Learn about how businesses are reacting to the EAA deadline, what’s happening with enforcement and checks, and where the real risks actually are.
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.
Over the past few months, many clients have been asking the same questions:
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.
In a recent survey, around 9% is saying it is less than 10%, 4% is saying around 10%, around 15% is saying they are around the 25% compliant mark, 32% saying half of their organization is conformant or they are halfway there, 35% around a little more than 1/3 saying they are 75% there, and only 5% of respondents are saying they are 100% there, that they are fully conformant with the directive.
About one-third of the responses have made significant progress, reaching around 75% conformance. But only 5% said they’ve achieved full conformance. 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.
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.
In the Netherlands, 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.
In other jurisdictions, for instance in Germany or Poland, there are sort of more generic forms that may be used to provide information to the authorities, but nothing as detailed as the Netherlands has. Although in Germany, the authorities also have quite clear guidance from the authorities on how to operate the accessibility act and how to meet the requirements.
The EAA can put pressure on companies through public opinion, not just fines. So, in France, 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.
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.
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 same 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.
No, accessibility isn’t just a developer or accessibility expert problem. Customer support plays a huge role here. They’re usually the first ones users contact when something doesn’t work, and they’re the first to hear that something is inaccessible. At that point, it’s no longer just “feedback” — it can turn into a legal signal.
Finance also needs to be involved because accessibility isn’t a one-off cost — it’s ongoing. The finance team plans the budget, decides what spending is necessary, and gives the green light to invest in it. This could be for accessibility audits, external experts, extra dev and QA hours, or training the teams.
To meet EAA requirements, companies need accessibility experts, designers, QA engineers, and other people who actually understand accessibility. It’s HR’s job to make sure these specialists are hired and to take care of training — courses, webinars, onboarding sessions. On top of that, HR helps define responsibilities in job descriptions and supports an accessibility-first culture inside the company.
Operations is the team that makes sure everything inside the company runs smoothly. They coordinate different specialists, make sure accessibility checks are part of new website pages, app updates, and even emails, keep an eye on deadlines, track issues, and ensure fixes happen in a clear, repeatable way, not randomly.
Marketing creates a lot of digital content — from text and images to promo pages and landing pages. That’s why the marketing team also needs to think about accessibility, so everyone, including people with physical or cognitive disabilities, can actually use and understand the content. Even if a website is technically accessible, the content itself can still break EAA rules — for example, videos without captions or images without alt text. Making sure this doesn’t happen is part of marketing’s responsibility.
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.
