How to Achieve European Accessibility Act (EAA) Compliance: A Comprehensive Guide

Digital accessibility has become a pressing concern for businesses around the world. In the European Union (EU), the push toward creating equitable digital experiences has resulted in the European Accessibility Act (EAA). The EAA sets out a standardized framework for making digital content accessible to people with disabilities, covering websites, mobile applications, e-commerce platforms, digital documents, and more.

This act has wide-reaching implications — not just for organizations headquartered in Europe, but for any company serving EU markets. With the EAA compliance deadline set for June 28, 2025, businesses face a ticking clock to ensure that their digital platforms meet recognized accessibility standards. Ignoring these regulations can have serious repercussions, from fines to potential legal and reputational damage.

In this blog post, we’ll unpack the core requirements of the EAA. We’ll look at the top accessibility issues that commonly put businesses at risk and highlight practical steps for adopting inclusive design principles and meeting internationally accepted standards, such as the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. Whether you’re a technical professional or a non-technical decision-maker, this comprehensive guide will help you understand the path to EAA compliance in time for the 2025 deadline.

Why is digital accessibility necessary?

You might be wondering: Why is digital accessibility necessary? At its heart, digital accessibility is about ensuring everyone has equal access to online products and services. Over one billion people globally live with some form of disability, and many barriers in digital environments can prevent them from accomplishing everyday tasks, from reading product descriptions to completing a simple checkout process.

Companies that prioritize accessibility gain more than just legal compliance. They benefit from a broader customer base, positive brand reputation, and better user experience for all visitors. Accessibility best practices — such as using clear headings, providing text alternatives for images, and designing intuitive navigation — enhance usability across the board. When done right, inclusive design fosters brand loyalty and can even yield higher conversions.

Above all, the moral imperative of digital accessibility is unassailable. Excluding a significant portion of the population from full participation in the digital economy isn’t just bad business; it’s fundamentally unfair. For business leaders deciding which initiatives to fund, it’s important to see accessibility as both a compliance issue and a deeply human concern.

Understanding the European Accessibility Act (EAA)

The EAA was established to harmonize accessibility rules across all EU Member States. Instead of each country enforcing entirely different requirements, the EAA creates a common ground, instructing all member countries to transpose its stipulations into national laws. Effectively, each country interprets and enforces the EAA in its own legislative framework, but the goal remains the same: ensuring digital platforms and services reach WCAG 2.1 Level AA conformance.

This broadens existing accessibility initiatives by including private businesses that offer products or services to EU consumers, even if those businesses are not physically located in Europe. From financial platforms and e-commerce websites to entertainment services and travel sites, if you cater to individuals within the EU, you’re under the EAA umbrella.

Key to these regulations is the principle that each nation will levy its own penalties and fines for non-compliance. The amounts vary by country. Some states may impose fines of up to €100,000, while others can approach €250,000. There’s even the possibility of higher recurring daily penalties until businesses address outstanding accessibility failures.

You might be interested in: See how European Accessibility Act applies to your country.

What is the scope of EAA compliance?

Many business leaders ask: “Is WCAG a legal requirement?” Under the EAA, the short answer is yes, specifically, WCAG 2.1 Level AA. This standard covers a range of accessibility provisions, from providing text alternatives for images to ensuring keyboard compatibility.

The EAA’s scope stretches beyond websites. Mobile apps, electronic documents (like PDFs and manuals), and digital customer service channels are all part of the package. If you offer software interfaces for consumer products, these user interfaces must also be accessible. For example, a TV streaming platform or an e-reader’s interface would come under these regulations.

Most businesses are aware that they need to address public-facing content, but they often neglect internal portals used by employees or contractors. While the EAA primarily focuses on consumer-oriented content, remember that many EU countries have overarching disability non-discrimination laws that require accessible environments for employees. Taking a holistic approach to digital accessibility can safeguard your organization on multiple fronts.

