Navigating accessibility after the EAA deadline: what comes next
Learn about how businesses are reacting to the EAA deadline, what’s happening with enforcement and checks, and where the real risks actually are.
Introduction
June 28, 2025, marked the moment when the European Accessibility Act (EAA) stopped being just “on paper” and started working in real life. Most people treat this as the EAA deadline — the point where accessibility stopped being a rule on paper and became something regulators can actually enforce.
In practice, the Act introduces a phased timeline:
- June 28, 2025 is the key enforcement trigger for new or updated products and services;
- June 28, 2027 applies to emergency services;
- June 28, 2030 covers legacy products and services already on the market (or their next update, whichever comes first);
- June 28, 2045 (or 20 years from installation) applies to long-life self-service terminals.
In the few months leading up to the EAA taking effect, many clients have been asking the same questions:
“Are regulators actually enforcing this yet?”
“Is this happening the way expected?”
“Are there already fines?”
Most companies expected either a wave of penalties or no real consequences at all.
There are a few types of companies right now. Some had everything done by June 28. Others are still working through it. And there are those who clearly didn’t make it in time and are now scrambling to catch up and figure out what to fix first. There are even companies that used to think the EAA didn’t apply to them at all — until the law came into force and they suddenly realized it very much does, and had to start taking action.
Some figures about EAA compliance
WebAIM’s 2026 Million report found accessibility errors on the vast majority of the top 1,000,000 home pages, with an average of 56.1 detected errors per page and detectable WCAG failures on 95.9% of tested home pages.
That doesn’t mean each of those sites automatically violates the EAA, but it does show that accessibility problems are widespread, measurable, and often concentrated in basic areas such as low contrast, missing alternative text, missing form labels, empty links, and empty buttons.
AbilityNet’s 2025 Attitudes to Digital Accessibility survey reveals that perceptions differ sharply across organizational levels: executives are far more likely to view their organizations as accessibility-ready (71%), compared with just 34% of senior leaders and only 21% of managers and non-managerial employees.
There is also a significant gap between individual expertise and organizational maturity. More than 70% of respondents rate their personal knowledge of digital accessibility as extremely or quite confident, but only slightly more than a quarter believe their organization as a whole has the same level of understanding.
The question is: are those fully conformant organizations smaller with fewer digital properties, or did they just make accessibility a top priority early on?
Lawyers have shared their take as well. For years before a law actually comes into force, most companies treat it as a very distant new piece of digital legislation that will become relevant at a stage that is too far away. Then, right before the deadline, there’s a sudden wave of questions like:
“So… what exactly are we supposed to do?”
Lawyers say this is classic market behavior, and not just when it comes to accessibility. In an ideal world, companies would start working on accessibility and compliance early, so they’re fully ready when the law kicks in. But in reality, many businesses first try to figure out how not to be covered by the law at all. They ask things like:
“Does this really apply to us?”, “Are there any exceptions?”, or “Is there a way around it?”
Only after a lot of digging and internal discussions do they usually realize that, one way or another, they’ll still need to comply.
People have complained about accessibility issues before, but the big problem was that it wasn’t always clear where those complaints should actually go. On top of that, there often wasn’t a clear legal hook for commercial digital products, because WCAG on its own isn’t a law — it’s a guideline. As a result, many complaints were left hanging or handled case by case.
With the EAA, things have changed. Now there’s a clear place to file complaints, including complaints from organizations representing people with disabilities. Official monitoring bodies have been set up, clear procedures are in place, and EU member states are required to accept, review, and enforce these complaints. This system is rolling out step by step — it’s not like someone just flipped a switch overnight. That’s exactly how the European Accessibility Act timeline works: enforcement, reporting, and penalties are introduced gradually, depending on the country and regulator.
How it works in practice: real compliance cases under the EAA
Before getting into specific examples around accessibility compliance in Europe, it’s important to understand one thing: the EAA requires companies to report accessibility issues, but it doesn’t set an exact deadline. Instead, each EU country can define its own rules and timelines through local regulators.
