The European Accessibility Act (EAA) came into effect on 28 June 2025. Many of our customers have asked what impact that may have on the digital services they offer.
This post provides information on the application of the EAA in the context of websites and mobile apps.
Understanding any new legislation can be challenging. The nature of the European Accessibility Act as a directive and its wide scope can make it particularly difficult to fully understand.
While our Understanding the European Accessibility Act (EAA) post provides a review of the entire directive, this post focuses on digital content only, to make it easier for organisations offering websites, mobile apps, and other digital content to find the information they need.
The EAA is a directive, not a law. It sets the overall goals that organisations must achieve, but it does not contain details about how these goals are enforced and monitored. This is decided at a national level by each European Union (EU) member state.
Over the past few years, all EU member states have transposed the EAA into national law. Organisations operating in EU markets must comply with the relevant national law in order to comply with the EAA.
This depends on many factors, including the size of your organisation, the countries it operates in, and the types of digital services it offers.
The following decision tree may help you understand whether your organisation's websites and apps are covered by the EAA:
If you answered Yes to all of these questions, the EAA most likely applies to your organisation's digital services.
Even if your organisation does not provide services directly to customers but sell web or native content to other organisations that make it available to the public, it still needs to consider the requirements of the EAA. Unless its content is compliant, organisations covered by the EAA may be unable to purchase or integrate it into their services.
There are three sets of requirements your organisation need to consider:
The general requirements your organisation must meet are set in the EU "harmonised standard" EN 301 549 (PDF). According to the EN 301 549, digital services must meet WCAG 2.1 compliance. Note that this is due to be updated to reference WCAG 2.2 soon.
Your organisation must then check whether the services it provides are subject to the additional service-specific requirements described in Annex I Section IV of the EAA. For example, one of the requirements in the EAA for consumer banking services is:
Ensuring that the information is understandable, without exceeding a level of complexity superior to level B2 (upper intermediate) of the Council of Europe’s Common European Framework of Reference for Languages.
Finally, organisations must comply with the country-specific requirements in the national law of the countries they operate in.
No, the EAA lists a number of exemptions:
- Pre-recorded time-based media published before 28 June 2025;
- Office file formats published before 28 June 2025;
- Online maps and mapping services, if essential information is provided in an accessible digital manner for maps intended for navigational use;
- Third-party content that is neither funded, developed by, or under the control of, the economic operator concerned;
- Content of websites and mobile applications qualifying as archives, meaning that they only contain content that is not updated or edited after 28 June 2025.
The EAA also contains a section about disproportionate burden; if an organisation believes that making some of its content compliant would result in a disproportionate burden, it can request for it to be exempt. However, very few cases are likely to meet the criteria for disproportionate burden. For example, a small organisation offering self-help eBooks might qualify if the cost of full compliance would genuinely threaten its ability to operate. A larger company with greater resources, however, is unlikely to meet that threshold.
The steps that organisations should take as they work towards reaching compliance are described in another EU harmonised standard referenced by the EAA: EN 17161 Design for All
As described in Understanding EN 17161 Design for All, this standard explains how organisations can integrate accessibility in their processes and practices across the following areas:
Monitoring compliance is responsibility of the individual EU member states. Each state has its own monitoring processes and has appointed one or more market surveillance authorities to carry them out.
The market surveillance authorities are ultimately responsible for ensuring that organisations operating in their country follow the EU harmonised standards EN 301 549 and EN 17161 and any additional country-specific requirements, thus complying with the EAA requirements.
They are also tasked with reviewing the applications for disproportionate burden claims.
Your organisation's websites and apps must be assessed against WCAG and their compliance level must be described in a publicly available accessibility statement.
Currently, the EAA does not provide details on the contents or format of this statement. However, in 2022 the European Commission (EC) requested the harmonised standard EN 301 549 be updated and part of this update will be to include "a model accessibility statement in accordance with Directive (EU) 2016/2102". Many organisations are therefore already using the model accessibility statement template from Directive (EU) 2016/2102 to document the compliance level of their digital services.
Article 13 of the EAA also requires organisations to inform the relevant market surveillance authorities of non-compliant services:
In the case of non-conformity, service providers shall take the corrective measures necessary to bring the service into conformity with the applicable accessibility requirements. Furthermore, where the service is not compliant with applicable accessibility requirements, service providers shall immediately inform the competent national authorities of the member states in which the service is provided, to that effect, giving details, in particular, of the non-compliance and of any corrective measures taken.
Since each member state is ultimately responsible for monitoring conformance, your organisation should also check any country-specific requirements around documenting compliance.
The penalties for non-compliance are set by the individual EU member states; they may include fines or prohibition on selling services altogether.
According to Article 13 of the EAA, if you are contacted by a market surveillance authority you must:
Provide it with all information necessary to demonstrate the conformity of the service with the applicable accessibility requirements. [You] shall cooperate with that authority, at the request of that authority, on any action taken to bring the service into compliance with those requirements.
Based on this, it is likely that market surveillance authorities will first ask organisations to rectify any existing issues and make their services compliant. However, if issues are not acted upon promptly, organisations are likely to face penalties.
To learn more about the EEA and associated standards, you can read our Understanding the European Accessibility Act (EAA) and Understanding EN 17161 Design for All posts. We can also provide EAA Assessments and Consultancy services to help you meet your goals.
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