Top 6 accessibility issues putting you at risk

WCAG covers a wide range of success criteria, but certain issues are more frequently responsible for lawsuits or fines under laws like the EAA. Let’s explore the most common barriers:

Missing alternative text (alt text)

At a fundamental level, images must be accompanied by alt text to accommodate users who rely on screen readers. Yet, missing or vague alt text remains a common violation. Alt text is also a search engine optimization (SEO) best practice, so taking time to add accurate text alternatives helps with both compliance and discoverability.

Low color contrast

According to color contrast accessibility guidelines, text and background colors must meet a minimum contrast ratio, typically 4.5:1 for standard text and 3:1 for large text (18pt or above). Color blind or visually impaired users particularly benefit from adequate contrast, but these guidelines also enhance overall readability. Exploring a color blind friendly palette hex can be the first step to ensuring you use a palette that meets everyone’s needs.

Keyboard navigation traps

Some users operate web pages entirely via keyboard, often with the assistance of screen readers. Missing focus indicators or poorly structured tab orders can trap keyboard users, preventing them from progressing or exiting certain elements. This becomes a top reason for compliance demand letters, as these traps can render a website effectively unusable for many people.

Inaccessible multimedia (captions, transcripts)

Video and audio content must be accessible to people who are deaf, hard of hearing, or blind. Captions, transcripts, audio descriptions, or sign language interpretation can make all the difference. Given the explosion of video content online, lacking captions or transcripts is a glaring error, and one frequently identified in automated accessibility testing tools.

Broken or redundant links

Empty link text (like “Read more” or “Click here” without additional context) and broken hyperlinks cause confusion and frustration. Screen reader users often rely on link lists to jump around a site, and descriptive link text is vital for them to navigate efficiently. Redundant links that all point to the same page can also be confusing for assistive technologies.

Inaccessible e-commerce

Inaccessible e-commerce experiences pose a significant risk for legal action because they’re often complex websites with varied functionality (product searches, user accounts, payment gateways). From mislabeled product images (no alt text) to CAPTCHA elements that lock out screen reader users, the e-commerce checkout flow is a frequent source of friction.

The business case for complying with the EAA

It’s easy to frame the EAA as another regulatory burden, but there’s a strong business case behind accessibility. First, compliance widens your potential customer base by welcoming people who might otherwise face barriers to transaction. For instance, color contrast accessibility guidelines can help convert a visitor who might otherwise give up when faced with difficult-to-read text.

Second, accessible design tends to improve overall user experience. Clear navigation, logical information architecture, properly labeled forms, and descriptive links benefit all users. This can lower bounce rates and increase time-on-page. E-commerce websites, in particular, may see improvements in cart completion rates after addressing accessibility.

Moreover, an inclusive brand identity resonates with modern consumers. People increasingly want to purchase from companies that align with their values. Demonstrating that you adhere to ethical, accessible business practices can be a key differentiator. Finally, proactive compliance avoids expensive legal fees, reputational harm, and the potential for daily fines.

EAA enforcement and potential penalties

Penalties under the EAA differ from country to country, as each EU Member State sets its own mechanisms for enforcement. Some may cap fines at €100,000, while others can impose penalties of over €250,000 for severe or repeated violations. Beyond one-off fines, some regulators enforce daily penalties that accumulate until an organization addresses outstanding accessibility issues.

For instance:

• In Germany, authorities can penalize organizations with fines of up to €100,000 for non-compliant websites.
• In France, serious violations might incur penalties up to €250,000.
• In Sweden, the Swedish Agency for Digital Government can issue financial sanctions of up to 10,000,000 Swedish kronor (almost €900,000).

Repeated offenses can lead to reputational damage, increased governmental scrutiny, and even the suspension of business activities in extreme cases. Some EAA transposition laws treat non-compliance as a civil offense, but others may treat it as criminal if the breach is especially egregious or persistent.

Real-world examples of non-compliance consequences

To underscore the seriousness of EAA non-compliance, consider how private and public organizations have been penalized under similar disability non-discrimination laws in other jurisdictions. Over the past several years in the United States, for example, many top e-commerce sites have faced lawsuits for lacking alt text or providing inaccessible payment forms.