Things get even more complicated because, in some countries, several bodies are responsible for accessibility checks simultaneously. And in many places, it’s still not fully clear who is responsible for what, how different authorities will work together, or what enforcement will actually look like in practice.
If a company operates globally and is present in several — or even all — EU countries, the best way to handle non-conformance reporting is usually with the help of lawyers. They’re the ones who have the clearest view of how the laws work across different countries, and even between multiple authorities within the same country.
Regulators from the Authority for Consumers and Markets (ACM) actively send official letters to companies and let them know about checks on accessibility for ecommerce services and digital communications. Companies shouldn’t wait for user complaints or regulator inspections — they need to act on their own and clear where the problem is, what exactly is wrong, and how serious it is — whether it’s critical, serious, moderate, or minor. If the issue is resolved within certain terms, no notification is required. This approach shows that the regulator is encouraging fast fixes, not paperwork or automatic fines.
Germany’s BFSG is highly relevant to digital accessibility, especially for covered digital services such as ecommerce and banking interfaces. Compliance is primarily enforced by market surveillance authorities, with fines of up to EUR 100,000 for certain violations and up to EUR 10,000 for others.
Germany also has a distinctive private-enforcement risk: certain BFSG breaches may give rise to Abmahnungen and potential cease-and-desist claims under the UWG, but only where the specific obligation qualifies as a market conduct rule, and the infringement materially affects relevant interests. Missing or incomplete accessibility information may increase regulatory and private-enforcement exposure, although BFSG-related Abmahnung practice is still developing.
France’s digital accessibility framework combines Article 47/RGAA obligations for online public communication services with EAA-related accessibility rules transposed into the Consumer Code for covered products and services. Covered services include ecommerce, banking, transport-related services, and certain audiovisual or digital services. Enforcement is fragmented: Arcom oversees Article 47 obligations for public bodies, public-service delegates, and certain large private entities, while DGCCRF is one of the competent authorities for EAA-related consumer-law compliance.
France has also seen early private enforcement activity. In July 2025, associations for visually impaired and blind people filed public complaints against some major grocery retailers because their online services — like ecommerce sites and online stores — didn’t meet EAA standards and were basically inaccessible. In the end, this turned into a brand reputation issue.
Spain’s accessibility framework is relevant to digital accessibility, including covered digital services such as ecommerce, banking, transport-related services, and consumer-facing digital interfaces. Under Spain’s disability-rights sanctions framework, as applied to accessibility obligations, infringements may be classified as minor, serious, or very serious, with fines ranging from EUR 301 to EUR 30,000 for minor infringements, up to EUR 90,000 for serious infringements, and up to EUR 1,000,000 for very serious infringements.
Very serious accessibility failures may therefore carry substantial financial exposure. Spanish law also provides accessory sanctions in some cases, such as restrictions on access to public grants or subsidies, but this should not be described as a general operational ban.
Italy’s accessibility framework is highly relevant to digital accessibility, particularly for websites, mobile apps, ecommerce, and other covered digital services under Legge Stanca and the Italian transposition of the European Accessibility Act. AgID is the key authority for website and mobile app accessibility enforcement, although other market-surveillance or sectoral authorities may be relevant for non-digital products and some EAA-covered services.
For private-sector website and app obligations under Legge Stanca, the relevant threshold is generally tied to providers offering services to the public through websites or mobile apps with average turnover above EUR 500 million over the previous three years, not a generic EUR 50 million or 250-employee threshold. If AgID finds non-compliance, it may set a remediation deadline; failure to comply can lead to an administrative fine of up to 5% of turnover.
Is accessibility only a B2C concern?
It’s not that simple. In practice, it makes sense to focus on accessibility from the B2B level. Even if a company is purely B2B, real people still end up using its product, so it’s part of the chain that delivers the product to the end user. Because of that, B2C companies are increasingly making accessibility a condition for working with service providers. They don’t want to pay extra for adaptations later — they want the software they buy to be accessible from day one.
