EAA Accessibility Compliance: What Businesses Should Know?

Understanding the European Accessibility Act (EAA)

The European Accessibility Act (EAA), adopted in 2019, sets legally binding accessibility standards for digital and physical products sold or used across the European Union. It targets industries with high cross-border impact, including e-commerce, banking, telecom, and transportation. The goal is to reduce accessibility barriers and ensure equal participation.

The EAA applies to digital services and products such as:

• Websites and mobile apps of private companies in certain sectors
• E-books and e-readers
• ATMs, ticketing machines, and payment terminals
• Online banking and e-commerce platforms

Note: Public sector websites are not covered under EAA because they are already regulated by the EU Web Accessibility Directive.

What Makes EAA Compliance Different from Other Accessibility Laws

Most global accessibility laws use WCAG (Web Content Accessibility Guidelines) as their technical foundation. EAA does the same, but with some key differences:

1. Private Sector Scope: Unlike the EU Web Accessibility Directive, which focuses on public bodies, EAA places legal obligations on private businesses.
2. Cross-Border Enforcement: The EAA is meant to harmonize accessibility requirements across the EU. That means a company offering digital products in more than one EU country must now meet one standard rather than adapt to each nation’s local rules.
3. Product + Service: EAA not only covers websites or apps but also physical hardware and the associated support services (like ATMs and kiosks).
4. Covers Support Services: If a user needs help using your service, every support channel must be accessible. This includes live chat tools that can be navigated with a keyboard, phone systems with voice prompts that work for screen readers, and written instructions that follow proper structure and language clarity.

Deadline for Complying With EAA Rules

EAA enforcement follows a phased rollout, and understanding these timelines is critical for compliance planning.

• The EAA was adopted in June 2019.
• EU Member States were required to transpose it into national law by June 28, 2022.
• The enforcement deadline for most digital products and services is June 28, 2025.

A five-year grace period ending June 28, 2030, applies mainly to physical products rather than digital services. This includes hardware such as ATMs, ticket machines, and e-readers placed on the market before June 28, 2025.

Why EAA Accessibility Compliance Matters?

Failing to meet the EAA’s requirements has direct legal, financial, and operational consequences for businesses offering digital products or services in the EU. 

• Fines and Enforcement: Each EU country enforces EAA rules, and the penalties vary across regions. For example, Germany has issued fines between €40,000 and €50,000 for digital accessibility violations, whereas in France, fines can reach up to €75,000 for non-compliance. 
• Loss of Market Access: Without EAA compliance, you may be legally barred from launching or continuing to offer services in EU countries. This directly affects revenue and customer acquisition.
• Contract Risk: Public-sector buyers and enterprise clients in the EU increasingly require proof of accessibility in procurement processes. Failure to demonstrate EAA alignment can disqualify you from bids or lead to terminated contracts.
• Brand and Legal Exposure: Non-compliance can result in legal complaints filed by users or advocacy groups. These often become public, leading to reputational damage and loss of user trust.
• Increased Operational Costs: When accessibility is not built into the product, support teams see more tickets, dev teams spend more time retrofitting fixes, and testing cycles grow longer. Compliance delays often lead to higher long-term costs.

How to Audit Your Website or App for Accessibility Gaps

A complete audit should assess how your site or app performs against WCAG 2.1 Level AA, both functionally and technically.

1. Use Automated Scanning Tools as a Starting Point

Automated tools quickly detect common WCAG failures, such as missing labels, low color contrast, incorrect heading structure, or empty links. 

Tools like BrowserStack Accessibility Testing allow teams to run scans across 3,500+ real devices and browser combinations. Unlike browser extensions or local tools, it flags accessibility issues across environments, helping you catch device- or browser-specific inconsistencies.

2. Keyboard-Only Navigation Audit

Turn off your mouse and navigate through the entire interface using only the keyboard. Check that menus, modals, skip links, dropdowns, and dynamic elements are fully accessible and follow a logical tab order.

3. Screen Reader Compatibility Review: 

Use screen readers like NVDA, JAWS, and VoiceOver to test your content across different platforms. Check that the reading order makes sense, elements are described clearly, labels are correctly linked, and key actions such as form submissions or menu navigation are properly announced.

4. Semantic HTML and Role Usage Validation

Check whether the site uses proper semantic elements (like buttons, links, headings) and avoids divs or spans where native elements are more appropriate. Misusing ARIA roles or adding unnecessary roles can introduce new accessibility barriers instead of improving the experience.

