The European Accessibility Act is Coming: What U.S. IT Companies Need to Know

Digital accessibility is not a niche consideration, but rather a necessity. In the United States alone, 1 in 4 adults—over 27%—live with some form of disability, according to the Centers for Disease Control and Prevention (CDC). That translates to nearly 1 in 4 people facing barriers when interacting with digital platforms that are not designed inclusively.

The legal landscape is evolving alongside these realities. In 2023, digital accessibility lawsuits in the U.S. rose to over 4,600 cases—an all-time high. And it’s not just happening domestically. As global regulatory pressure increases, companies operating internationally must be prepared to meet a broader range of compliance standards.

Enter the European Accessibility Act (EAA). Slated to take full effect on June 28, 2025, the EAA is a landmark piece of legislation that will reshape how businesses—both within and outside the EU—approach digital accessibility. Its goal is to harmonize accessibility requirements across member states and ensure that people with disabilities have equal access to products and services in key areas such as banking, e-commerce, software, and telecommunications.

If you're a U.S.-based IT company offering digital products or services in the EU, the EAA directly affects your operations. 

This article will explain what the European Accessibility Act is, who it applies to, why it matters for your business, and how your teams—especially QA professionals, developers, and product managers—can prepare effectively.

Accessibility isn’t just about avoiding lawsuits—it’s about building better, more inclusive digital experiences for everyone. And now, it’s becoming a legal requirement on a global scale.

Understanding the European Accessibility Act

The European Accessibility Act (EAA), formally known as Directive (EU) 2019/882, is a legislative effort by the European Union to standardize accessibility requirements across member states. It aims to remove market fragmentation caused by inconsistent national accessibility laws and to improve access to key products and services for people with disabilities. The EAA also brings the EU in closer alignment with its obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD).

Unlike previous EU directives that mostly targeted public institutions (such as the Web Accessibility Directive for government websites), the EAA takes a much broader approach. It applies to a wide range of private-sector products and services that are sold or made available within the EU, regardless of where the provider is based. This means U.S. businesses that want to maintain or grow their footprint in the European market need to take this law seriously.

Which products and services are covered?

The EAA targets products and services that are considered essential to daily life and digital inclusion. These include:

Products:

• Smartphones and computers;
• Payment terminals (like card readers);
• ATMs and ticket machines;
• Smart TVs and related equipment;
• E-book readers.

Services:

• E-commerce websites and mobile apps;
• Banking and financial services platforms;
• Online ticketing and travel services (including public transport);
• Telephony and electronic communication services;
• Audiovisual media services (e.g., video streaming platforms).

Let’s say your U.S.-based company develops an e-commerce SaaS platform used by retailers in Germany or France. Under the EAA, your product must be accessible to people with disabilities—this includes things like keyboard navigation, screen reader compatibility, high-contrast design options, and clear, resizable text. It also means that updates and new features must continue to meet accessibility standards throughout the product’s lifecycle.

Technical standards: What’s required?

The EAA doesn’t reinvent the wheel—it builds on well-established international standards. Most notably, it references the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, which set out clear criteria for making web content more accessible to users with visual, auditory, motor, and cognitive impairments.

Below are the specific WCAG success criteria that U.S. IT companies should be aware of.

• Perceivable: Provide text alternatives for non-text content; ensure content is adaptable and distinguishable (e.g., good color contrast and resizable text).
• Operable: Make all functionality available from a keyboard; give users enough time to read and use content; avoid flashing content that could trigger seizures.
• Understandable: Ensure that content is readable and predictable; offer clear instructions and error messages.
• Robust: Maximize compatibility with current and future user agents, including assistive technologies like screen readers or speech input software.

As of late 2023, WCAG 2.2 was officially released, and while the EAA currently mandates WCAG 2.1, many accessibility advocates—and forward-looking organizations—are already moving to align with 2.2 to future-proof their offerings.

Deadlines and compliance milestones

The EAA was adopted in 2019, but member states were given until June 28, 2022, to transpose it into national law. The key date for enforcement is June 28, 2025. From this point forward, all covered products and services placed on the EU market must comply with the directive.

There is a transition period for legacy systems: products or services that were in the market before June 2025 can continue to be sold until June 2030, provided no substantial changes are made that would require re-certification or re-release. This gives companies some breathing room—but only if they’ve already invested in accessible foundations.

Enforcement and penalties

Each EU member state is responsible for setting up its own monitoring and enforcement mechanisms. While the penalties will vary by country, businesses that fail to comply could face:

• Fines and administrative sanctions;
• Product bans or forced product withdrawals from the EU market;
• Legal action from consumers or disability rights organizations;
• Damage to brand reputation and loss of consumer trust.

In short, non-compliance is both a legal and a business risk, especially in a region that increasingly emphasizes corporate social responsibility and digital inclusion.

Implications for U.S. IT companies

For U.S. IT companies doing business in Europe—or planning to expand into the EU market—the European Accessibility Act is not just another international regulation to keep on the radar. It’s a strategic turning point. The EAA introduces legal obligations that directly affect how digital products are designed, built, tested, and maintained.