That’s why accessibility needs to be part of the requirements for B2B products too. The whole supply chain affects compliance. Let me explain how this works in detail.
According to the survey by Deque, 55% of companies say their websites are the least ready for EAA requirements. The same 55% point to mobile apps. Then it’s customer support at 26%, packaging at 6%, and support for executive leadership teams at just 5%. What’s interesting is that websites come out on top as the biggest problem area.
Websites (55%) ranked as the least ready area compared to mobile apps (45%). This likely comes down to numbers — most companies have way more websites than apps. Getting one or two mobile apps ready is much easier than fixing hundreds of websites.
Here’s a key gap spotted: mobile apps often lack accessibility statements. For example, both UK guidance and the Dutch ACM say you need them on apps, not just websites. They give users an easy way to report problems — and that matters for compliance.
When it comes to websites, the problem isn’t just how many of them there are. A big issue is the content itself — especially third-party widgets, plugins, and external services. That kind of content is hard to control, and if something breaks, it’s often not easy to fix quickly. But if a company has to report to regulators, it’s still responsible for that third-party code, because it appears on its own sites and apps. That’s why accessibility isn’t just a developer problem anymore — it also becomes a responsibility for procurement and compliance teams.
There’s no special exception for third-party content in the EAA. But if, for example, the company embeds a video from an external platform and it can’t add captions, change the player, or control how it works, this company can explain to the regulator that it’s not directly responsible for the accessibility of that specific element. That said, this is not an automatic get-out-of-jail-free card.
The regulator will look at whether the company really had no control or whether it simply chose a convenient vendor that could have been replaced. Even if a product is built by a contractor, the legal responsibility still sits with the company that offers it. That’s why accessibility needs to be built into contracts and actively managed through reporting, checks, and audits.
Who in the team is responsible for web accessibility?
Web accessibility isn’t a single-team responsibility. Within the EAA, it’s best viewed as a system of accountability: who recognizes risks, who provides resources to address them, who integrates accessibility within daily processes, and who maintains evidence that the company is systematically managing accessibility.
The first signal often comes not from developers, but from users. Customer support fulfills a key role: it’s where people turn when they can’t place an order, read a page, fill out a form, open a PDF, understand a video, or navigate using assistive technology. Such a request shouldn’t be left as mere feedback. It could indicate an accessibility violation and become a legal or regulatory signal.
At this level, the team’s job is to properly document the issue, escalate it, and guarantee it doesn’t get lost. A key area of focus here is maintaining a separate complaint register for accessibility complaints: details of what happened, which user path is affected, how critical the issue is, who is assigned as the owner, what remediation SLA is set, and when the issue was resolved.
How can Attico help businesses comply with EAA?
Even after the EAA comes into force, some companies may still think it’s not a big deal and decide to do nothing for now. So, how do you make them see that accessibility actually needs urgent attention?
There’s a way that really works: show them real risks and real timelines, not just say “because the law says so”.
The first step is an audit and a risk assessment. It’s about answering simple questions like:
“How compliant are you right now?” and “What does European Accessibility Act compliance actually look like for your products today?”
Next, it’s needed to look at the pace of fixes:
“How fast are you actually shipping changes right now?” and “How long would it realistically take you to fix everything?”
Some large companies are already saying it could take them up to 10 years to get their products fully accessible. And that means 10 years of ongoing risk — legal, financial, and reputational. Even on a small website, let’s say you have a 100-page website with a hundred defects. If they are only fixing three defects per sprint every two weeks, how many weeks is that?
Attico specialists help businesses comply with WCAG 2.1 AA and EAA by finding accessibility issues, fixing them, testing solutions, and keeping everything compliant over time. Our expert accessibility consulting ensures your digital products are optimized for all users and legally compliant. We give you clear, practical recommendations — no jargon, no unnecessary theory — so your team knows exactly what to fix and where to start.
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