European Accessibility Act 2025 – Website Accessibility Impact (Directive 2019/882)

Accessibility Standards: The EAA sets functional accessibility requirements for websites and related online services rather than naming a specific technical standard. In practice, these requirements align closely with principles from the Web Content Accessibility Guidelines (WCAG). Annex I of the directive mandates that websites (and mobile apps) must be "perceivable, operable, understandable and robust" for users with disabilities (Official EAA Directive Text). These four principles are the foundation of WCAG 2.1, ensuring that content can be perceived in multiple ways, all interface elements can be operated by different means, information is clear, and technology is compatible with assistive tools.

Functional Criteria: Businesses must ensure that all information and user interface components on their sites meet specific criteria. Notable requirements include:

• Multi-Sensory and Flexible Presentation: Information about a service or product must be available through more than one sensory channel (for example, provided in text and audio formats) and presented in a clear, understandable way (EAA Requirements on Multi-Sensory Access). Text alternatives should be provided for non-text content (e.g. images or multimedia), enabling assistive technologies to convey equivalent information.
• WCAG-Aligned Web Design: All website content and interactive features must conform to the POUR principles (Perceivable, Operable, Understandable, Robust). This means, for example, ensuring that non-text content has text descriptions, that all functions can be used via keyboard (not just mouse), that content is structured logically for comprehension, and that the site's code is compatible with assistive technologies like screen readers (EAA Technical Requirements) (POUR Principles in EAA). In essence, although the EAA does not explicitly require "WCAG 2.1 AA" compliance, it embeds the same objectives – making web services as accessible as if WCAG guidelines were followed.
• Accessible Forms and E-Commerce Features: For websites that offer services (e.g. e-commerce or online banking), interactive steps such as login, identification, security verification, and payment must be accessible. The directive specifies that identification/authentication mechanisms and payment interfaces provided online must be perceivable, operable, understandable, and robust (EAA E-Commerce Requirements) (Digital Service Accessibility Standards). For instance, an online shop's checkout process should be fully usable by a screen reader and keyboard-only navigation, with clear error indicators and instructions.

Technical Standards: To help businesses meet these requirements, the EU relies on harmonized standards. The current European standard for ICT accessibility, EN 301 549, already incorporates WCAG 2.1 Level AA criteria as the baseline (EU Web Accessibility Standards Guide). Compliance with EN 301 549 is a common way to achieve the EAA's web accessibility goals. In fact, an updated version of EN 301 549 (expected as v4.1.1) will be officially harmonized with the EAA, meaning that conforming to this standard gives a "presumption of conformity" with the directive (EAA Standards Harmonization Overview). In practical terms, businesses can look to WCAG 2.1 AA success criteria as the blueprint for making websites EAA-compliant. While the EAA's legal text is phrased in functional terms, following WCAG's concrete guidelines (e.g. text alternatives for images, captions for videos, form input labels, etc.) is considered a reliable way to satisfy the Act's technical requirements (WCAG Compliance and EAA Requirements).

Enforcement Structure: Enforcement of the EAA is largely decentralized to EU member states. Each country must designate one or more authorities (often called market surveillance or competent authorities) to oversee compliance (EAA Enforcement Framework). These bodies will monitor products and services, investigate complaints, and have powers to take corrective action. Starting June 28, 2025, consumers and advocacy groups can file complaints if a product or service (including a website) fails to meet accessibility requirements (EAA Compliance Monitoring System). Upon finding non-compliance, regulators can issue warnings and require fixes within a given timeframe. In serious cases, authorities can even order non-compliant services to be suspended or products withdrawn from the market until they are brought into conformity (EAA Enforcement Powers). The EAA explicitly requires that penalties for violations be "effective, proportionate and dissuasive," which means EU countries are expected to impose sufficiently serious consequences to discourage businesses from ignoring accessibility rules (EAA Penalty Framework).

