European Accessibility Act 2025: What Businesses Need to Know Before the Deadline

The European Accessibility Act (the EAA, Directive 2019/882/EU) has been adopted as law in 2019, with a compliance date of June 2025, when products and services placed on the European market must comply with the law’s accessibility requirements. Therefore, if your company serves European customers, is organized in Europe, or distributes products there, this is not a future concern to be put on a road map. It is something that needs to be actively dealt with now.

This post will cover what the EAA requires, who must follow it, what the technical standard looks like, and what you must do to prepare.

What the European Accessibility Act Is

The EAA is a directive that establishes accessibility requirements for a set of products and services sold in the EU. Prior to the EAA, there were differing accessibility requirements across the EU member states, which the directive now harmonizes into a common standard applying to all markets. This means that previously, individual member states’ accessibility laws could be more or less stringent than the EAA requirements – but after June 2022, when the directive was fully incorporated into the laws of all member states, the EAA requirements became the baseline for accessibility in the EU.

The EAA is a directive and not a regulation, and thus member states are required to incorporate it into their laws, which they did by June 2022. Therefore, from June 28 th , 2025, new products and services placed on the market must comply with the EAA. However, there is a transition period for older products already on the market, which may remain until June 2030, depending on the member state.

Who Must Follow the EAA

The EAA applies to economic opera tors placing products or services on the EU market and service providers offering services to end users in the EU.

Economic operators include manufacturers, importers, distributors, and authorized representatives of economic operators who place products on the EU market. Therefore, if your company falls under any of these categories and sells any of the products covered by the EAA, you must ensure their compliance.

Service providers include organizations offering any of the services covered by the EAA to end users in the EU. Thus, in practice, this includes digital services for end users in the EU, which is why many international companies without a physical presence in the EU will have to adjust their digital offerings.

The EAA provides for a derogation for micro, small, and medium-sized enterprises (SMEs) – organizations with fewer than 10 employees and a turnover or asset total of no more than €2 million are not subject to the EAA for services. However, SMEs are still required to comply with the EAA when it comes to products.

Another derogation the EAA provides for is a disproportionate burden – an economic operator may be exempt from following specific accessibility requirements if they can demonstrate that these requirements would impose a disproportionate burden on them after having assessed the benefits these requirements would deliver to persons with disabilities.

EAA what Products and Services Apply

The EAA applies to a wide range of products and services falling under six categories:

Products:

• computers and operating systems
• ATMs, ticket machines, and check-in/self-service terminals
• mobile phones and consumer terminals (including smartphones)
• payment terminals
• e-readers

Services:

• telephone and text-based communication services
• audiovisual media services (including online and on-demand services and electronic program guides)
• passenger transportation services by air, bus, rail, and water
• banking services
• e-books and computer software related to e-books
• e-commerce services

This coverage includes a significant number of businesses, but the most relevant category for most organizations is probably services. Audiovisual services include online services, such as streaming platforms, which makes their websites and mobile applications subject to the EAA. Similarly, telephone and text-based communication services apply to organizations interacting with end users in the EU through their websites or mobile applications. Passenger transportation services include buses, airlines, and other forms of transport that may interact with end users. Banking services, e-commerce services, and e-books are also relevant.

Note that the scope of the EAA is considerably broader than the scope of the ADA and Section 508. How Australia’s web accessibility requirements compare to European standards in 2026 provides useful comparative context for organizations navigating multiple international accessibility frameworks.

What the EAA Asks for Technically

EN 301 549 defines the accessibility requirements for information and communication technology (ICT), which incorporates much of the content of WCAG. Specifically, the EAA incorporates WCAG 2.1 Level AA as technical criteria for web content.

The specific requirements span:

Web content and applications: WCAG 2.1 Level AA — perceivable content, keyboard-operable interfaces, understandable information and operation, and robust compatibility with assistive technologies.

Mobile applications: EN 301 549 includes additional requirements for mobile-specific accessibility, including touch gesture alternatives, screen reader compatibility, and notification accessibility.

User interface and functionality: Products must allow users to adjust text size and spacing; content must be adaptable to different presentation requirements; audio content must be captionable; and interfaces must work with the range of assistive technologies users employ.

Documentation and support: Support services (help content, FAQs, chatbots, telephone support) must also be accessible, and documentation must be available in accessible formats.

WCAG 2.2 has been published since EN 301 549’s last major update, and while EAA’s current technical standard remains WCAG 2.1 AA, organizations building for forward compliance should address WCAG 2.2 criteria alongside the current baseline. The 2026 accessibility testing landscape and how WCAG standards are evolving alongside international regulatory requirements covers where standards are heading.

EAA vs ADA: How They Differ

Organizations already familiar with US ADA accessibility requirements will find significant overlap but also meaningful differences:

Scope: The EAA covers a defined product and service category list explicitly. ADA Title III’s application to websites has evolved through litigation without explicit statutory product-category definitions, making the covered scope less precise in US contexts.

Technical standard: Both EAA and US requirements reference WCAG 2.1 Level AA, but the EAA does so through EN 301 549 while US requirements reference WCAG directly (for ADA Title II) or through Section 508 (for federal contexts).