The EU has historically been strict in enforcing consumer protections and data privacy laws, as seen with GDPR fines. There’s no reason to think the EAA will be any different. Once enforcement ramps up after June 2025, we can expect more headlines of large settlements, especially targeting high-traffic websites and widely used digital platforms.

While smaller businesses might not face the same scale of penalties, they’re still vulnerable. In many EU countries, local advocacy groups regularly test websites for accessibility. If they discover significant barriers, they may file complaints or demand letters, which could lead to legal actions.

What does accessibility mean in social media?

Many companies assume accessibility applies mainly to their websites or apps. But what does accessibility mean in social media? In short, any social media content — from posts on LinkedIn to stories on Instagram — should also meet accessibility best practices. Provide alt text for images, include captions or transcripts for videos, and avoid excessive use of emoji or special characters that screen readers have trouble interpreting.

Social media platforms have their in-platform accessibility settings and guidelines. For example, YouTube includes automated captioning (though it can be error-prone, so manual review is crucial). If social content is a key part of your business’s marketing, building inclusive social media practices is essential for brand reputation and EAA compliance in countries that interpret the law broadly.

WCAG 2.1 Level AA: The gold standard

As the EAA references WCAG 2.1 Level AA, it’s useful to understand what these guidelines entail. WCAG 2.1 stands for Web Content Accessibility Guidelines, version 2.1. Managed by the World Wide Web Consortium (W3C), these guidelines address critical pillars of accessibility: Perceivable, Operable, Understandable, and Robust (POUR).

WCAG 2.1 is divided into levels of conformance: A, AA, and AAA. Level AA is widely seen as the legal baseline in many jurisdictions, covering issues like text contrast, form labeling, keyboard accessibility, and mobile accessibility. Achieving AA conformance typically meets the needs of users with a range of disabilities, from visual impairments to mobility or cognitive issues.

When businesses ask, “Is WCAG a legal requirement?” the answer in the EU context is effectively yes. The EAA directly references these standards, so failing to meet WCAG 2.1 AA means failing to meet the fundamental criteria set forth by the EAA.

Conducting an accessibility audit

To get started with EAA compliance, it’s vital to know where you stand. That’s where an accessibility audit comes in. If you’ve ever wondered how to conduct an accessibility audit, the process involves automated scanning as well as manual testing:

1. Automated tools: Tools like WAVE, Axe, or other free accessibility testing tools crawl your site to detect many common issues, including missing alt text and low contrast.
2. Manual testing: Accessibility experts and users with disabilities manually navigate your site using assistive technologies such as screen readers and keyboard-only navigation. This step catches issues automation alone might miss (like poorly structured heading hierarchies or complex interactive elements).
3. Reporting: The findings are compiled in a thorough report, highlighting each WCAG success criterion that your platform fails to meet. You’ll also receive recommended solutions, timelines, and severity levels.

Depending on the size of your digital footprint, you might need a phased audit approach, focusing on your most visited pages or core transaction flows first. From there, you can progressively fix issues across your entire ecosystem.

Automated accessibility testing tools and their limitations

The market for automated accessibility testing tools is growing, with some solutions offering real-time scanning, integration with continuous integration/continuous deployment (CI/CD) pipelines, and even code suggestions to fix accessibility barriers.

These technologies can help you identify repeated issues, such as incorrectly nested HTML elements, missing form labels, or low-contrast text. However, automation can only detect around 30–40% of possible WCAG violations. Issues like ambiguous alt text or unclear link context often require manual interpretation.

Therefore, accessibility testing should be a blend of automation and manual review. Automated scans are fantastic for spotting patterns, but a human touch is needed to evaluate user experience. And if you’re aiming for EAA compliance, you won’t want to rely solely on automated scanners.

You might be interested in: 5 Most Commonly Used Tools for Web Accessibility Testing.