Penalties for Non-Compliance: The specific fines for accessibility violations are determined by national law, so they vary across EU member states. Many countries have updated their legal frameworks (or will do so by 2025) to introduce substantial fines for breaching the new accessibility obligations. For example:

• Spain can impose hefty fines ranging from €30,000 up to €1,000,000 for serious cases of website or service inaccessibility, under its existing laws (e.g. Law 51/2003 and national web accessibility regulations) (Spanish EAA Enforcement Guidelines). The upper end would apply to the most severe or repeated offenses.
• Germany's disability equality and ICT laws (e.g. BITV and BGG) allow fines up to €100,000 per violation for failing to meet digital accessibility requirements (German Digital Accessibility Penalties). This framework is expected to continue under the EAA, meaning large organizations could face six-figure penalties if their websites or apps remain inaccessible.
• France recently strengthened its enforcement: public sector bodies and very large companies (annual turnover ≥ €250M) can be fined €50,000 for not conforming to web accessibility standards (RGAA/EN 301 549), with additional penalties around €25,000 for failing to publish the required accessibility statements and action plans (French Accessibility Law Updates) (French Accessibility Reporting Requirements). These fines can recur (e.g. every six months) until compliance is achieved.
• Other countries also have strict fines in place. In the Netherlands, regulators may levy up to €450,000 in fines for accessibility breaches (Dutch Accessibility Enforcement Measures). Ireland can impose penalties from €5,000 up to €60,000 depending on the nature of the violation (higher for indictable offenses) (Irish Digital Accessibility Penalties). Italy sets fines roughly between €5,000 and €20,000 for accessibility violations in either public or private sector websites, and is expected to tighten enforcement under the EAA (Italian EAA Implementation Guide). Sweden's anti-discrimination and digital services laws similarly allow significant sanctions (up to 10 million SEK) for non-compliance (Swedish Digital Accessibility Laws).

Enforcement in Practice – Lessons from Past Directives: The EAA builds on prior EU accessibility efforts, notably the Web Accessibility Directive (2016/2102) which required public sector websites/apps to be accessible. Enforcement of the Web Accessibility Directive (WAD) in 2018-2021 was characterized by a focus on compliance through monitoring and remedial action rather than punishments. All member states set up formal procedures where users could report inaccessible public websites and trigger an enforcement process (). However, an EU review found that these feedback and enforcement mechanisms "have not yet reached their full potential," partly because many users were unaware or unsure of how to use them (). In practice, relatively few fines were issued under the WAD; instead, governments often emphasized helping agencies fix issues. For instance, Italy's enforcement body intervened when certain government agencies failed to meet web accessibility requirements, resulting in those agencies having to rapidly remediate their sites (a corrective rather than punitive approach) (The Cost of EAA Violations and Their Legal Consequences). In Sweden, regulators put public institutions and their private contractors on notice that fines would be coming if they didn't address accessibility failures, effectively using the threat of penalties to spur compliance (The Cost of EAA Violations and Their Legal Consequences). France saw high-profile organizations subjected to audits and "name-and-shame" reports; violations led to mandatory corrective action plans and significant reputational damage for those entities (The Cost of EAA Violations and Their Legal Consequences). These case studies show that enforcement is real: even before large fines are levied, companies can be compelled to fix issues and may suffer public scrutiny. With the EAA extending accessibility obligations to the private sector, experts anticipate more vigorous enforcement after 2025. Each member state's authority is empowered to conduct audits, issue binding orders to comply, and apply penalties or even bar companies from offering inaccessible services (The Cost of EAA Violations and Their Legal Consequences) (The Cost of EAA Violations and Their Legal Consequences). In short, non-compliance will carry both legal and business risks, and regulators are expected to enforce the rules more stringently as the deadline passes.

WCAG 2.1 as the Baseline: The Web Content Accessibility Guidelines (WCAG) 2.1 are the internationally recognized standards for web accessibility. While WCAG itself is not a law, it heavily influences EU regulations. The earlier Web Accessibility Directive (for public sector websites) explicitly referenced EN 301 549, a European standard which in turn "refers to the Web Content Accessibility Guidelines 2.1 Level AA" for its concrete criteria (The EU Web Accessibility Directive: Frequently Asked Questions). This made WCAG 2.1 Level AA effectively the legal benchmark for public websites in the EU. The European Accessibility Act similarly draws from WCAG 2.1 principles. As noted, Annex I of the EAA uses the four guiding principles of WCAG (Perceivable, Operable, Understandable, Robust) to frame its requirements for websites and mobile apps (Directive - 2019/882 - EN - EUR-Lex). Many of the EAA's detailed rules (e.g. providing text alternatives, ensuring keyboard operability, etc.) correspond directly to WCAG success criteria.