Enforcement mechanism: EAA compliance is enforced through national market surveillance authorities in each member state, which can issue corrective measures and penalties. ADA enforcement occurs through private litigation and Department of Justice proceedings.

Documentation requirement: EAA requires economic operators to maintain technical documentation demonstrating conformance, and service providers to produce accessibility statements. This documentation requirement is more explicit and standardized than equivalent US requirements.

How ADA Title II digital accessibility requirements have evolved and what they require in 2026 covers the US side of this comparison for organizations navigating both markets.

The EAA Accessibility Statement Requirement

One EAA requirement that has no direct equivalent in US accessibility law is the mandatory accessibility statement. Service providers covered by the EAA must publish an accessibility statement that includes:

• A description of which accessibility requirements the service meets
• Any parts of the service that don’t meet those requirements and why
• Information about how users can provide feedback about accessibility problems
• Contact information for the relevant enforcement authority

The accessibility statement can’t simply assert compliance — it must reflect a genuine, current evaluation of the service’s accessibility status. Organizations publishing statements that aren’t grounded in actual conformance assessment expose themselves to both regulatory risk and reputational risk when the gap between statement and reality becomes visible.

This statement requirement makes formal accessibility auditing not just a quality practice but a documentation necessity. What certified WCAG compliance auditors provide and why certification matters for regulatory compliance covers the expert evaluation that grounds these statements in verifiable evidence.

How to Prepare for EAA Compliance

Step 1: Determine Your EAA Scope

Not every business operating in Europe needs to comply with every EAA requirement. Identify whether your products and services fall within the EAA’s defined categories. If you’re providing e-commerce, banking, transport, or audiovisual media services to consumers in EU member states, your web and mobile presence is covered. If you’re manufacturing or importing covered hardware products, those products’ software and interfaces are covered.

Step 2: Conduct a WCAG 2.1 Level AA Accessibility Audit

The core technical work of EAA compliance is achieving WCAG 2.1 Level AA conformance for your covered digital products and services. This requires a formal accessibility audit combining automated scanning and manual evaluation by qualified accessibility professionals — not simply running a web accessibility checker and reporting the results.

What a step-by-step professional accessibility audit involves and what it produces and what the accessibility compliance audit checklist for 2026 should cover provide useful frameworks for understanding what EAA-credible audits require.

D2i Technology’s comprehensive accessibility testing services provide the certified evaluation that EAA compliance documentation requires.

Step 3: Remediate Identified Violations

Audit findings need to be addressed — not just documented. What accessibility remediation involves and how to approach it systematically covers the remediation process. D2i Technology’s accessibility remediation services provide the technical depth to address audit findings in code, content, and documents.

Why proactive accessibility produces better outcomes than reactive remediation is particularly relevant for organizations that have accumulated accessibility debt — addressing it systematically now is less expensive than addressing it under enforcement pressure.

Step 4: Publish Your Accessibility Statement

Once you have a genuine assessment of your service’s accessibility status, publish an accessibility statement that accurately reflects it — including any known gaps, the timeline for addressing them, and the feedback mechanism required by the EAA.

Step 5: Establish Ongoing Maintenance

EAA compliance is a maintenance commitment, not a one-time achievement. New features, design updates, and platform changes can introduce new accessibility issues. Periodic re-auditing, accessibility testing integrated into your development process, and monitoring of production pages are what keep compliance current.

How accessibility testing services support ongoing compliance rather than one-time auditing makes the case for treating accessibility as a continuous quality standard.

Consequences of Non-Compliance

EAA enforcement happens through national market surveillance authorities. Member states were required to establish penalties for EAA non-compliance when transposing the directive, and those penalties vary by country — ranging from financial penalties to product or service withdrawal from the market.

Beyond regulatory penalties, non-compliant services are increasingly visible to users who experience barriers. The EAA’s feedback mechanism requirement gives users a formal channel to report accessibility problems — and organizations that receive those reports and don’t act on them are accumulating both regulatory risk and reputational evidence of knowing non-compliance.

D2i Technology and EAA Compliance

D2i Technology supports organizations across the full EAA compliance journey — WCAG 2.1 Level AA accessibility audits using both automated scanning and expert manual evaluation, accessibility remediation that addresses audit findings in code and content, and the certification-backed compliance documentation that EAA accessibility statements require.

Our accessibility services cover the full spectrum from initial assessment through remediation and ongoing maintenance, and our IAAP-certified team provides the credentialed evaluation that EAA compliance documentation needs to be credible.

Conclusion

The European Accessibility Act has moved from compliance horizon to enforcement reality. For businesses with EU operations, EU customers, or products distributed in EU markets, the June 2025 deadline means WCAG 2.1 Level AA conformance is now required — not aspirational. The organizations that addressed this proactively are now in a defensible compliance position; those that haven’t are accumulating regulatory risk with every day their digital products remain inaccessible.

D2i Technology is ready to help — with the accessibility auditing, remediation expertise, and compliance documentation that EAA compliance requires.