
The June 2025 deadline for the European Accessibility Act is fast approaching. Find out what you need to know and how it may affect the websites you build, even if you’re outside of the E.U.
Music: https://www.bensound.com
Show Notes
- European Accessibility Act
- EU Directive 2016/2102
- EN 301 549
- Rian Rietveld’s WordCamp Europe talk
- Spanish airline Vueling
- Ireland’s accessibility law
- Episode 182: Compliance versus Conformance
- Lainey Feingold
- Accessibility training
Hi, and thanks for tuning in. I’m Colleen Gratzer, and in this episode of Design Domination, I’m digging into the European Accessibility Act, which must be implemented before June 28, 2025. If you’re outside the E.U. and think this doesn’t apply to you, then listen up, because it’s not just for companies inside the E.U.!
What is the European Accessibility Act (EAA)?
In case you haven’t heard of the European Accessibility Act, let’s go over the basics.
The European Accessibility Act (EAA), also referred to as Directive (EU) 2019/882, is a directive of the European Union that became law in 2019.
Its goal is to improve the accessibility of products and services for people with disabilities and people with functional limitations, such as elderly people and pregnant women. They even mention people traveling with luggage.
This is also expected to help economies, cross-border trade and mobility.
The directive aims to do this by streamlining accessibility standards across all of the E.U.’s 27 member states.
What does the European Accessibility Act apply to?
The European Accessibility Act applies to certain products and services, such as:
- computers and operating systems;
- ATMs and payment terminals;
- ticketing and check-in machines;
- smartphones;
- equipment for digital television and phone services;
- websites and mobile services, including e-books and e-readers;
- access to audio-visual media services;
- services related to air, bus, rail and water passenger transport;
- banking services; and
- e-commerce.
It does not apply to certain digital content, such as:
- prerecorded time-based media published before June 28, 2025;
- office file formats published before June 28, 2025 (I am not entirely sure what “office file formats” refers to);
- online maps and mapping services, if essential information is provided in an accessible digital manner for maps intended for navigational use;
- third-party content that is not funded, developed by or under the control of the economic operator concerned;
- content of websites and mobile apps that qualify as archives (meaning they only include content that is not updated or edited after June 28, 2025).
Who does the European Accessibility Act apply to?
Now let’s talk about who the EAA applies to.
But first off, don’t confuse the EAA with EU Directive 2016/2102, which relates to accessibility requirements for websites and mobile apps for the public sector, such as for the government.
The EAA applies to private sector businesses inside and outside of the E.U. that provide services or sell products to consumers within the E.U.
European Accessibility Act Exemptions
There are two circumstances for exemptions under the EAA—companies with:
- 10 or fewer employees and
- an annual balance sheet of less than €2 million.
Some businesses meeting certain criteria may be able to show a disproportionate burden and be exempted as well.
When does the European Accessibility Act go into effect?
E.U. member states are required to adopt and publish certain laws, regulations and administrative provisions for compliance by June 28, 2025. They must also fully implement the EAA requirements as well.
What accessibility standard do you need to meet for the European Accessibility Act?
All right, so we know the what and who and when. But what about the accessibility standard (WCAG) you need to meet for the EAA?
Well, the EAA itself does not state any specific accessibility standard. However, the European standard EN 301 549, which applies to websites, mobile apps and electronic documents (PDFs, Word, etc.), does. It calls for WCAG 2.1 AA but is being updated to the current standard released in October 2023, which is 2.2.
How will the European Accessibility Act be enforced?
So how will the EAA be enforced?
The European Commission, the executive branch of the E.U., will work with disability organizations and other groups to make sure that businesses are adhering to the EAA. They will perform regular checks.
Not only that, but E.U. member states must submit reports about the status of their compliance (how they meet the accessibility requirements) by June 28, 2030, and every five years after that.
Consumers can also file complaints.
What happens if a company doesn’t comply with the European Accessibility Act?
So what happens if a company doesn’t comply with the European Accessibility Act?
It will be up to each member state to determine any specific fines and penalties for non-compliance. That makes things a bit more complicated.
The act states:
2. The penalties provided for shall be effective, proportionate and dissuasive. Those penalties shall also be accompanied by effective remedial action in case of non-compliance of the economic operator.
In Rian Rietveld’s talk about the EAA at WordCamp Europe, she mentioned a couple cases as examples of what to expect.
One was a case with Spanish airline Vueling. The National Court of Spain fined them €90,000 for not having an accessible website. Not only that but they were prohibited from receiving public funds for six months.
The second example was Ireland’s accessibility law. Their penalties may be:
- A fine of up to €5,000 and/or imprisonment for up to six months for a summary conviction,
- A fine of up to €60,000 and/or imprisonment for up to 18 months for an indicted conviction.
How to comply with the European Accessibility Act?
So how can you and your clients comply with the EAA? I am not a lawyer, and you should consult with one about compliance. Remember: compliance and conformance are two different matters, and compliance goes beyond a website, app, document, etc., conforming to accessibility guidelines.
Disability rights lawyer Lainey Feingold has some helpful information about E.U. laws and specific countries on her website.
But there are some things you can do to help make websites, apps and digital documents conform to accessibility guidelines and practices.
Accessibility statement
Make sure all websites have an accessibility statement. An accessibility typically includes the level of conformance you’re aiming for (i.e. WCAG 2.2 AA), the company’s plan and timeframe for implementing accessibility (auditing, remediation, etc.) and contact information for reporting any accessibility issues.
In clause 81, the EAA specifically mentions that companies must talk about how a service conforms to accessibility requirements in its terms and conditions. Maybe that could be included in the accessibility statement? I am not sure if that is a separate thing or not.
Audits and remediation
Get websites, apps and electronic documents audited or just go straight to having them remediated. Audits usually involve an assessment and a report, both of which take time and come at a high cost. But they don’t fix anything. That takes additional time. Remediating means diving right into fixing issues.
Ongoing monitoring
Accessibility is not set it and forget it, so ongoing monitoring is important. Some things to do are:
- Continue to monitor the state of the website and electronic documents.
- Assess the accessibility of any technical updates to the website: themes and plugins, especially forms.
- Check the accessibility of any new or newly edited pages or posts and any images, audio or video added to the site.
- Check the accessibility of digital documents (PDFs, Word, PowerPoint files, etc.) before publishing them.
Training
It’s best for anyone working on a website or creating digital documents to have accessibility training.
Anyone who maintains the technical aspects of the site, updates the content of the site, creates documents for the site should be trained.
If you’re a website designer or developer or document designer, you can work with an accessibility specialist to help these efforts if you don’t have the skills or if there is a lot of work to do and you want to get it done faster. But you can learn how to do this too.
You can get up to speed quickly with my plain-English accessibility training and straightforward processes. Check out my Foundations of Website Accessibility course and Accessible PDFs From InDesign course.
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