However, Directive 2019/882 does not outright mandate "WCAG 2.1 compliance" by name (European Accessibility Act (EAA) Summary | Accessible.org). Instead, it sets functional goals that WCAG compliance would fulfill. The EAA was crafted to be technology-neutral and future-proof, so it doesn't lock in a specific version of WCAG. That said, conforming to WCAG 2.1 AA is widely seen as the surest way to meet the Act's current web accessibility requirements (European Accessibility Act (EAA) Summary | Accessible.org). In fact, meeting WCAG 2.1 AA across your website should cover the vast majority of EAA criteria for websites (from text transcripts for audio content to proper focus order for interactive elements).

Harmonized Standards and WCAG Alignment: The European Commission will issue or update harmonized standards that correspond to the EAA – these are official technical standards that, if followed, give legal certainty that you comply. As mentioned, the key standard is EN 301 549, which already mirrors WCAG 2.1 AA and related ICT accessibility guidelines. A new version of EN 301 549 aligned to the EAA is expected by 2025 (European Accessibility Act (EAA) Summary | Accessible.org). This will likely continue to reflect WCAG 2.1 (and potentially newer WCAG 2.2 improvements) as the reference. Member States and businesses also look to European Harmonised Standard EN 301 549 because using it creates a "presumption of conformity" with the law (European Accessibility Act (EAA) Summary | Accessible.org). In practical terms, the strong overlap means that efforts put into meeting WCAG 2.1 will directly satisfy EAA obligations. Conversely, ignoring WCAG guidelines would almost certainly result in failing to meet the EAA's functional requirements. In summary, WCAG 2.1 serves as the blueprint for EAA web accessibility: it provides the specific testable checkpoints (like having captions on videos or not using inaccessible CAPTCHAs) that underpin the Act's broad principles. Businesses are therefore wise to use WCAG 2.1 AA as their compliance checklist for website and mobile app accessibility under the EAA.

Covered Sectors and Services: The European Accessibility Act does not apply to every website in Europe, but rather to those offering certain key products and services identified in the directive's scope (Article 2). These are industries deemed both important to persons with disabilities and prone to inconsistent accessibility rules across the EU. According to the directive and EU summaries, the EAA "applies to certain consumer products and services across a range of sectors including banking, computers and tablets, telecommunications, e-commerce, e-publishing, and air, bus, rail and water passenger transport services." (European Accessibility Act (EAA) - Bird & Bird) In addition, it covers digital TV services/devices and the European emergency number 112. In practice, this means:

• Public Transport and Travel: Websites, mobile apps, electronic ticketing systems, and electronic information for passenger airlines, bus/coach services, railways, and ferries must be accessible (European Accessibility Act (EAA) Summary | Accessible.org). For example, an airline's website for booking tickets and a train operator's mobile app for schedules and e-tickets are within scope.
• E-Commerce: Any business offering online sales of products or services is covered. The directive defines e-commerce services broadly as services provided at a distance via websites or mobile apps to consumers for concluding consumer contracts (Directive - 2019/882 - EN - EUR-Lex) (Directive - 2019/882 - EN - EUR-Lex). In short, online shops and marketplaces must ensure their web interfaces (product listings, checkout process, customer support chat, etc.) are accessible. Notably, this applies even if the product itself isn't covered by the EAA – selling any product or service online triggers the website requirements (Directive - 2019/882 - EN - EUR-Lex). So, an online retailer, food delivery service, or travel booking site all fall under the Act.
• Banking and Financial Services: Consumer banking services (such as online banking portals, mobile banking apps, electronic payment services, ATMs interfaces, etc.) are in scope () (). For instance, banks must ensure that their websites for account management, loan applications, or payment transfers are accessible to users with disabilities. Payment terminals and e-payment gateways used in e-commerce must also meet accessibility criteria.
• Telecommunications: Providers of electronic communications services (telecom operators, internet service providers) and related consumer equipment (like smartphones or landline phones) are covered (European Accessibility Act (EAA) - Bird & Bird). This means websites or apps for telephony services (e.g. customer account management portals, call/SMS applications) must be accessible. Additionally, special requirements apply for communications – for example, enabling text-based and synchronized communication for emergency calls (ensuring 112 emergency services are reachable by text or video for people with hearing/speech disabilities) (Directive - 2019/882 - EN - EUR-Lex) (Directive - 2019/882 - EN - EUR-Lex).
• E-Books and Media: E-book files and their distribution platforms must be accessible, and services that provide access to audiovisual media (like video streaming platforms) have accessibility obligations for their user interfaces (European Accessibility Act (EAA) Summary | Accessible.org). The EAA dovetails with existing EU media laws by ensuring the apps and websites of video on-demand services or digital TV interfaces are usable by people with disabilities (though the content itself – like captioning of videos – may be governed by the Audiovisual Media Services Directive).
• Hardware Products: Although our focus is websites, it's worth noting the EAA also covers many consumer electronics (from computers and operating systems to self-service kiosks like ATMs, ticketing machines, and interactive info terminals) () (). Manufacturers of these products must meet accessibility requirements (e.g. an ATM must have tactile keys and audio output options). When these products have a digital interface or companion website, those too must be accessible.