Importance of manual testing and expert review

Manual testing is key to fulfilling the full scope of WCAG 2.1 Level AA. Accessibility specialists and people with disabilities can replicate real-world usage scenarios in ways that automated tests can’t. They can check whether keyboard users can easily navigate a dropdown menu or confirm if transcripts accurately capture spoken dialogue in a video.

Expert review also helps in prioritizing issues. While an automated tool might flag 200 errors, some could be duplicates or low-impact issues. A specialist can reframe which issues are the most urgent from a user perspective. This is especially important when setting compliance roadmaps under tight deadlines like June 2025.

Crafting a long-term accessibility strategy

The EAA’s 2025 deadline shouldn’t be seen as a one-time finish line. Digital content evolves continuously. Every new blog post, product listing, or software release can potentially introduce new barriers. To maintain compliance, businesses need a long-term strategy that includes:

1. Ongoing audits: Regularly check your site and apps, especially after redesigns or platform updates.
2. Governance and policy: Create internal guidelines ensuring developers, designers, and content creators follow accessibility principles.
3. Training: Offer training to all relevant staff on best practices, from color blind friendly palette hex usage to proper HTML structure for headings.
4. Accessibility champion: Appoint a role or department responsible for accessibility oversight — sometimes called a digital accessibility specialist or “Accessibility Champion.”

By establishing clear governance and routine checks, you keep your organization on track. This also protects you from the risk of daily penalties that could pile up if regulators discover major accessibility gaps.

Addressing mobile accessibility

With smartphones, tablets, and other mobile devices dominating user interactions, focusing on mobile accessibility testing is paramount. WCAG 2.1 introduced success criteria specifically targeting mobile experiences. This includes making sure interactive elements are large enough for touch targets, ensuring the screen reflows properly when zoomed, and verifying that orientation changes (portrait vs. landscape) work seamlessly.

Accessibility audits should never skip mobile. If your website or app is only partially optimized for mobile screen readers or if pinch-zoom gestures break your layout, users with disabilities may not be able to navigate. And given that mobile commerce is skyrocketing, ignoring mobile accessibility could alienate a big chunk of potential customers and place you at legal risk.

Inclusive design in products and services

Accessibility is more than checking off guidelines. It’s about creating accessible design products that naturally accommodate a broad range of users from the start. By embedding inclusive design principles at the conceptual stage, you reduce the likelihood of accessibility problems later.

Many designers today incorporate persona-building exercises that include users with disabilities. They test prototypes with people who use assistive technology, gather feedback, and iterate. This approach not only meets compliance needs but can lead to innovative solutions that benefit everyone. After all, features like auto-complete or voice-controlled interfaces were once considered accessibility features — today, they’re mainstream conveniences.

Handling accessibility in e-commerce

We’ve highlighted e-commerce as a high-risk area for EAA violations. Complex checkout funnels, product filtering systems, user reviews, and dynamic content can introduce numerous barriers. Think about a “filter by color” widget that doesn’t have labels properly set for screen readers, or a payment gateway form missing crucial accessible name attributes for each field.

An accessible website design for e-commerce covers alt text for product images, consistent navigation, forms labeled for assistive technologies, and error messages that help users correct inputs. Even small wins like ensuring the “Add to Cart” button has a clear label that a screen reader announces can make a big difference.

Common accessibility testing pitfalls and challenges

Even with a robust accessibility testing strategy, certain pitfalls can undermine your efforts:

• Overreliance on automation: Automated scans alone won’t detect issues like vague alt text or ambiguous button labeling.
• Lack of clarity in responsibilities: Without clear roles and responsibilities (e.g., an accessibility tester vs. a content manager), tasks can slip through the cracks.
• Incomplete testing environments: Testing only the homepage or ignoring interactive pages means you might miss major problems elsewhere.
• Ignoring dynamic content: Elements like drop-down menus, pop-ups, and embedded videos often pose hidden barriers.

Staying organized with an accessibility test plan template can help. List out all the user journeys you need to check, from sign-up to purchase, to ensure you leave no stone unturned.

