What is the European Accessibility Act (EAA)?

The European Accessibility Act (EAA) is EU legislation requiring businesses to make digital products and services accessible to people with disabilities. It mandates WCAG 2.2 Level AA compliance and has applied to private sector websites since June 28, 2025.

Who must comply with the European Accessibility Act?

The EAA applies to businesses selling products or services in the EU: e-commerce sites, banking and financial services, transport ticketing, streaming platforms, e-books, and telecom services. Microenterprises (fewer than 10 employees and under €2M turnover) are exempt.

What are the penalties for EAA non-compliance?

EAA penalties vary by EU member state but typically range from €5,000 to €300,000 depending on the severity and jurisdiction. Non-compliant businesses may face fines, mandatory corrective orders, and in severe cases, prohibition from selling in the EU market.

What accessibility standard does the EAA require?

The EAA requires compliance with EN 301 549, which references WCAG 2.1 Level AA as the baseline. In practice, most organisations target WCAG 2.2 Level AA, which is the current standard and covers all WCAG 2.1 requirements.

How do I check if my website complies with the EAA?

Use CompliScope's free accessibility scanner at compliscope.polsia.app. Paste your URL to get an automated audit against WCAG 2.2, EN 301 549, and RGAA criteria with developer-ready fix code for every issue found. No signup required.

Compliance Guide

European Accessibility Act:
What You Need to Know in 2025

The EAA enforcement deadline has passed. If your website sells products or services to EU consumers, you're legally required to be accessible now. Here's what applies to you, what the standards require, and how to check your site today.

✓ Enforcement started June 28, 2025 Updated April 2026 8 min read

1. What is the European Accessibility Act?

The European Accessibility Act (EAA), officially Directive 2019/882/EU, is EU legislation that mandates digital accessibility for a wide range of products and services sold to European consumers. It was adopted in April 2019 and entered full enforcement on June 28, 2025.

Unlike earlier EU accessibility laws that only applied to public sector websites, the EAA specifically targets the private sector — e-commerce stores, banking apps, transport booking systems, digital media services, and more. If you sell to EU customers online, you are likely in scope.

Key fact: The EAA transposes into national law in all 27 EU member states. Each state enforces it through its own regulatory authority and penalty structure. France, Germany, and the Netherlands have all activated their enforcement frameworks as of mid-2025.

Scope of the EAA

The EAA covers digital products and services in these categories:

E-commerce websites and apps (selling goods or services to EU consumers)
Online banking and financial services
Passenger transport booking services (airlines, rail, bus, urban mobility)
Electronic communications services (VoIP, messaging apps)
Digital media services (streaming, podcast platforms)
E-books and dedicated e-reader software
Computers, operating systems, smartphones and their related services
ATMs, ticketing machines, and self-service terminals

There are limited exemptions for micro-enterprises (fewer than 10 employees and annual turnover/balance sheet under €2M) — but only for service providers, not product manufacturers.

2. Who must comply?

If your business sells products or services to EU consumers through a digital channel, the EAA likely applies to you — regardless of where your company is headquartered. A US-based e-commerce store selling to France is in scope. A UK SaaS company with EU customers is in scope.

Businesses clearly in scope

E-commerce: Any online store selling to EU consumers must ensure the shopping journey (product listings, checkout, order confirmation, support) is accessible.
Financial services: Banks, payment processors, investment platforms, insurance portals — all digital touchpoints must meet accessibility requirements.
Travel and transport: Airline, rail, and bus booking sites; car rental; ride-sharing apps; urban transport apps.
Streaming and media: Video-on-demand, music platforms, podcast services with subscriptions sold to EU users.
Telecom: Internet service providers, phone carriers, VoIP apps.

Exemptions

Micro-enterprises providing services (not products) with fewer than 10 employees and under €2M turnover may be exempt — but must still provide accessibility on request.
Content published before June 28, 2025 that is not essential to a core service may have a grace period (varies by member state).
Pre-existing contracts signed before June 28, 2025 have a five-year grace period (until 2030) for full compliance under some member state implementations.

⚠️ Don't assume you're exempt. The micro-enterprise exemption is narrow. If you're in e-commerce with even modest EU sales, you should treat the EAA as applying to you. The cost of a compliance audit is far lower than the cost of a regulatory investigation.

3. What are the penalties?

Penalties are set at member state level. The Directive requires them to be "effective, proportionate and dissuasive." In practice:

€300K Maximum fine — France (per violation)

€100K Maximum fine — Germany (administrative)

Market ban Products can be withdrawn from EU sale

Named Public naming of non-compliant companies

Beyond fines, enforcement agencies can order withdrawal from the market — meaning EU consumers would be blocked from purchasing your product until compliance is achieved. For a B2C business with meaningful EU revenue, this is an existential risk.