Who Must Comply – Business Size and Exemptions: The EAA obligations apply to economic operators of the covered products/services – primarily manufacturers, service providers, and also importers/distributors in the supply chain. Private sector companies offering the in-scope services are the main new target of this law (previously, only public sector websites were EU-mandated to be accessible). Public sector entities are generally already covered under the 2016 Web Accessibility Directive, but the EAA may indirectly extend some duties (for instance, public procurement must ensure any procured EAA-covered product or service meets the new standards (European Accessibility Act (EAA) Summary | Accessible.org)).

Importantly, the directive includes an exemption for the very smallest businesses in the services category: microenterprises providing services are exempt from the EAA requirements (Directive - 2019/882 - EN - EUR-Lex) (Directive - 2019/882 - EN - EUR-Lex). A microenterprise is defined (by EU criteria) as a company with fewer than 10 employees and a turnover under €2 million. In other words, a tiny start-up offering an e-commerce service or a local family-run transport service might not be legally compelled to make its website accessible under the EAA. The rationale is to avoid over-burdening micro businesses. That said, the law "encourages" small players to still follow accessibility best practices, recognizing the benefits of inclusivity (European Accessibility Act (EAA) Summary | Accessible.org). Additionally, even microenterprises may find they need to comply in practice if they want to partner with larger organizations or bid for contracts (since larger entities and public bodies will demand accessibility from their suppliers).

Aside from the microenterprise exemption, there are also general clauses for "disproportionate burden" or fundamental alteration – similar to those in the public sector Web Directive. If a company can demonstrate that making a particular feature accessible would impose a disproportionate burden (excessive costs or technical infeasibility) or would fundamentally change the nature of the product/service, they may be allowed a specific exception (). However, these derogations are tightly constrained: the burden or impact must be well documented and justified to regulators, and it's not a blanket pass. In practice, very few organizations have been able to claim disproportionate burden under the public sector rules (only a handful of cases in the first few years of WAD enforcement) () (). We can expect EAA regulators to also scrutinize any such claims. The default expectation is that all covered businesses (beyond micro-size) will make the necessary changes by 2025.

Timeline Considerations: The deadline for compliance is 28 June 2025 for new products and services to meet the requirements (European Accessibility Act (EAA) Summary | Accessible.org). Member States had to transpose the directive into national law by 2022, and give companies a transition period until 2025. After June 2025, any new website or app falling under the scope must be accessible from the start. For existing services, there is some leeway for certain physical installations: for example, existing self-service terminals (like ATMs or ticket machines) that cannot be easily updated may be used until 2030 (or until end-of-life) before replacement (European Accessibility Act (EAA) Summary | Accessible.org), and some existing equipment can be grandfathered until 2045 in exceptional cases (e.g. an ATM that's too costly to retrofit but will be phased out) (European Accessibility Act (EAA) Summary | Accessible.org). However, websites and mobile applications are expected to be brought into compliance by 2025, unless a specific extension is granted by a national law for a very narrow context. Companies should therefore be well on their way to auditing and updating their digital platforms ahead of the deadline.

