What does the EAA 2025 actually mean for businesses?

The EAA 2025 (European Accessibility Act) is a European Union law that came into force on June 28, 2025. Companies offering products and services in the EU are required to comply with new accessibility requirements, ensuring their digital products and services are accessible to people with disabilities.

What is the EAA 2025 based on?

1

Directive (EU) 2019/882

The directive requires EU businesses to adapt accessibility requirements in services and digital products.

2

EN 301 549

Accessibility standard required by the directive.

3

WCAG 2.1 AA

Mandatory minimum accessibility requirements for websites and digital products.

All digital products, including websites and mobile applications, must comply with the WCAG 2.1 AA accessibility standards.

Some examples of requirements:

Content should be easy to read and understand

Sufficient text contrast (at least 4.5:1 for normal text)
Resizable text without breaking the layout
Clear language and no unnecessary jargon

The website must be usable without a mouse

Keyboard navigation for all interactive elements
Clear focus indicators
Consistent navigation

Everyone should be able to access information

Video captions for deaf and hard-of-hearing users
Alt text for images
Avoiding content that triggers seizures

Users should be able to complete forms easily

Error messages must be clear and helpful
Labels for all form fields
No time limits or extendable time for completing tasks

What does it mean in practice?

Websites & apps must meet WCAG 2.1 AA standards.

E-commerce sites must ensure an accessible checkout process.

Digital content must be accessible.

Companies must conduct regular check-ups and provide reports

EAA enforcement may come faster than you think! GDPR went into effect in May 2018, and major fines were issued within 8 months. EAA is expected to follow a similar enforcement timeline.

Who does this affect?

Companies with 10+ employees and a turnover of €2M+.

Companies based in the EU, as well as those serving European customers.

Companies that serve EU public institutions or government bodies.

Companies in consumer sectors like e-commerce, finance, media, and transport.

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What’s at risk:

Fines

Fines up to €100,000 per violation

Sales Ban

Ban on selling digital solutions in EU countries

Trust Loss

Loss of customer trust and brand credibility

Audit Risks

Risks during audits, tenders, and collaborations with government bodies

FAQ

How likely is it to receive a fine after June 28?

As with GDPR, the enforcement of fines under the EAA 2025 will not start immediately. Companies are expected to receive warnings and corrective orders first.

However, if these orders are ignored or repeated complaints are filed, fines will become inevitable.
Example from GDPR: GDPR came into effect on May 25, 2018. The first significant fine was imposed eight months later, in October 2018, when the Barreiro Montijo Hospital (CHBM) in Portugal was fined €400,000 for non-compliance.

Who will oversee compliance, and how?

Compliance with EAA 2025 will be monitored by national regulatory authorities. Each EU country has its own supervisory body:

Austria – DSB
France – CNIL
Germany – Various authorities depending on the region
Spain – AEPD
Italy – Garante per la Protezione dei Dati Personali.

These authorities can:

Conduct accessibility audits of digital services
Investigate user complaints
Issue orders to remedy violations
Impose fines for non-compliance

Who is exempt from liability?

Some businesses may be exempt from EAA requirements:

Small businesses (fewer than 10 employees and annual revenue under €2M) are exempt from most requirements
Documented "disproportionate burden": If a company proves that implementing accessibility measures requires excessive costs or threatens business viability, it may qualify for an exemption. This requires a cost analysis and formal justification to authorities
Specific exemptions: If a product is technically impossible to adapt (e.g., legacy systems or devices with limited functionality)

Which user limitation groups are covered by accessibility requirements?

EAA 2025 ensures equal access for individuals with various disabilities:

Visual impairments – Low vision, blindness, color blindness
Hearing impairments – Deaf and hard-of-hearing users
Motor impairments – Users with limited hand mobility
Cognitive disabilities – Dyslexia, autism, attention disorders
Temporary limitations – Injuries, noisy environments, poor internet connectivity

The law mandates compliance with WCAG 2.1 AA, but WCAG 2.2 is already available

Currently, EAA 2025 requires compliance with WCAG 2.1 AA, but WCAG 2.2 has already been published, introducing additional improvements, particularly for users with cognitive and motor impairments.

It is highly likely that future revisions of the law or national regulations in some EU countries will require a transition to WCAG 2.2. This has already happened in the UK, where government services must comply with WCAG 2.2 AA.

What you should do now:

Ensure your website meets the European Accessibility Act requirements! Order an accessibility audit and receive a step-by-step improvement plan tailored to your site.

7 business days | € 990

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