demonstrate that your organisation has taken all reasonable steps to meet accessibility requirements.
Don’t risk non-compliance. Book an accessibility audit with The A11Y Collective today to fast-track your compliance and create a more accessible web for everyone.
Ensure your website is EAA-compliant
Book a professional accessibility audit today to ensure legal compliance and make your website more accessible for everyone.
