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The European Accessibility Act goes live in 2025: Are you ready?

On June 28 2024, the European Accessibility Act (EEA) will come into force. If your digital products and services in the EU aren’t compliant, you risk significant fines and legal action. Here’s what you need to know to ensure compliance and benefit from creating inclusive products.


The European Accessibility Act goes live in 2025: Are you ready?

On June 28 2024, the European Accessibility Act (EEA) will come into force. If your digital products and services in the EU aren’t compliant, you risk significant fines and legal action. Here’s what you need to know to ensure compliance and benefit from creating inclusive products.

Lavinia Aparaschivei
| Linkedin
| Content Manager

In brief

Good design improves usability for everyone. However, many products today exclude millions of people due to accessibility barriers. The European Accessibility Act (EAA), which will come into force in mid-2025, aims to remove these barriers, ensuring equal access for people with disabilities and giving companies the opportunity to reach a wider audience and create inclusive products.

27% of the EU population (aged 16 years and over) have disabilities, often facing products that don’t take different abilities into account. Common issues include ATMs that only have touch screens and no audio feedback or online forms that lack proper labeling, have small click targets, or are difficult to navigate. Sites that can’t be navigated without a mouse or that automatically play audio or video, which can be disorienting or frustrating, especially for users with cognitive disabilities.

Then there are devices that don’t recognize a range of voices, speech impairments, or accents. What about a flat keyboard with no tactile markers on the home keys (F and J), making touch typing difficult. And on and on.

Enter the EAA.

The challenge for a number of industries is that it will apply to certain products and services put on the market after June 28, 2025. This doesn’t leave much time for compliance.

But will you be affected? What products must change? What does the EAA actually want you to do?

Let’s take a look.

What does it want to achieve?

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The dry version from the published directive itself: “The purpose of this Directive is to contribute to the proper functioning of the internal market by approximating laws, regulations and administrative provisions of the Member States as regards accessibility requirements for certain products and services by, in particular, eliminating and preventing barriers to the free movement of certain accessible products and services arising from divergent accessibility requirements in the Member States.”

Okay, now that you’ve had a couple of cups of coffee to wake up, let’s put it another way. The EAA is an EU-wide law that sets minimum accessibility standards for a range of products and services. This harmonizes accessibility requirements across member states, aiming to give people with disabilities more (equal) access to goods and services within the entire European Union.

Road to the European Accessibility Act


The European Commission issued Mandate 376 to establish functional accessibility requirements for any ICT product or service.


The European Telecommunications Standards Institute (ETSI) published the standard accessibility requirements (EN 301 549) to fulfill Mandate 376. These requirements are now used in Voluntary Product Accessibility Templates (VPAT) for European accessibility standards.


The European Accessibility Act (EAA) was published. It mandates that all private companies operating in the EU with more than 10 employees must comply with the directive.


The EAA’s finalized outlines of laws, regulations, and administrative provisions were established, which each EU member country will enforce.


The EAA will be fully enforced, with each EU member country operating under its own specific laws and penalties.

But don’t take this as a history lesson, what you should really understand is:

  • Digital products created in the EU after June 28, 2025, must adhere to the accessibility requirements outlined in the directive.
  • Each country enforcing the EAA must review and validate its enforcement every five years, ensuring continuous compliance rather than a one-time assessment.
  • Digital products designed before June 2025, which were not legally required to be accessible at the time, do not need to comply with accessibility standards until June 2030.

As we approach the implementation of the European Accessibility Act, it’s important for businesses to recognize that the five years (between 2025 and 2030) will pass by quicker than you might expect. Developing a comprehensive strategy and making the necessary adjustments to ensure compliance can be a time-consuming process. So it is crucial for organizations to start early in order to effectively meet the upcoming accessibility standards and avoid potential challenges down the line.

Who will be most impacted by the EAA?

Some industries need to prioritize accessibility, including banks and financial services, e-commerce and online retail platforms, mobile app developers (banking, ride-hailing, food delivery), digital product and service providers (e-books, streaming services), and manufacturers of digital equipment (computers, smartphones, ATMs, ticket machines). Telecommunications and internet service providers must also ensure their websites and apps comply.

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There are some exemptions, however. The EAA doesn’t apply to micro-enterprises (less than 10 employees and with an annual turnover not exceeding 2 million euro) and certain types of media, like pre-recorded videos published before June 2025. But overall, the EAA applies to a wide range of businesses that operate in the EU, or provide goods and services to EU customers (including importers and distributors).

Why it matters

Beyond giving people with disabilities equal access to digital products and services in the EU internal market, non-compliance can lead to (as the act states) penalties that “shall be effective, proportionate and dissuasive”.

Moreover, it can damage brand reputation and result in customer loss. Conversely, compliance with the EAA and other relevant standards, such as the Web Content Accessibility Guidelines (WCAG),can attract more customers, foster positive word-of-mouth, and facilitate cross-border trade. That’s why it’s essential to know your solution’s current accessibility level and to craft an effective strategy to ensure it is compliant. But more on that later.

Crowdtesting also plays a critical role in this process by identifying accessibility issues in real-world scenarios and ensuring that your solution meets these standards. This proactive approach not only helps keep you complaint but protects your brand from potential penalties and promotes an inclusive digital environment.

What are the EAA specifics?

  • Level A is the most basic level of web accessibility, which addresses the most critical issues that prevent access to content. Compliance ensures that content is accessible to some users with disabilities, but does not guarantee accessibility for all.
  • Level AA addresses a wider range of accessibility barriers and provides a higher level of accessibility, including for those with moderate visual impairments or hearing loss.
  • Level AAA is the highest and most comprehensive level of web accessibility and addresses the maximum number of users with disabilities, including severe visual impairments and cognitive limitations. It is typically pursued by websites specifically designed for individuals with disabilities, certain government and public sector sites, and organizations with a strong commitment to inclusivity.

