The European Accessibility Act Is Live — Developer Guide

The European Accessibility Act (EAA) entered force on 28 June 2025. By April 2026, six member states have published enforcement actions, three SMEs have received fines between €5,000 and €40,000, and DG Internal Market is publishing quarterly compliance reports. If your website serves EU consumers and you're not WCAG 2.1 AA compliant, you are now operating in non-compliance territory.

This is the developer-focused breakdown.

What the EAA actually covers

The EAA isn't just "make websites accessible." It's a market harmonization directive. It applies to:

E-commerce (any B2C selling)
Banking & financial services (consumer-facing)
E-books and dedicated reading software
Transport (ticketing, info terminals)
Telecom services (consumer-facing)
Audiovisual media services (access services)
ATMs, payment terminals, ticketing machines
Smartphones, computers, TVs (the hardware itself)

If you sell anything to a consumer in the EU through a website, you're in scope. The 250-employee / €50M turnover micro-enterprise exemption applies only to services, not products. And national rules go beyond the EAA in Spain, France, and Germany.

What "accessible" technically means

The EAA defers to EN 301 549, which adopts WCAG 2.1 AA for web content. Some member states are pushing WCAG 2.2 (added in October 2023) — better start there.

The four POUR principles:

Perceivable: text alternatives, captions, contrast 4.5:1 for normal text, 3:1 for large text
Operable: keyboard navigation, no seizure-inducing flashes, focus visible
Understandable: predictable navigation, error identification, input assistance
Robust: parses validly, ARIA used correctly, name/role/value exposed

A WCAG 2.2 AA conformance review = approximately 78 success criteria. A passing site needs all of them.

The 24-hour developer audit

You can do this without paying €15,000 for a Siteimprove license:

Hour 1 — Automated baseline

# axe-core via Playwright
npx playwright test --reporter=html
# OR free online: WAVE, Lighthouse, Pa11y

Automated tools catch ~30% of issues. Don't stop here.

Hour 2-4 — Keyboard-only manual sweep

Unplug the mouse. Tab through every page. Check:

Focus visible at all times
All interactive elements reachable
Skip-to-content link near top
Modal dialogs trap focus correctly
ESC dismisses overlays

Hour 5-8 — Screen reader smoke test

NVDA (free, Windows) or VoiceOver (Mac). Read the homepage, a form, a checkout page, a search results page. Note where context is missing.

Hour 9-16 — Top 20 failure points

Run targeted audits:

Color contrast (every text/bg pair)
Form labels (every input has visible + programmatic label)
Image alt text (every <img> has alt OR alt="" if decorative)
Heading order (H1 → H2 → H3, no skips)
Link text (no "click here", "read more")
Page language declared (<html lang>)
ARIA used minimally (prefer semantic HTML)
Error messages associated with inputs (aria-describedby)

Hour 17-20 — Accessibility statement

The EAA requires a public statement at /accessibility with:

Conformance level (full / partial / non-conformant)
Inaccessible content list
Alternative access methods
Contact for accessibility complaints
Date of last review
Enforcement procedure link

We publish a free template at fixmyweb.dev/accessibility-statement-generator.

Hour 21-24 — Fix the top 5 issues

You won't fix everything in 24h. Pick the 5 highest-impact:

Color contrast violations
Missing form labels
Missing alt text on content images
Keyboard traps
Missing skip-link

That's a 50% reduction in audit findings, achievable in one work day.

The 201-check superset

We compiled a checklist of every automated WCAG 2.2 rule plus manual heuristics: 201 individual checks. It maps to:

WCAG 2.0 + 2.1 + 2.2
EN 301 549 v3.2.1
Section 508 Refresh

That's the exact rule set our scanner runs at fixmyweb.dev. Free tier: 3 scans no card, full report download. Paid tiers exist if you need monitoring.

The hard truth

The companies fined in 2025-2026 weren't malicious. They had outdated CMSes, third-party widgets that broke accessibility, contrast violations on hero gradient overlays, and no alt text on auto-generated thumbnails. Boring failures, expensive consequences.

If you ship anything to EU consumers, run the audit this week. Fix the top 5. Publish the statement. That puts you ahead of 70% of the EU SMB market. The remaining 30% has 12-18 months before they all get audited.

Antonio Altomonte builds accessibility and compliance tools at DevToolsmith. WCAG scanner free tier: fixmyweb.dev.

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