Accessibility law
The European Accessibility Act, Explained
It’s live, it has no grace period, and it reaches American companies selling into the EU. Here’s what the EAA requires and how to get compliant.
The European Accessibility Act (EAA, Directive 2019/882) is the most consequential accessibility law most businesses have never read. It took effect on 28 June 2025 — with no grace period — and it reaches well beyond the EU’s borders. If you sell digital products or services to consumers in the EU, it almost certainly applies to you, whether or not your company is European.
The deadline already passed
Unlike a future regulation you can plan for, the EAA is live now. Products and services placed on the EU market on or after 28 June 2025 must comply. There is no transition window for new offerings.
What the EAA is
The EAA harmonizes accessibility requirements across all 27 EU member states so that products and services work for people with disabilities and older users. Before it, accessibility rules varied country by country; now there’s one baseline. Each member state has transposed it into national law with its own enforcement body and penalties.
Who it applies to — including US companies
The EAA covers a defined set of products and services, including:
- E-commerce — any website or app selling goods or services to EU consumers.
- Banking and financial services for consumers.
- E-books and e-readers.
- Transport services (ticketing, real-time info).
- Electronic communications and the hardware/software that accesses them.
Geography doesn’t save you
The EAA applies based on market, not headquarters. A US-based online store that ships to or sells to consumers in the EU falls within scope. “We’re not a European company” is not a defense.
There is a genuine exemption for microenterprises providing services (fewer than 10 staff and ≤ €2M turnover), but it does not extend to microenterprises that manufacture or sell products, and it’s narrower than most people hope.
The technical standard: EN 301 549 → WCAG
The EAA itself states functional outcomes; the technical detail lives in the harmonized European standard EN 301 549, which for web content points straight at WCAG 2.1 Level AA. So the practical target is the same one you’d aim for under the ADA: WCAG AA. Our WCAG 2.2 checklist covers it (and then some).
You’re also expected to publish an accessibility statement describing how your service meets the requirements and how users can report problems.
Penalties and enforcement
Penalties are set by each member state, and they’re not symbolic. They commonly reach up to €100,000 per infringement in some jurisdictions, and several states tie fines to a percentage of turnover. Beyond fines, regulators can order a non-compliant service withdrawn from the market — a far more expensive outcome than any fine for a business that depends on EU sales.
The deadline has passed — now what?
If you’re reading this in 2026 and aren’t compliant, you’re already exposed, but enforcement is complaint- and audit-driven rather than instantaneous. The right move is to demonstrate active, documented remediation now: a regulator that sees an ongoing, dated effort treats you very differently from one that finds nothing.
Overlays do not satisfy the EAA
EU enforcers explicitly reject accessibility overlay widgets as a compliance method — they require accessible source code. If a vendor told you a widget makes you “EAA compliant,” read why overlays fail.
A practical compliance path
- Confirm scope. Do you sell to EU consumers? Which of your products/services are covered?
- Audit against WCAG 2.1 AA. Automated scan first, then manual testing.
- Remediate in source code, prioritizing purchase and account flows.
- Publish an accessibility statement with a feedback channel.
- Monitor continuously and keep dated records — your evidence of conformity.