5. Dynamic Content and Focus Handling

When a modal opens, new content is added, or the page changes, make sure focus moves to the right element and screen readers are notified. Use ARIA attributes such as aria-live, role="alert", or programmatic focus to ensure these updates are correctly announced.

6. Color and Contrast Review

Verify contrast ratios across real pages using implemented styles. Review how text and UI elements appear in high contrast mode (if supported) and dark mode to ensure consistent readability.

7. PDFs and Embedded Documents

Ensure downloadable content, such as PDFs, is tagged with a clear reading order, proper headings, and alt text. Accessibility checks must include these files, as they are covered under EAA requirements.

Common Challenges in Achieving EAA Accessibility Compliance

Even with clear WCAG guidelines, practical implementation often brings up specific hurdles. Common issues include: 

• Lack of internal expertise: Accessibility knowledge is often limited across product, design, and engineering teams.
• Inconsistent component behavior: Custom UI components may behave differently in different parts of the app, affecting keyboard and screen reader navigation.
• Third-party integrations: Tools like chatbots, analytics overlays, or payment systems may introduce accessibility gaps that are harder to control.
• Legacy codebases: Older platforms can contain accessibility issues that are deeply embedded and time-consuming to fix.

How to Meet EAA Accessibility Compliance

Compliance with the EAA requires a process-wide shift in how digital products are designed, built, tested, and maintained. A sustainable approach needs clear standards, defined responsibilities, and checkpoints throughout the product lifecycle.

• Adopt WCAG 2.1 Level AA as a non-negotiable standard: This is the benchmark referenced by the EAA. Every new feature, screen, and user flow must be evaluated against it.
• Establish accessibility ownership across teams: Accessibility is not the responsibility of one person or team. Product managers must include it in feature planning, designers must align layouts with usability principles, developers must write semantic and accessible code, and testers should validate using automated and manual tests.
• Review your component library: Start with the UI components you reuse across the application, such as modals, dropdowns, buttons, and input fields. Check how they handle focus, keyboard interaction, announcements to screen readers, and responsiveness. 
• Build accessibility into QA and CI/CD: Add automated accessibility checks as part of your test runs, but manual testing with real assistive technologies, such as screen readers, high contrast settings, and magnifiers, must also be scheduled and documented. 
• Define non-visual requirements in design specs: Design tickets should include contrast ratios, keyboard tab order, and error message behavior. Figma files should also contain hidden text or alt text annotations where needed.
• Document accessibility acceptance criteria: Add clear, testable accessibility checks directly to user stories or feature tickets. These should cover keyboard operability, contrast ratios, focus handling, and screen reader compatibility. To ensure consistency, include these checks in your backlog templates and review them as part of your standard QA process.

How to Handle EAA Accessibility Issues in Third-Party Tools

Many digital products rely on third-party scripts, SDKs, or services for things like payment, analytics, customer support, or personalization. These can introduce accessibility issues beyond your control.

Here's how to address them:

• Review Before Integrating: Audit the accessibility of third-party widgets before adding them. If they fail critical WCAG checks, look for alternatives.
• Audit the tool thoroughly: Use both automated and manual testing to identify WCAG violations within the third-party component.
• Document everything clearly: Log affected pages, specific failures (e.g., missing labels, focus traps), impacted users, and any blocking severity for prioritization.
• Isolate the component structurally: Use ARIA landmarks or semantic HTML to separate the inaccessible tool from surrounding accessible content.
• Control focus behavior: Use wrappers or focus guards to prevent keyboard traps, broken tab order, or unexpected screen reader announcements.
• Apply local patches where possible: If the component allows limited styling or DOM manipulation, inject accessibility fixes (e.g., labels, roles, alt text) using JavaScript or CSS.
• Communicate with the vendor: File detailed accessibility bug reports referencing WCAG violations and cite your EAA obligations to increase urgency.
• Request accessibility documentation: Ask for a VPAT or conformance statement to verify the vendor’s accessibility commitments and roadmaps.

Conclusion

The European Accessibility Act sets legal accessibility requirements for digital products and services offered in the EU. It follows the WCAG 2.1 Level AA standard and applies to websites, apps, platforms, and connected hardware. If you haven’t optimized for accessibility yet, you are already at legal and operational risk. The compliance deadline (June 28, 2025) has passed, and enforcement is now in effect.