EU Accessibility Act

The EAA is a major step toward a more inclusive Europe. By requiring products and services to be accessible regardless of disability, it expands rights for 87 million Europeans with disabilities and establishes a single-market standard that replaces the patchwork of national rules that came before it.

For businesses, accessibility is no longer optional. It is a legal requirement with enforcement mechanisms in each Member State, and companies that ignored accessibility before June 2025 now face an evolving compliance landscape with real penalties attached.

What the EU Accessibility Act Covers

The EAA (Directive 2019/882) applies to specific categories of products and services placed on the EU market:

• Computers and operating systems
• Smartphones and other communication devices
• TV equipment related to digital television services
• Telephone services and related equipment
• Access to audiovisual media services (streaming services, broadcast-related equipment)
• Services related to air, bus, rail, and waterborne passenger transport
• Consumer banking services
• E-books and dedicated e-reader software
• E-commerce services
• ATMs, ticketing machines, and check-in machines
• 112 emergency communications

The Act applies to businesses that sell to EU consumers, regardless of where the business is headquartered. A US or UK company with an e-commerce site available to EU customers is within scope. Non-EU businesses that block EU visitors entirely can avoid the Act, but for most commercial sites that’s not a viable strategy.

EAA vs the Web Accessibility Directive: Two Different Laws

The EU has two separate accessibility laws that are frequently confused:

• Web Accessibility Directive (WAD) — Directive (EU) 2016/2102, adopted in 2016 with full enforcement since 2020. Applies to public sector websites and mobile apps (government bodies, public-sector organizations, public service contracts). Member States transposed it into national law.
• European Accessibility Act (EAA) — Directive (EU) 2019/882, with compliance required since June 28, 2025. Applies to private sector products and services in the categories listed above.

Both laws point to the same technical standard (EN 301 549 and WCAG). The difference is who they apply to. Public sector organizations comply with WAD; private sector businesses with covered products or services comply with EAA. Some organizations fall under both.

WCAG and EN 301 549

The EAA and WAD both reference EN 301 549, the European harmonized standard for accessibility requirements of ICT products and services. EN 301 549 in turn adopts the W3C’s Web Content Accessibility Guidelines (WCAG) as its technical foundation.

For 2026 compliance:

• The current harmonized standard cited by the EAA is EN 301 549 V3.2.1 (August 2021), which references WCAG 2.1 Level AA.
• WCAG 2.2 was published by the W3C in October 2023 and adds nine new success criteria (focus appearance, target size, dragging movements, and several cognitive accessibility improvements). An updated EN 301 549 (V4.x) referencing WCAG 2.2 is expected to become the harmonized standard, but EAA compliance is currently measured against the 2.1 requirements.
• Practically, building to WCAG 2.2 now is a sensible forward-looking move — it exceeds current EAA requirements and future-proofs against the next harmonized-standard update.

Core WCAG 2.1 AA requirements include: text alternatives for non-text content, keyboard accessibility, adequate color contrast (at least 4.5:1 for normal text), pages that work at 200% zoom, no content that flashes more than three times a second, descriptive labels and error messages, and content that makes sense when read by a screen reader.

Enforcement and Penalties

Each EU Member State sets its own enforcement regime. Administrative fines in most states range from €2,000 to €100,000 per violation, with higher ceilings in some countries. Ireland’s regime allows for fines up to €60,000 and potential imprisonment for repeat non-compliance. Germany, France, and the Netherlands have established enforcement bodies with audit and complaint-handling powers. Consumers, disability rights organizations, and competitors can all file complaints.

The first 12 months of enforcement (mid-2025 to mid-2026) focused more on notice-and-remediation than immediate fines, but intensity is expected to increase as Member State bodies build up casework.

Microenterprise Exemption

The EAA includes a carve-out for microenterprises providing services (not products): businesses with fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million are exempt from the detailed accessibility requirements, though they must still demonstrate on request how they considered accessibility. The exemption doesn’t extend to microenterprises selling covered products. Businesses above the 10-employee or €2M threshold have no exemption and must comply in full.

A Tool to Stay Compliant With the EU Accessibility Act

As businesses and organizations work to maintain compliance with the EAA, the right tools make accessibility testing and remediation manageable. DYNO Mapper is a website mapping and accessibility testing tool that can help you stay compliant with WCAG 2.1 AA.

DYNO Mapper offers a range of features that help identify accessibility issues on your website. With its accessibility testing tool, you can test your website for compliance with WCAG 2.1 AA, including issues related to alternative text, keyboard navigation, and language clarity. The tool provides detailed reports that highlight accessibility issues and suggest ways to fix them.

In addition to its accessibility testing tool, DYNO Mapper offers a website mapping tool that helps visualize the structure of your website. This is useful for identifying areas that may be difficult to navigate for individuals with disabilities. Understanding your site structure makes it easier to make informed decisions about accessibility priorities.

DYNO Mapper’s user-friendly interface makes the tool accessible without a deep technical background, and its reports are easy to understand and act on. For businesses maintaining EAA compliance, it’s a practical starting point for identifying issues and tracking remediation.

Frequently Asked Questions

Does the EAA apply to my US business?

It applies if you sell covered products or services to EU consumers. Geographic location of the business headquarters doesn’t matter — what matters is whether you place products or services on the EU market. An English-language e-commerce site that ships to EU customers falls under the EAA.

What happens if I’m not compliant?

Enforcement is handled by each Member State. Typical consequences range from notice-and-remediation orders to administrative fines (€2,000-€100,000+ per violation in most Member States), product or service prohibitions, and in some jurisdictions criminal liability for repeat offenders.

Do I need WCAG 2.2 compliance or is 2.1 enough?

EAA compliance is currently measured against WCAG 2.1 Level AA (via EN 301 549 V3.2.1). WCAG 2.2 was published in October 2023 and exceeds current EAA requirements. Building to 2.2 is a good forward-looking choice, but 2.1 AA satisfies the current legal requirement.

How do I prove compliance?

EAA-covered services (including websites) need an accessibility statement that documents the level of compliance, any non-compliant content, and contact details for feedback. For products, the manufacturer issues an EU Declaration of Conformity and applies CE marking. Third-party accessibility audits provide evidence but are not strictly required.

Bottom Line

The European Accessibility Act has been in force since June 28, 2025, and is the most significant expansion of digital accessibility law in Europe in over a decade. Compliance requires meeting WCAG 2.1 AA (via EN 301 549) for covered products and services, and non-compliance carries real financial and reputational risk.

For businesses still catching up: start with a WCAG 2.1 AA accessibility audit of your customer-facing digital properties, publish or update your accessibility statement, and establish a remediation workflow for new issues as they surface. Accessibility is both a legal requirement in the EU and a baseline expectation globally — the right approach is to treat it as part of your ongoing quality process rather than a one-time compliance project.