⚡ Key Facts at a Glance
Enforcement Date
June 28, 2025
Standard Referenced
EN 301 549 (maps to WCAG 2.1 AA)
Applies To
Products & services sold in the EU
Penalties
Set by each EU member state
What Is the European Accessibility Act?
The European Accessibility Act (Directive 2019/882) is an EU-wide law that sets binding accessibility requirements for products and services sold within the European Union. Unlike the ADA—which relies on court interpretation—the EAA explicitly defines which digital products and services must be accessible and references specific technical standards.
The directive was adopted in 2019 and gave member states until June 28, 2022 to transpose it into national law. Enforcement began on June 28, 2025, meaning businesses must now comply or face penalties.
For US companies, the EAA represents a major shift: if you sell to EU customers, you're subject to EU accessibility law regardless of where your company is headquartered.
What Products and Services Are Covered?
The EAA covers a specific list of products and services. If yours is on this list, compliance is mandatory.
Products
- •Computers and operating systems
- •Smartphones and tablets
- •ATMs and payment terminals
- •Ticketing and check-in machines
- •E-readers
- •Interactive self-service terminals
Services
- •E-commerce websites and apps
- •Banking and financial services
- •Telecom services
- •Audiovisual media services
- •E-books and dedicated software
- •Transport services (air, bus, rail, waterborne)
The big one for US companies: E-commerce is explicitly listed. If you operate an online store that accepts orders from EU customers, your website must meet EAA accessibility requirements. This applies to businesses of all sizes (with limited exceptions for microenterprises under 10 employees and €2M annual turnover).
EAA vs. ADA: Key Differences
If you're already familiar with ADA compliance, the EAA will feel both similar and different. Here's how they compare:
ADA (United States)
- • No explicit website accessibility text in the law
- • Courts reference WCAG 2.1 AA informally
- • Enforcement through private lawsuits
- • Damages vary by case and state
- • Applies to "places of public accommodation"
EAA (European Union)
- • Explicitly names digital products and services
- • References EN 301 549 standard (based on WCAG 2.1 AA)
- • Enforcement through national market surveillance
- • Penalties set by each member state
- • Applies to specific listed product/service categories
The good news: The technical standard is essentially the same. EN 301 549 maps closely to WCAG 2.1 Level AA. If your website already meets WCAG 2.1 AA for ADA compliance, you're most of the way there for EAA compliance too.
What Does Compliance Look Like Technically?
The EAA references EN 301 549, the European standard for digital accessibility. For web content, EN 301 549 incorporates WCAG 2.1 Level AA requirements. Here's what that means in practice:
Perceivable
- ✓All images have meaningful alternative text
- ✓Videos have captions and audio descriptions
- ✓Text meets minimum contrast ratios (4.5:1)
- ✓Content is responsive and works at 200% zoom
Operable
- ✓All functionality available via keyboard
- ✓No keyboard traps
- ✓Focus indicators are visible
- ✓Navigation is consistent and predictable
Understandable
- ✓Language of the page is declared
- ✓Forms provide clear labels and error messages
- ✓Navigation is consistent across pages
Robust
- ✓Valid HTML with proper semantic structure
- ✓Custom components have ARIA roles and states
- ✓Status messages communicated to assistive technologies
🚩 What Happens If You Don't Comply?
Unlike ADA enforcement (which relies on private lawsuits), the EAA is enforced by government market surveillance authorities in each EU member state. This means:
- •Fines — Each member state sets its own penalty structure. Some have announced significant fines for non-compliance.
- •Market restrictions — Non-compliant products and services can be ordered off the EU market entirely.
- •CE marking implications — Products requiring CE marking must demonstrate accessibility conformity.
- •Consumer complaints — EU citizens can file complaints with their national authority, triggering investigations.
For US companies, the practical risk is being reported by EU customers or flagged during market surveillance sweeps. The penalty can include being forced to withdraw your product or service from the EU market.
Which US Industries Are Most Affected?
Any US company selling covered products or services to EU customers needs to comply. These industries face the highest impact:
🛒 High Impact
E-Commerce
Online stores selling to EU customers must make their full purchase journey accessible.
🏦 High Impact
Banking & Financial Services
Online banking, payment platforms, and fintech apps serving EU users must comply.
✈️ High Impact
Travel & Transportation
Booking platforms, airline sites, and transport services are explicitly covered.
🏬 Medium Impact
Retail & Consumer Goods
Brands with EU online presence or self-service kiosks in EU stores.
See our complete industry-specific compliance guide for detailed requirements by sector.
Your EAA Compliance Action Plan
If the EAA applies to your business, here's what to do right now:
Audit Your Current State
Run a comprehensive accessibility scan to understand your current compliance level. Identify which WCAG 2.1 AA criteria you're failing.
Determine if the EAA Applies to You
Review whether your products or services fall within the EAA's scope. If you sell to EU customers online, the answer is almost certainly yes for your website. Microenterprises (under 10 employees and €2M turnover) providing services may be exempt.
Fix Critical Issues First
Focus on the most common WCAG failures: missing alt text, low contrast, unlabeled forms, and keyboard traps. These fixes cover the majority of accessibility issues.
Test Critical User Journeys
The EAA cares about whether users can actually complete tasks. Test your purchase flow, registration, customer support, and account management with keyboard-only and screen reader testing. See our full audit checklist.
Publish an Accessibility Statement
The EAA requires service providers to explain how their services meet accessibility requirements, provide contact information for accessibility issues, and link to enforcement bodies.
Monitor Continuously
Accessibility isn't a one-time project. New content, features, and updates can introduce new issues. Set up regular scans and include accessibility in your development workflow.
The Double Compliance Advantage
Here's the silver lining: meeting EAA requirements simultaneously protects you from ADA lawsuits in the US. Both frameworks map to WCAG 2.1 AA.
ADA website lawsuits continue to rise in the US, particularly in New York, California, and Florida. By investing in accessibility for EAA compliance, you're also reducing your ADA lawsuit risk.
Think of it as one investment that protects you on two fronts.
Frequently Asked Questions
Does the EAA apply to my small US business?
If you sell covered products or services to EU customers, generally yes. Microenterprises providing services (under 10 employees and €2M turnover) may qualify for an exemption, but product manufacturers of any size must comply.
Is WCAG 2.1 AA enough for EAA compliance?
For web content, yes—EN 301 549 incorporates WCAG 2.1 AA for web content. However, EN 301 549 also includes additional requirements for software, hardware, and documentation that go beyond WCAG.
What if I just block EU traffic?
This is technically possible but rarely practical. You'd lose an entire market of 450 million consumers. And if your site still accepts EU orders (even inadvertently), you could still be liable.
Is there a transition period?
The main transition period ended June 28, 2025. Some products placed on the market before that date may have an extended period until June 28, 2030, for certain service contracts entered before June 28, 2025. New products and services must comply now.
Check Your Compliance
Is Your Website Ready for the EAA?
Our AI-powered scanner checks your site against WCAG 2.1 AA—the same standard the EAA requires. Get your report in under 60 seconds.