Does your company fall under the EAA?

The short answer: If you sell or provide digital services or hardware to consumers in the EU, you’re likely affected. Examples include:

• A U.S.-based SaaS provider offering a web-based productivity tool to customers in Germany, France, or any other EU country.
• A mobile app developer distributing apps via the Apple App Store or Google Play Store in European regions.
• An e-commerce platform that processes transactions and delivers products across European borders.
• A fintech startup providing banking apps or digital wallets that serve EU-based users.
• A travel tech company enabling EU citizens to book transportation or accommodations online.

Even if your company doesn’t have a physical presence in the EU, the “place of use” principle applies—meaning that what matters is where the end user is located, not where your servers or headquarters are based.

QA teams: prepare for increased accountability

Software testers and QA managers will play a critical role in ensuring compliance with the EAA. Accessibility testing can no longer be an afterthought or limited to the final stages of a release cycle. It needs to be baked into your QA strategy from the start.

You’ll need to:

• Establish automated and manual accessibility testing pipelines to ensure consistent WCAG compliance throughout development.
• Test across assistive technologies, such as screen readers (JAWS, NVDA, VoiceOver), magnifiers, and speech-to-text systems.
• Validate user journeys for accessibility barriers, including critical flows like registration, checkout, form submission, and customer support.
• Create issue-tracking protocols for accessibility-related defects and ensure they are resolved with the same priority as functional bugs.

For product teams that practice Agile or DevOps, this means embedding accessibility into your definition of “done.”

Developers and designers: shifting to inclusive design practices

Front-end engineers and UX designers will need to build with accessibility in mind from day one. This involves:

• Using semantic HTML for proper structure and readability by assistive tech.
• Ensuring keyboard navigability and logical tab ordering.
• Providing ARIA (Accessible Rich Internet Applications) roles where appropriate, but not as a substitute for native elements.
• Maintaining sufficient color contrast ratios and scalable fonts.
• Implementing responsive design that works across devices and screen readers.

Failing to implement these practices could mean having to retrofit your product later, which is often more expensive and time-consuming than building accessibly from the outset.

You may be interested in: QualityForge 2024 Recap: A Day Dedicated to Digital Accessibility.

Business impact: risk, reputation, and opportunity

From a strategic standpoint, EAA compliance represents both a risk mitigation measure and a market opportunity:

• Avoid legal penalties. As with GDPR, enforcement across EU states will increase over time, and non-compliance may lead to product bans, recalls, or legal action.
• Strengthen brand reputation. Companies that proactively invest in accessibility demonstrate a commitment to corporate responsibility and user experience, values that resonate with today’s socially conscious consumers.
• Gain a competitive edge. Accessible products appeal to a broader customer base, including the 100+ million EU residents with disabilities, as well as aging users who benefit from accessible design features like larger fonts and voice controls.
• Win enterprise clients. Many EU-based enterprises and government institutions require accessibility compliance in their procurement processes. If your product isn’t accessible, you may not even be considered.

In short, the EAA is reshaping what it means to be "market-ready" in Europe. U.S. companies that act now can minimize disruption and maximize long-term gain.

5 key steps to achieve EAA compliance

Meeting the requirements of the EAA may seem daunting at first—especially for companies with large digital ecosystems or legacy systems—but with the right approach, tools, and mindset, it’s entirely manageable. The key is to treat accessibility as an ongoing responsibility, not a one-time task. Below are practical steps your organization can take to get on track.

1. Conduct a comprehensive accessibility audit

Start by assessing your current state. An accessibility audit helps you understand where your digital products stand relative to the WCAG 2.1 Level AA standards.

• Automated tools like Axe, Pa11y, Lighthouse, or Wave can help identify common issues quickly (e.g., missing alt text, low color contrast, incorrect ARIA use).
• Manual testing is essential to catch the nuances automated scans miss, such as logical tab order, screen reader behavior, or keyboard traps.
• User testing with people with disabilities adds even more insight, revealing real-world usability issues not always covered by technical guidelines.

Audit all user-facing platforms: websites, mobile apps, web applications, portals, and PDF documents.

2. Develop an accessibility remediation roadmap

Once you've identified the issues, prioritize them based on business impact and risk exposure.

• Which user flows are most critical (e.g., checkout, login, support)?
• Which issues pose the highest legal or usability risks?
• Are any of the issues blockers for assistive tech users?

Then build a phased remediation plan. Assign tasks to appropriate teams (e.g., developers, UX designers, content editors), and track progress using your existing issue management system (Jira, Azure DevOps, etc.).

3. Align your digital products with WCAG 2.1 AA (or 2.2)

The EAA references WCAG 2.1 AA, but many organizations are moving toward WCAG 2.2 to stay ahead of evolving standards. Ensure your teams understand the four foundational principles of WCAG (POUR):

• Perceivable – Information must be presented in ways users can recognize and understand (e.g., captions for video, alternatives for images).
• Operable – Interfaces must be navigable and usable via keyboard and assistive tech.
• Understandable – Content must be readable and predictable; forms must have clear instructions and helpful error handling.
• Robust – Content must work across browsers, operating systems, and assistive technologies.

