Who must comply with the European Accessibility Act?

The EAA applies to businesses that provide consumer products or services in the EU covered by the directive: e-commerce, consumer banking services, e-books, telecommunications services, TV broadcast equipment and services, transport service passenger information (air, bus, rail, waterborne), and self-service terminals like ATMs, ticket machines and check-in kiosks. Microenterprises providing services (fewer than 10 employees and under €2M turnover) are exempt from service obligations.

When did the EAA become enforceable?

The EAA has applied to new products and services since 28 June 2025. Service contracts concluded before that date may run unchanged until their expiry but no longer than five years (until June 2030). Member states had to transpose the directive into national law by 28 June 2022.

What standard defines EAA conformance for websites?

Harmonized European standard EN 301 549, which incorporates WCAG 2.1 Level AA as its web requirement. Meeting WCAG 2.1 AA for your website and mobile apps is the practical benchmark most regulators and market-surveillance authorities use when checking digital services under the EAA.

What are the penalties for EAA non-compliance?

Penalties are set nationally and vary by member state, but all states must provide effective, proportionate and dissuasive sanctions. Beyond fines, authorities can require corrective action, withdraw non-compliant products or services from the market, and suspend service provision. Consumer associations can also take legal action on behalf of affected users.

Updated August 2026 · Applies since 28 June 2025 · Directive (EU) 2019/882

The European Accessibility Act Checklist for Digital Services

28 concrete requirements across 6 categories, mapped to EN 301 549 / WCAG 2.1 AA. Tick what's in place, watch your score update live, and get a prioritized gap list at the end. Nothing is stored — everything runs in your browser.

This is a self-assessment tool, not legal advice. It maps to the accessibility requirements of Directive (EU) 2019/882 as specified by EN 301 549. Enforcement and penalty details vary by member state — verify against your national law and involve counsel for formal questions.

1. Scope & Governance

Before fixing anything: know whether you're in scope, and who owns it.

You've confirmed which of your services fall under the EAA MUST E-commerce, consumer banking, e-books, telecoms, transport passenger info, and self-service terminals are covered. B2B-only services generally are not — but many companies serve both without realizing it. A named person owns accessibility compliance MUST Market-surveillance authorities expect a contactable responsible party. "The web team" is not an owner. An accessibility policy statement is published SHOULD A public commitment plus a feedback channel is both good practice and expected by several member-state regimes. Our compliance template pack includes one. Staff who build content have received accessibility training SHOULD Editors, designers and developers each introduce different classes of barriers. Annual training keeps regression rates down.

2. Perceivable Content

WCAG 2.1 AA principles 1–2 — users must be able to perceive your content.

All meaningful images have accurate alt text MUST Decorative images need empty alt attributes so screen readers skip them. Missing alt text is the single most common WCAG failure worldwide. Text contrast meets 4.5:1 (3:1 for large text) MUST Low-contrast gray-on-gray design trends fail this constantly. Test your actual brand colors, not a sample page. Video has captions; audio-only content has transcripts MUST Pre-recorded video requires captions at AA level. Auto-captions alone don't reliably meet the accuracy bar. Content reflows at 320px width without horizontal scrolling SHOULD WCAG 1.4.10: users who zoom to 400% must still be able to read in a single column. Fixed-width layouts fail. Text alternatives exist for icons and non-text UI elements SHOULD Icon-only buttons (cart, close, menu) need accessible names. The free EUComply scanner flags missing alt text automatically on any URL.

3. Operable Interfaces

Everything must work without a mouse.

Every function is reachable and usable by keyboard alone MUST Tab through your whole checkout. If focus disappears into a modal or custom widget, keyboard users cannot buy from you. Keyboard focus is always visible MUST outline:none without replacement is a direct WCAG 2.4.7 failure and one of the easiest violations to spot. No time limits trap users without a way to extend or disable them MUST Session timeouts, carousels and countdown timers need pause, extend or adjust mechanisms (WCAG 2.2.1). Focus order matches visual reading order SHOULD CSS order changes and positive tabindex values create illogical tab paths through forms and menus. Motion-triggered interactions have a non-motion alternative SHOULD WCAG 2.5.4 AA-level: swipe gestures and shake-to-act need buttons too, for users who cannot perform precise movement.

4. Understandable Forms & Errors

Where e-commerce loses accessibility-critical conversions.