If you’re developing anything online, you’ll know about the Web Content Accessibility Guidelines (WCAG), which is an international recommendation for making websites and, to a lesser extent, mobile apps, more accessible to people with disabilities (think of it as a recipe book for accessible web design). Currently, there are three versions, WCAG 2.0, WCAG 2.1, and WCAG 2.2 with WCAG 3 currently being drafted.

The EAA was built on the EU Web Accessibility Directive (focusing on public services), which directly references WCAG 2.0 Level AA standards.

However, unlike WCAG, the EAA is a legal requirement within the EU that applies to a much broader range of digital products and services that are developed by both public and private businesses:

  • Computers and operating systems
  • Self-service terminals (payment terminals, ATMs, etc.)
  • Consumer terminal equipment for electronic communications and audiovisual media services
  • E-readers
  • Electronic communications services
  • Services providing access to audiovisual media
  • Elements of passenger transport services (websites, mobile applications, etc.)
  • Consumer banking services
  • E-books and dedicated software
  • E-commerce services

As such, manufacturers who develop any of the above must “ensure that the products have been designed and manufactured in accordance with the applicable accessibility requirements” of the EAA.

The rather extensive list of these requirements are listed within Annex 1 (sections 1 to 7) in the EAA.

Just quickly, here’s a few for thought.

E-readers must support text-to-speech technology. Self-service terminals must allow the use of personal headsets and have adequate contrast and tactile keys and controls. Consumer terminal equipment must support synchronized voice, real-time text, and video.

On the service side, electronic communications services must provide real-time text in addition to voice communications. Audiovisual media services must transmit accessibility components like captioning, audio description, and sign language interpretation. Banking services must provide accessible identification methods, electronic signatures, security, and payment services.

It’s a pretty long list but an essential one to check.


Your five steps to compliance!

To ensure your digital products and services meet the EAA standards, follow these five essential steps:

1. Assess current accessibility

Conduct a comprehensive audit to identify areas of non-compliance and areas for improvement. Use a combination of tools and techniques:

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  • WCAG Contrast Checker: Ensure your website meets color contrast requirements.
  • Manual Testing: Check for keyboard navigation, screen reader compatibility, and other aspects that automated tools might miss.
2. Develop a compliance strategy

Based on the findings from your accessibility audit, create a detailed plan:

  • Prioritize fixes: Identify high-priority issues that significantly impact user accessibility and address them first (from missing alt text for images to incompatible color contrast and lack of keyboard focus indicators).
  • Allocate resources: Determine the budget, tools, and personnel required to implement accessibility improvements.
  • Set a timeline: Establish realistic deadlines for each phase of your compliance strategy, ensuring adequate time for testing and revisions.
3. Implement accessibility features

Take actionable steps to enhance accessibility:

  • Code modifications: Ensure your HTML, CSS, and JavaScript are optimized for accessibility by utilizing WCAG 2.1 guidelines, Web Accessibility Initiative ARIA Practices and relevant code checkers to help identify accessibility issues in the code.
  • Design changes: Modify your design to include larger touch targets, accessible forms, and better color contrast – in addition to ensuring you follow accessible design principles like clear hierarchy and logical navigation.
  • Content revisions: Update content to be clear and easy to understand, using plain language and providing alternatives for multimedia content (e.g., transcripts for videos). Ensure elements like headings for structure and alt text for images are included.
  • Assistive technologies: Integrate technologies like screen readers, voice recognition, and alternative input methods.
4. Test and refine

After implementing changes, thoroughly test your digital products:

  • Web Accessibility Testing: Re-run tests to check for new issues or regressions.
  • Website Testing: Conduct end-to-end testing of your website to ensure all user interactions are accessible.
  • Usability Testing: Focus on user experience, ensuring the website is not only accessible but also user-friendly.
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  • Customer Journey Testing: Map out typical user journeys and test each step for accessibility.
  • Crowd Surveys: Engage a diverse group of users, including those with disabilities and/or make use of assistive technologies, to gather feedback on their experience.
5. Maintain accessibility

Accessibility is an ongoing commitment:

  • Continuous monitoring: Regularly audit your digital products to ensure ongoing compliance as new features are added or existing ones are updated.
  • Stay updated on standards: Keep abreast of updates to accessibility standards like WCAG and the EAA requirements.
  • Incorporate accessibility into development processes: Make accessibility a core part of your design and development processes, integrating it into your workflows and training your team on best practices.
Additional considerations

  • Legal compliance: Make sure that you stay updated on any legal requirements that relate to digital accessibility in your region (and at the EU-wide level).
  • WCAG Integration: Use WCAG 2.1 AA as a benchmark for web content, building on existing compliance efforts. This provides a solid foundation for meeting broader EAA requirements.
  • Documentation: Maintain clear and detailed records of your accessibility efforts, including audit results, compliance strategies, and testing outcomes. This documentation can demonstrate compliance to authorities if needed.
  • Training: Educate your team on accessibility standards and practices. Continuous learning ensures that your team stays updated on new approaches and technologies, maintaining a culture of accessibility within your organization.

Accessibility is good for business

The European Accessibility Act is an opportunity to make the EU’s digital landscape more inclusive. Proactively ensuring accessibility can help you avoid penalties, expand your customer base, and enhance your brand reputation.

Put simply, a more accessible digital world benefits everyone! But with less than a year to go, it’s better to start your compliance journey now.

Aside from compliance, though, accessibility brings a myriad of benefits – some of which we mentioned in this article, like a more inclusive product, improved bottom line. But there’s so much more. In our next article, we will analyze all these advantages in detail and explore how and why accessibility fuels digital excellence. See you there!


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