How enforcement works

Each EU member state designates a national market surveillance authority. Enforcement is complaint-driven and audit-driven. Disability advocacy organizations have started filing complaints in France and Germany as of late 2025. Common triggers:

Complaint filed by a user or disability advocacy group
Proactive market surveillance audit by the national authority
Competitor complaint (increasingly used in regulated markets)

4. What standards apply?

The EAA sets the legal requirement. The technical standards tell you how to meet it. For web and mobile, the compliance stack is:

Standard	What it covers	Status
WCAG 2.2 Level AA	Web content: images, forms, navigation, color contrast, keyboard access, focus management — 50 success criteria at Level AA.	Required
EN 301 549 v3.2.1	EU harmonised standard. Incorporates WCAG 2.2 plus additional requirements for mobile apps, software, documents, and hardware. Section 9 covers web.	EU Harmonised
RGAA 4.1	France's national framework. 106 criteria derived from WCAG with strict testing methodology. Required under French law for public-sector sites; de facto standard for French private-sector EAA compliance.	France Required

What "Level AA" means in practice

WCAG 2.2 AA encompasses 4 core principles — Perceivable, Operable, Understandable, Robust (POUR). The most commonly failed criteria include:

1.1.1 Non-text content — every meaningful image needs an alt attribute
1.4.3 Contrast (Minimum) — text must have at least 4.5:1 contrast ratio
2.1.1 Keyboard accessible — all functionality must be operable by keyboard
2.4.1 Bypass blocks — skip navigation link required
3.3.2 Labels or instructions — form inputs must have accessible labels
4.1.2 Name, Role, Value — interactive elements must have correct ARIA roles

CompliScope checks against all three standards — WCAG 2.2, EN 301 549, and RGAA 4.1 — in a single scan. Every issue is cross-mapped to the relevant article in each framework, so you know exactly what to cite in a compliance report.

5. How to check your site

There are three approaches to EAA compliance checking, with very different cost and effort profiles:

Option 1: Automated scan (fast, free, good starting point)

Automated tools catch 30–40% of WCAG issues — typically the clear-cut violations like missing alt text, contrast failures, and missing form labels. Good for a rapid baseline.

CompliScope scans any URL in under 30 seconds, free, no account required. You get a scored audit against WCAG 2.2, EN 301 549, and RGAA, with exact element locations and developer-ready fix code.

Option 2: Manual audit

A human tester using assistive technology (NVDA, JAWS, VoiceOver, TalkBack) catches issues automated tools miss — focus order, screen reader announcements, cognitive complexity. Required for full WCAG 2.2 conformance.

Option 3: Third-party audit + VPAT

A Voluntary Product Accessibility Template (VPAT) or Accessibility Conformance Report (ACR) documents your compliance status against EN 301 549. Required for enterprise procurement in many EU contexts. CompliScope Enterprise includes VPAT generation.

⚠️ Overlay widgets don't count. Automated accessibility overlays (those one-line JavaScript scripts that add an accessibility button to your site) do not bring you into EAA compliance. Regulators have specifically rejected them. You need to fix the underlying code.

Check your site for free — right now

Paste your URL. Get a full EAA compliance audit against WCAG 2.2, EN 301 549, and RGAA in under 30 seconds. No signup. No credit card.

Run Free EAA Compliance Scan →

Free scan covers all Level AA criteria. No account needed.

6. What CompliScope does

CompliScope is a web accessibility audit tool built specifically for the European compliance landscape. It's the only scanner that covers the full regulatory stack in one report.

Full WCAG 2.2 Level A and AA audit — 87 success criteria
EN 301 549 cross-mapping (Section 9 for web content)
RGAA 4.1 cross-mapping — required for French compliance
Issue severity scoring (0–100 scale)
Exact element locations with XPath and CSS selectors
Developer-ready fix code for every issue found
Multi-page crawling (up to 50 pages per audit)
Shared element detection across pages
Downloadable PDF and JSON reports
VPAT / Accessibility Conformance Report generation (Enterprise)

Free vs Pro

The free tier gives you one scan per day with issue descriptions and severity scores — enough to understand your baseline. Pro at $39/month unlocks detailed fix guidance with code examples, unlimited scans, PDF and JSON export, and multi-page crawling. See full pricing →

For teams with formal compliance mandates, audit trails, or enterprise procurement requirements, contact us for Enterprise pricing.