All form fields have programmatic labels MUST Placeholder text is not a label. Screen readers announce nothing useful without proper label elements or aria-labels. Error messages identify what went wrong and how to fix it, in text MUST Red borders alone fail WCAG 3.3.1/3.3.3. "Invalid input" is not a fix instruction; "Enter a date as DD/MM/YYYY" is. The page language is declared and language changes are marked up MUST Missing lang attribute makes screen readers use the wrong speech synthesizer — the entire page becomes unintelligible audio. Input purpose is programmatically identifiable where relevant SHOULD autocomplete attributes on name/email/address fields let assistive tech and browsers autofill correctly (WCAG 1.3.5). Navigation is consistent and help is available in the same place on every page SHOULD WCAG 3.2.3/3.2.6: repeated components in the same relative order; a site-wide help entry point.

5. Robust Code & Assistive Technology

Your markup must survive contact with real screen readers.

Pages use valid, semantic HTML with correct heading hierarchy MUST One h1 per page, headings that nest logically, landmarks (nav/main/footer). Screen-reader users navigate by structure, not visuals. Status messages are announced without stealing focus MUST "Added to cart", "3 results found", form success confirmations need aria-live regions — otherwise screen-reader users never learn anything happened. Tested with at least one screen reader (NVDA/VoiceOver) end-to-end SHOULD Automated tools catch perhaps 40% of issues. A 30-minute NVDA pass over checkout finds most of the rest. ARIA is used only where native HTML can't do the job SHOULD Broken ARIA is worse than none. Prefer native elements; when using ARIA roles/states, keep them synchronized.

6. Documentation, Monitoring & Market Duties

EAA obligations beyond the pixels — the part audits actually examine.

Accessibility information about the service is made available to consumers MUST Art. 4/5 & Annex IV of the directive require public information on how the service meets accessibility requirements — typically an accessibility statement page. Technical documentation demonstrating conformity is kept on file MUST Audit reports, test results and the applied standard (EN 301 549). Authorities can request it; you have to be able to produce it. A feedback channel exists for users to report accessibility barriers MUST Several national transpositions make a functioning response channel a formal requirement, not just courtesy. Accessibility is re-tested on a schedule and after major releases SHOULD Conformity decays with every deploy. Quarterly automated scans plus release-gate checks keep the documentation honest. Procurement contracts with suppliers carry accessibility requirements SHOULD If a third-party widget, payment form or chat tool is inaccessible, it's your compliance problem, not theirs.

Next step: several technical items (alt text, contrast signals, headers, TLS) can be verified automatically. Run the free scanner on your public URL — it works on any CMS, not just WordPress. Need an accessibility policy statement and audit-ready documentation templates? Browse ComplianceDocs templates.

Frequently asked questions

Who must comply with the EAA?

Any business providing covered consumer products or services to EU customers regardless of where it's based: e-commerce sites, consumer banking, e-books, telecom services, TV equipment and services, air/bus/rail/waterborne passenger transport information, and self-service terminals (ATMs, ticket machines, check-in kiosks). Services-only microenterprises — fewer than 10 staff and under €2M annual turnover — are exempt, though many choose to comply anyway because the same fixes satisfy procurement demands and ADA-style litigation risk outside the EU.

Doesn't Web Accessibility Directive (EU 2016/2102) already cover websites?

No — that directive covers only public-sector bodies. The EAA extends binding accessibility requirements to the private sector for the first time: any company selling covered consumer services in the EU. If you run a private e-commerce store, the WAD never applied to you, but the EAA does.

What exactly counts as "conforming"?

The harmonized standard EN 301 549 defines conformance, and its web chapter incorporates WCAG 2.1 Level AA. In practice: meet WCAG 2.1 AA on your website and mobile apps, document how you meet the remaining EN 301 549 clauses (documentation, support services, information provision), and keep evidence. You don't formally certify — you self-declare backed by documentation market surveillance can inspect.

We're based outside the EU — does this apply to us?

Yes, if you offer covered services to consumers in EU member states. The EAA follows the market, not the headquarters. A US-based online shop selling to French customers falls under the French transposition. Non-EU sellers are among the least prepared groups, which is why enforcement actions frequently start there.

What happens if we don't comply?

Each member state sets its own sanctions but they must be effective, proportionate and dissuasive: fines, corrective orders, withdrawal of the non-compliant service from that market, and suspension of provision. Consumers and representative organizations can also pursue claims. Because the EAA has been live since 28 June 2025, "we're working on it" is no longer a defense — documented remediation plans are what authorities accept.