Compliance Costs and Challenges: Achieving compliance with web accessibility standards requires an investment of time and resources. Businesses will need to audit their websites and apps for accessibility issues, then plan for design and development work to fix any shortcomings. Common tasks include adding missing alt text to images, reworking page layouts for screen reader compatibility, adjusting color schemes for contrast, making forms and interactive widgets fully keyboard-accessible, and testing the site with assistive technologies. Many organizations choose to hire accessibility experts or consultants to conduct evaluations and guide remediation efforts. This can involve costs such as paying for audits (e.g. manual WCAG audits often priced per page or per template) and developer time to implement code fixes or redesign certain features. Staff training is another cost factor: teams (developers, designers, content authors) may need training on accessibility best practices to maintain compliance going forward.

While these efforts do impose costs, studies of past implementations suggest that accessibility-related costs are not a major financial barrier in most cases (). The European Commission's review of the public sector Web Directive found that although public bodies reported some additional expenses, those were generally proportionate and manageable, and hardly any invoked the undue burden" escape clause. In the private sector context, many companies might find that building accessibility in can be integrated into regular IT upgrade cycles or web redesign projects. Modern web frameworks and content management systems increasingly offer built-in support for accessibility (or at least plugins to assist), which can mitigate costs. Still, for businesses with very outdated or non-compliant websites, the operational challenge of retrofitting accessibility can be significant. Some may need to undertake a substantial overhaul of their site or even rebuild certain applications from scratch to meet WCAG 2.1 AA standards (The Cost of EAA Violations and Their Legal Consequences). If left to the last minute, this can be disruptive – rushed retrofitting efforts can lead to high costs and operational downtime as teams scramble to fix issues under regulatory pressure (The Cost of EAA Violations and Their Legal Consequences) (The Cost of EAA Violations and Their Legal Consequences). It's far more cost-effective to incorporate accessibility early (e.g. in the design phase of a website) than to do it reactively.

Penalties and Liability Risks: On the flip side, non-compliance can prove far more costly. Companies that ignore the EAA risk fines (as detailed earlier) that can easily run into tens or hundreds of thousands of euros depending on the country and severity. Beyond regulatory fines, there's the possibility of lawsuits and compensation claims. Under EU law, individuals or advocacy groups may take legal action against companies that fail to meet accessibility obligations, especially once the requirements are explicit in national laws. Defending such legal actions can be expensive – legal proceedings alone can "easily exceed six figures" in costs even if the case doesn't go to full trial (The Cost of EAA Violations and Their Legal Consequences). Many organizations opt to settle accessibility lawsuits out of court, which can cost hundreds of thousands of euros in settlements (The Cost of EAA Violations and Their Legal Consequences), not to mention the negative publicity. There's also the risk of paying damages or being subject to injunctions that force a company to shut down parts of its service until fixes are made.

Moreover, under the EAA enforcement regime, a company might be ordered to temporarily cease offering a non-compliant service. For an e-commerce site or a digital banking platform, being forced offline (even briefly) to address accessibility could mean significant lost revenue and business interruption. This puts an additional weight on the operational impact: accessibility compliance becomes mission-critical for business continuity in the EU market.

Impact by Industry (examples): Different industries will experience the impact in specific ways. Online retail (e-commerce) companies may need to invest in updating their shopping platforms – adding features like accessible product image galleries, ensuring the checkout process works with screen readers, etc. Many larger retailers are already doing this, but smaller merchants will have to catch up or potentially face penalties. The banking and finance sector in many EU countries has been gradually improving digital accessibility (often under pressure from national regulators or customer complaints). With the EAA, banks across Europe must uniformly upgrade their customer-facing apps and sites; those that have lagged will need to allocate budget for compliance projects (updating ATM software, adding text-to-speech functions, captioning multimedia in online tutorials, etc.). Transportation providers (airlines, railways, public transit agencies) will similarly need to ensure their ticket booking websites, travel info pages, and self-service kiosks are accessible – this might involve procuring new accessible IT systems or heavily customizing interfaces. Past compliance efforts show that when airlines failed to provide accessible booking options, consumer organizations raised complaints leading to mandated fixes – the EAA will formalize such requirements for all carriers EU-wide.

