Who needs to comply with the European Accessibility Act?

What is the European Accessibility Act?

The European Accessibility Act (EAA) is an EU directive — Directive (EU) 2019/882 — that requires certain digital products and services to meet accessibility standards. It was transposed into national law across EU member states by June 2022, with a compliance deadline of 28 June 2025 for most obligations.

The goal is straightforward: make sure that digital products and services can be used by people with disabilities — including those with visual, auditory, motor or cognitive impairments. The EAA aligns closely with WCAG 2.1 Level AA as the technical standard for websites and apps.

Who must comply?

The EAA applies to private sector businesses that offer products or services to consumers in the EU. Unlike the earlier Web Accessibility Directive (which only covered the public sector), the EAA is broader. Here's a breakdown:

In scope — you likely need to comply if you:

• Operate an e-commerce website selling to EU customers
• Offer a banking or financial service online
• Provide transport services (ticketing, information systems)
• Run a digital media platform or audiovisual service
• Offer e-books or e-book reading software
• Provide consumer electronics with digital interfaces
• Operate a telephone service or related consumer equipment

Possible exemptions — you may be exempt if:

• Your business qualifies as a micro-enterprise (fewer than 10 employees and annual turnover under €2 million)
• Compliance would impose a disproportionate burden — but this must be assessed and documented formally
• Your product or service is out of scope by category (e.g., certain B2B-only services)

Note: the micro-enterprise exemption applies to services only, not products. And even if you're exempt today, growing past the threshold removes that exemption.

What about the public sector?

Public sector organisations — municipalities, government agencies, publicly funded institutions — have been subject to the Web Accessibility Directive (WAD) since 2018. This requires WCAG 2.1 AA compliance for websites and mobile apps, plus a published Accessibility Statement.

The EAA extends similar obligations to private businesses in scope, bringing EU digital accessibility requirements much closer to parity between the public and private sectors.

What does compliance actually require?

At a minimum, EAA-compliant digital products and services must:

• Meet WCAG 2.1 Level AA across all web content and native apps
• Provide an Accessibility Statement that's accurate, up to date and publicly accessible
• Offer a feedback mechanism for users to report accessibility issues
• Document your compliance approach and be able to provide evidence on request

What happens if you don't comply?

Enforcement is handled at national level, meaning penalties vary by country. However, the directive requires member states to apply "effective, proportionate and dissuasive" penalties, which can include:

• Fines (varying by country, potentially significant)
• Orders to withdraw non-compliant products from the EU market
• Reputational damage from public enforcement actions
• Civil claims from users or disability advocacy organisations

Not sure if you need to comply?

We built a free interactive tool that walks you through 5 simple questions and gives you an instant, plain-language indication of whether the EAA applies to your organisation. No legal jargon, no sign-up required.

What to do next

If you think the EAA applies to you (or you're not sure), here's a practical starting point:

• Run an accessibility audit — understand where you stand today against WCAG 2.1 AA
• Prioritise critical issues — focus on barriers that prevent users from completing key tasks
• Write your Accessibility Statement — this is required and must be accurate
• Build a remediation roadmap — systematic fixes, not a one-time scramble
• Embed accessibility into your process — so you stay compliant as your product evolves

Juwix can help with all of the above. Get in touch for a free intro call — we'll assess your situation and recommend the most practical next steps.