The European Accessibility Act (EAA) is now fully in force across all 27 EU Member States. This landmark legislation requires that many digital and physical products and services be accessible to people with disabilities. With the June 28, 2025 deadline now behind us, organizations that sell into or within the EU—regardless of where they are based—must ensure they are compliant or face legal and operational consequences.
Whether you’re a business leader, developer, content creator, designer, or policy advisor, understanding the EAA is no longer optional—it’s essential. In this blog, we break down the 15 most important takeaways from recent questions raised by companies trying to navigate the new landscape of accessibility in Europe.
1. The EAA Is Now Law Across the EU
The European Accessibility Act is not just guidance—it’s an enforceable law in all 27 EU Member States. It harmonizes accessibility requirements for certain products and services across the EU to ensure equal access for people with disabilities. The goal is to remove barriers and create a more inclusive digital and physical environment for everyone.
2. Microenterprises Are Exempt
Businesses with fewer than 10 employees and/or less than €2 million in annual turnover or balance sheet total are generally exempt from the EAA’s obligations when providing services. However, Member States may still offer guidance to help these businesses make their services more accessible.
3. Disproportionate Burden Exceptions Exist—but Must Be Justified
If the cost of compliance is too high relative to the benefit or company size, businesses may invoke the “disproportionate burden” clause. However, this isn’t a free pass. You must:
- Assess and document the costs
- Compare them to overall operations
- Notify relevant national authorities
Failure to report can lead to penalties.
4. Legal Responsibility Falls on Your Business, Not on Your Contractor
If your organization hires a third-party company to build your website or app, the legal responsibility for EAA compliance remains with your company, not the contractor. You must ensure any contracts for such work include accessibility requirements and that any company you hire has the capacity to deliver on them.
5. Software Updates Trigger Accessibility Obligations
Under the EAA, even minor updates—including content tweaks, bug fixes, or UI changes—can reset the compliance clock. Most continuously developed or agile-based products must meet accessibility standards with each release.
6. EN 301 549 and WCAG 2.1 Are the Current Benchmarks
The EAA’s technical accessibility requirements are based on EN 301 549, which currently references WCAG 2.1 AA. Businesses should already be preparing for future updates that will likely require WCAG 2.2 AA compliance.
7. Mobile Apps Must Support Multiple Orientations
Accessibility guidelines require mobile apps to be usable in both portrait and landscape modes. Popular apps like Facebook and Slack may not currently meet this, but that does not excuse non-compliance. Orientation flexibility is key to accessibility.
8. Non-Ecommerce Websites Are Still in Scope
Even if your site doesn’t include a shopping cart, features like contact forms, product information, or support pages make it subject to EAA requirements. Any part of a site that facilitates interaction or delivers a service must be accessible.
9. Partial Compliance Is Risky
Trying to only make parts of your website or app accessible (like just the homepage or checkout flow) is a short-sighted strategy. Accessibility should be integrated throughout the entire user experience to minimize legal risk and maximize usability.
10. Accessibility Overlays Aren’t Enough
Many companies have turned to overlays—automated tools that attempt to fix accessibility issues on the front-end. However, the European Commission has explicitly stated that overlays alone cannot ensure compliance. Manual testing, remediation, and design adjustments are still required.
11. National Authorities Will Enforce the Rules
Each EU Member State is responsible for enforcing EAA compliance. Authorities will conduct regular checks, investigate complaints, and have the power to issue fines or sanctions for non-compliance. Businesses must take enforcement seriously.
12. B2B and Internal Systems Are Generally Exempt
The EAA applies to services and products offered to consumers—not internal systems or B2B platforms. That said, some tools (like content management systems) used both internally and externally may still fall under EAA rules if they affect public-facing services.
13. Free Services Are Still Considered Services
The EAA defines “services” in line with EU law. Even free apps, blogs, or booking tools may fall under this definition if they are part of an economic activity. “Remuneration” doesn’t always mean money is exchanged—it can include services that generate value in other ways (e.g., ads, lead generation).
14. Non-EU Businesses Must Comply If Serving EU Consumers
If your company is based in the US or elsewhere, but you sell to or serve EU-based consumers, you are subject to the EAA. This includes e-commerce sites, mobile apps, and physical products shipped to the EU.
15. Having a Roadmap Helps—But Won’t Stop Complaints
Regulators may be more lenient if you show a good-faith effort toward compliance with a clear roadmap. However, consumers can still file complaints, and accessibility issues can disrupt operations and damage your reputation. Aim for proactive compliance, not reactive excuses.
Conclusion
The EAA represents a major shift in how accessibility is handled across the European market. For businesses, it’s both a legal obligation and an opportunity to create better, more inclusive digital experiences.
If your organization hasn’t yet taken steps toward full EAA compliance, now is the time. Begin by auditing your digital properties, training your teams, updating procurement language, embedding accessibility into every stage of your product lifecycle, and, of course, reaching out to us with questions and to do an audit of your website.