One notable business implication is in public procurement and B2B contracts. Governments and public entities in the EU already cannot purchase products or services that are not accessible (per public procurement directives and the EAA's interplay with them) (European Accessibility Act (EAA) Summary | Accessible.org). This means that if a business wants to sell software or digital services to any public sector client in Europe, it must be able to demonstrate accessibility compliance. There have been cases where companies lost lucrative contracts or were disqualified from bidding because their digital products did not meet accessibility criteria (The Cost of EAA Violations and Their Legal Consequences) (The Cost of EAA Violations and Their Legal Consequences). For example, a financial software provider might be passed over in a government tender if its web application fails to support keyboard navigation for users with disabilities (The Cost of EAA Violations and Their Legal Consequences). In the transport sector, a private bus company could be barred from a city's service contract after an audit found its ticketing app inaccessible (The Cost of EAA Violations and Their Legal Consequences). Thus, beyond direct fines, non-compliance carries a competitive disadvantage: businesses may be excluded from market opportunities if they cannot prove their websites or digital offerings are accessible. By contrast, companies that invest in accessibility can use it as a selling point and meet the procurement requirements, turning compliance into a market advantage rather than just a cost.

Long-Term Benefits: While the initial push to comply with the EAA may feel costly or complex, there are long-term financial benefits for businesses that embrace accessibility. The European Commission notes that having common accessibility rules across the EU can actually reduce costs for companies by harmonizing requirements and removing the need to customize products per country (European accessibility act - European Commission). Instead of dealing with a patchwork of national laws or potential lawsuits in different jurisdictions, a business can follow one standard and cover the whole EU market. This eases cross-border trade and opens up new customer segments (European accessibility act - European Commission). There are over 80 million Europeans with disabilities, and even more when including the aging population – making websites accessible allows companies to serve this large demographic, potentially gaining customers and goodwill. Accessible websites often have better usability for all users (which can increase conversion rates) and improved search engine optimization (SEO) – for example, adding proper alt text for images not only helps blind users but also improves image search indexing. Many organizations find that accessibility improvements align with mobile-friendly and user-centric design, providing a smoother experience for everyone. Finally, showing commitment to accessibility can enhance a company's brand reputation as an inclusive, socially responsible business.

In sum, the financial and operational impact of the EAA on websites is two-fold: there is an upfront cost and effort to comply, but this is balanced against the avoidance of potentially very steep penalties and the opportunity to improve service quality and reach. Companies that plan ahead – conducting audits, training their teams, and integrating accessibility into their development lifecycle – are likely to manage these costs effectively. Those that delay or dismiss the requirements may find themselves facing not only fines and legal actions, but also the scramble of urgent retrofitting which is far more disruptive (as seen in cases where enforcement actions forced rapid fixes at high expense) (The Cost of EAA Violations and Their Legal Consequences) (The Cost of EAA Violations and Their Legal Consequences). As the June 2025 deadline approaches, smart businesses are treating accessibility compliance as an investment into their product's quality and their eligibility to operate in Europe, rather than just a regulatory checkbox. The EAA represents a shift towards accessibility being a standard part of doing business online in the EU – much like data privacy became essential after GDPR – and organizations should adapt their strategies accordingly.

The European Accessibility Act represents a significant shift in how digital accessibility is regulated in the EU. By setting clear requirements and enforcement mechanisms for website accessibility, it pushes businesses to make their online services more inclusive. While compliance may require investment and changes to development practices, the alternative – facing fines or being excluded from the EU market – is far costlier. Organizations should view the EAA not just as a regulatory obligation but as an opportunity to improve their digital services for all users.

For businesses operating in or targeting the EU market, now is the time to assess their websites and begin necessary accessibility improvements. This might involve conducting accessibility audits, training development teams, updating design systems, and establishing processes to maintain accessibility in future updates. While the deadline may seem distant, the scope of changes required for full compliance can be substantial – starting early allows for a more manageable and strategic approach to meeting the EAA's requirements.

• Official EU Resources:
  • Full text of the European Accessibility Act (Directive 2019/882)
  • European Commission's EAA Overview
• Technical Standards:
  • WCAG 2.1 Quick Reference
  • EN 301 549 Standard
• Implementation Guidance:
  • W3C's Planning and Managing Web Accessibility
  • Evaluating Web Accessibility Overview