Preparing for the June 2025 EAA deadline

With the 2025 deadline rapidly approaching, it’s crucial to form a roadmap. Consider these steps:

1. Initial audit: Identify the most pressing accessibility issues using both automated and manual checks.
2. Remediation: Fix the high-priority barriers first, especially those that block critical user paths like sign-ups or purchases.
3. Review and testing: Conduct a comprehensive re-check. If feasible, bring in third-party experts for validation.
4. Training and policy: Set up guidelines so that new content and features are accessible from the outset.
5. Continuous monitoring: Plan for regular retests, user feedback channels, and performance metrics tracking.

Adopting these measures early will help you avoid a frantic scramble in late 2024 or early 2025. Accessibility is an ongoing commitment. Organizations that cultivate an inclusive mindset often find that changes become easier over time, and the overall user experience improves significantly.

What are the next steps?

Digital accessibility is no longer just a nice-to-have; it’s a legal, ethical, and market-driven necessity. The European Accessibility Act (EAA) mandates conformance with WCAG 2.1 Level AA by June 28, 2025, placing real pressure on businesses to proactively address accessibility barriers. Non-compliance can lead to stiff fines, daily penalties, and significant reputational harm.

That said, compliance doesn’t have to be an overwhelming burden. Many tools and techniques exist to make the journey manageable, from automated accessibility testing tools that detect low-hanging fruit to thorough manual audits by experts. Adopting inclusive design principles can help you build better, more intuitive products for all your users.

For European business decision-makers — especially those with both technical and non-technical backgrounds — the time to act is now. Start by conducting a thorough digital accessibility audit. Address top issues like missing alt text, low color contrast, and poor keyboard navigation. Overhaul your training and content creation processes so that new content is inherently accessible.

By turning EAA compliance into a long-term strategy, you’ll not only dodge hefty fines but also create more inclusive experiences that resonate with modern consumers. Embracing accessibility is a win-win scenario: it keeps regulators satisfied, broadens your market reach, and shows your commitment to social responsibility.

Key takeaways

• The EAA will enforce WCAG 2.1 Level AA by June 28, 2025, requiring websites, mobile apps, and more to be fully accessible to EU consumers.
• Non-compliance risks heavy fines and reputational damage, with penalties differing by country (up to €250,000 or higher for repeated violations).
• Address common barriers such as missing alt text, low color contrast, and keyboard traps, as these are frequent causes of lawsuits under the EAA.
• Inclusive design widens your customer base and boosts user satisfaction, making accessibility investments a win-win for both compliance and brand reputation.
• Automate initial checks but always add manual reviews, since automation alone can miss key user experience issues that affect people with disabilities.
• Embed accessibility in long-term strategies (training, policies, audits) to ensure ongoing compliance, cover social media content, and avoid last-minute fixes before the 2025 deadline.

Final words

Whether you’re uncertain what digital access is or you’re a seasoned professional looking into website accessibility companies, remember that building inclusive digital experiences is an ongoing process. The digital accessibility foundations you set today will serve your organization for years to come, well beyond the June 2025 EAA deadline.

Ready to take the next step? Start by evaluating your current website, product designs, and customer service workflows against WCAG 2.1 AA guidelines. If you need guidance, consider consulting with an accessibility expert or employing specialized automated accessibility testing tools. The return on investment isn’t just regulatory compliance — it’s a better experience for all.

Additional resources

Enhance your digital accessibility journey with these valuable resources:

• Our comprehensive accessibility testing services provide a thorough evaluation of your digital products against WCAG standards and accessibility best practices.
• Equip your team with practical knowledge through our customized accessibility training programs for designers, developers, content creators, and QA specialists.
• Examine how the European Accessibility Act impacts telecommunications companies with our Digital accessibility & EAA: Telecommunications industry under review white paper.
• Watch our Quality Forge 2024 - Digital accessibility conference featuring industry experts discussing the latest accessibility trends, legal requirements, and implementation strategies.