Your developers should refer to the official WCAG success criteria and use resources like the W3C’s Quick Reference for practical implementation advice.

4. Integrate accessibility into your development lifecycle

Accessibility shouldn’t be confined to a single team or project—it should become part of your company’s design and development DNA.

To achieve this:

• Include accessibility criteria in your definition of done.
• Add accessibility checks to your CI/CD pipeline using tools like Axe-core, Deque, or Tenon.
• Provide ongoing training for developers, designers, and QA testers on accessibility fundamentals.
• Build accessible design systems and component libraries to reduce repeat work and ensure consistency.

Additionally, consider assigning a dedicated accessibility champion or hiring a consultant to support teams during implementation and code reviews.

5. Monitor, maintain, and document

Accessibility is not a one-time fix—it’s a continuous process. Products evolve, and so do standards. To remain compliant:

• Perform regular audits after major releases.
• Encourage user feedback and make it easy for users to report accessibility issues.
• Track accessibility-related defects in your bug-tracking system.
• Maintain clear documentation outlining your accessibility strategy, known limitations, and ongoing improvements.

This documentation is not only helpful for internal alignment—it may also be requested by EU authorities, especially in case of consumer complaints.

You may be interested in: Digital Accessibility in Transportation Apps: A Comprehensive Guide.

Beyond compliance: Why accessibility is a smart business move

While the EAA sets a legal standard, forward-thinking companies know that accessibility offers much more than regulatory compliance. It enhances user experience, strengthens brand reputation, expands market reach, and supports innovation. For U.S. IT companies eyeing sustainable growth in Europe and beyond, accessibility should be viewed as a strategic advantage—not just a checkbox.

Expand your customer base

The World Health Organization (WHO) estimates that over 135 million people in the EU live with some form of disability. Globally, the number surpasses 1.3 billion. By designing and testing your digital products for accessibility, you open the door to a significantly larger audience—including individuals with permanent, temporary, or situational impairments.

And it’s not just about people with disabilities. Accessible features also benefit:

• Older users, who may experience reduced vision, hearing, or motor control;
• Users in low-bandwidth or high-glare environments;
• Multilingual users, who benefit from clear language and consistent navigation;
• Mobile-first users, who rely on touchscreens and alternative inputs.

Designing for inclusion leads to more intuitive and flexible digital experiences for everyone.

Improve user experience and engagement

Accessible design often results in cleaner code, simpler navigation, better content structure, and faster load times. These benefits improve usability for all users, not just those with disabilities.

Consider these examples:

• A clear, logical page hierarchy makes it easier for screen reader users and sighted users to skim content.High contrast and scalable fonts help users with low vision and those using devices in bright sunlight.
• Keyboard-friendly navigation supports users with motor impairments and power users who prefer shortcuts.

When usability improves, so does engagement, leading to higher conversion rates, lower bounce rates, and increased customer satisfaction.

Strengthen brand reputation and trust

Consumers are increasingly looking to align with brands that demonstrate ethical practices and social responsibility. By making accessibility a visible priority, your company sends a powerful message: you care about all users, not just the majority.

This kind of brand integrity can:

• Increase customer loyalty
• Boost word-of-mouth referrals
• Differentiate your product in crowded markets
• Improve your positioning in public procurement bids, where accessibility is often a non-negotiable requirement

In the event of a legal challenge or customer complaint, having a documented, proactive approach to accessibility can protect your reputation and demonstrate good faith.

Future-proof your products

Accessibility standards evolve. So do technologies, regulations, and user expectations. By building accessible foundations today, your team is better prepared to adapt to future changes with minimal disruption.

For example:

• New devices and platforms (like smart TVs, voice assistants, and AR/VR) rely on flexible, standards-compliant interfaces.
• WCAG 2.2 and future versions are already gaining traction.
• Legislative trends suggest more countries—including the U.S.—will strengthen digital accessibility requirements in the coming years.

Investing in accessibility now sets you up for long-term success.

Final thoughts

The European Accessibility Act is more than just a legal requirement—it’s a catalyst for better, more inclusive digital products. For U.S. IT companies aiming to serve or expand into the European market, accessibility must become a core part of product development, QA, and business strategy.

By acting now, your company can avoid last-minute scrambles, reduce legal and reputational risk, and build solutions that truly serve everyone. Accessibility isn’t just the right thing to do—it’s the smart thing to do.

At TestDevLab, we specialize in helping companies build accessible, high-performing software that meets international standards. Our QA experts can guide you through accessibility audits, testing, remediation planning, and continuous compliance support.

Whether you’re just getting started or looking to strengthen your existing efforts, we’re here to help you navigate the road to compliance with confidence.

Ready to make digital accessibility a competitive advantage? Don’t wait. Contact us to learn more about how our accessibility testing services can support your product goals.