European Accessibility Act (EAA) in Web Design: Requirements & Guides

The European Accessibility Act (EAA), Directive (EU) 2019/882, sets new accessibility standards. The compliance deadline is June 28, 2025. This guide explains EAA's impact on businesses, focusing on digital accessibility.

EAA: Core Information & Impact

What is the EAA's primary goal?

The EAA's primary goal is improving the EU internal market for accessible products and services. It establishes common accessibility rules across all EU Member States, like Poland. This action simplifies regulations for businesses. It also increases accessible options for consumers, particularly persons with disabilities and older individuals.

Who complies with the EAA?

Economic operators comply with the EAA. These include manufacturers, importers, distributors, and service providers. The EAA applies to businesses inside the EU and to businesses outside the EU selling covered products or services to EU consumers.

What is the EAA compliance deadline?

The EAA requirements apply from June 28, 2025. New products placed on the market and services provided in the EU after this date conform to EAA standards.

EAA Scope: Covered Products and Services

Which products does the EAA cover?

The EAA covers specific products placed on the EU market from June 28, 2025:

• Computers and their operating systems.
• Smartphones and related telecommunications equipment.
• TV equipment linked to digital television services.
• E-readers.
• Payment terminals.
• Self-service terminals (e.g., ATMs, ticketing machines, check-in machines).

Which services does the EAA cover?

The EAA covers services provided from June 28, 2025:

• E-commerce services (entire customer journey: websites, apps, payment).
• Consumer banking services (websites, apps).
• E-books and their dedicated software/platforms.
• Access to audiovisual media services (e.g., streaming platforms).
• Telephony services.
• Passenger transport services by air, bus, rail, and water (websites, apps, ticketing).
• Answering of emergency communications to the '112' number.

EAA Digital Accessibility Requirements

What are the EAA's core digital accessibility principles?

Digital interfaces, like websites and mobile applications, adhere to four POUR principles from the Web Content Accessibility Guidelines (WCAG):

• Perceivable: Users can identify information (e.g., text alternatives for images, sufficient color contrast).
• Operable: Users can use interface components (e.g., full keyboard navigation).
• Understandable: Information and functions are clear (e.g., simple language, predictable operation).
• Robust: Content functions reliably with various technologies, including assistive technologies like screen readers.

How does the EAA relate to WCAG for websites and apps?

The EAA references the European standard EN 301 549 for Information and Communication Technology (ICT) accessibility. For websites and mobile applications, EN 301 549 incorporates WCAG 2.1 Level AA. Conformance with WCAG 2.1 Level AA through EN 301 549 is the current technical path for EAA digital compliance. WCAG 2.2 is a newer version; EN 301 549 might reference it later.

Is WCAG 3.0 relevant for the current EAA deadline?

No. WCAG 3.0 is a working draft under development by the W3C. It is not the standard for the June 28, 2025, EAA compliance deadline. Businesses focus on WCAG 2.1 Level AA.

Business Responsibilities Under the EAA

What are manufacturers' main EAA duties?

Manufacturers design and produce accessible products. They perform conformity assessments. They draw up an EU Declaration of Conformity. They affix the CE marking. They maintain technical documentation. They take corrective actions for non-compliant products.

What are importers' and distributors' EAA duties?

Importers verify that products from outside the EU meet EAA requirements before placing them on the market. Distributors, when making products available, also verify EAA compliance indicators (e.g., CE marking). Neither party supplies non-compliant products.

What are service providers' main EAA duties?

Service providers design and deliver services meeting EAA accessibility requirements. They provide information on their service's accessibility. They take corrective actions for non-compliant services.

EAA Exemptions: Limited Circumstances

Which businesses qualify for the microenterprise exemption?

Microenterprises are generally exempt from EAA requirements. A microenterprise has fewer than 10 employees AND an annual turnover not exceeding EUR 2 million OR an annual balance sheet total not exceeding EUR 2 million. Verification of specific national law transpositions is advisable.

What are other grounds for EAA exemption?

Two other grounds exist, requiring rigorous justification:

• Fundamental Alteration: Compliance would significantly change a product or service, altering its basic nature.
• Disproportionate Burden: Compliance costs are excessively high for the economic operator relative to benefits for persons with disabilities, assessed against criteria in EAA Annex VI. This requires documented assessment and notification to authorities.

Achieving EAA Compliance: Key Actions

What is the first step for EAA compliance?

Conduct comprehensive accessibility audits of current products, services, websites, and mobile applications. These audits compare offerings against EAA requirements, using WCAG 2.1 Level AA for digital aspects. Expert manual testing with assistive technologies is essential, beyond automated tools.

How is "Accessibility by Design" relevant?

"Accessibility by Design" integrates accessibility into all stages of product and service creation, from initial concept through development and testing. This proactive approach is more effective than retrofitting.

Why is staff training important for EAA?

Staff training ensures teams understand EAA obligations and accessibility best practices. Developers, designers, content creators, and customer service staff benefit from targeted training.

What is an Accessibility Statement?

An Accessibility Statement, published for websites and apps, affirms commitment to accessibility. It details standards met (e.g., WCAG 2.1 AA) and provides contact information for user feedback or reporting accessibility issues.

What documentation is needed?

Manufacturers maintain technical documentation and the EU Declaration of Conformity for products with CE marking. Service providers prepare and make public information on how their services meet accessibility requirements. All businesses document their accessibility efforts, audits, and remediation.

EAA Non-Compliance: Consequences

How is the EAA enforced?

EU Member States designate Market Surveillance Authorities (MSAs) to monitor and enforce EAA compliance. MSAs handle complaints and ensure businesses take corrective actions.

What are potential penalties for non-compliance?

Penalties for EAA non-compliance are set by national law. They are "effective, proportionate, and dissuasive." Penalties include substantial fines (levels vary per country), orders to withdraw products or prohibit services, and public notices of non-compliance.

Are there other consequences besides penalties?

Yes. Non-compliance can lead to product recalls, service delivery disruptions, significant reputational damage, and loss of customers. It may also result in exclusion from public and private procurement processes that require accessibility.

EAA Compliance: A Business Imperative

The European Accessibility Act deadline is June 28, 2025. Meeting EAA requirements is a legal obligation. It also presents an opportunity for businesses to reach a wider audience, foster innovation, and enhance their brand. Proactive engagement with accessibility is vital. Businesses needing guidance on EAA obligations or digital accessibility audits can seek expert consultation.