European Accessibility Act (EAA) 2025: The Complete Compliance Checklist for Websites, E-Commerce and SaaS
On 28 June 2025, the European Accessibility Act (EAA) became directly enforceable across all 27 EU member states. For the first time, private-sector digital products and services — e-commerce storefronts, SaaS platforms, banking apps, e-readers, streaming services and more — must meet a harmonized accessibility standard or face fines, injunctions and market-access restrictions.
Nearly a year into enforcement, the pattern is clear: regulators have started acting on complaints, national accessibility bodies are publishing non-compliance lists, and procurement teams at large EU buyers now reject vendors without documented conformance. If your business touches EU consumers and you have not formally audited your website or product against WCAG 2.2 AA, your exposure is growing every week.
This guide walks through exactly who must comply, what the Act requires in practice, the penalties country-by-country, and a 12-step checklist your team can work through this quarter.
What the European Accessibility Act Actually Covers
The EAA (Directive 2019/882) is designed to harmonize accessibility requirements for products and services across the EU single market. The scope is deliberately broad and covers most B2C digital services.
Products within scope
- Consumer computer hardware and operating systems
- Self-service terminals (ATMs, ticket machines, check-in kiosks)
- Consumer terminal equipment for telecoms and audiovisual services
- E-readers
Services within scope
- E-commerce: Any website or app selling products or services to EU consumers
- Banking services: Retail banking websites, apps and payment interfaces
- Electronic communications: Telecom services including emergency communications
- Audiovisual media: Streaming services, on-demand video
- Transport: Websites, apps and ticketing for passenger transport
- E-books and dedicated reading software
Who is exempt
There is a limited microenterprise exemption for services: businesses with fewer than 10 employees and annual turnover or balance sheet under €2 million are exempt from the service requirements (but not product requirements). This is narrow — most digital agencies, SaaS companies and e-commerce operators fall outside it. And the exemption does not travel with your customers: an exempt vendor cannot shield a non-exempt client from their own compliance obligations.
The Technical Standard: WCAG 2.2 Level AA
The EAA references the harmonized European standard EN 301 549, which in turn aligns with the W3C's Web Content Accessibility Guidelines. In practice, meeting the digital-service requirements means conformance to WCAG 2.2 Level AA.
WCAG organizes requirements around four principles — the POUR model:
| Principle | What it means | Common failures |
|---|---|---|
| Perceivable | Information must be presentable in ways users can perceive, regardless of sensory ability. | Low color contrast, missing alt text, video without captions, images of text. |
| Operable | Interface components must be operable via keyboard, voice, switch devices and touch. | Keyboard traps, missing focus indicators, touch targets smaller than 24×24 CSS pixels. |
| Understandable | Information and operation must be understandable. | Unlabeled form fields, cryptic error messages, unexpected context changes. |
| Robust | Content must be interpretable by assistive technologies including current and future tools. | Invalid ARIA, missing landmarks, non-semantic markup. |
WCAG 2.2 added nine new success criteria on top of WCAG 2.1 — most notably 2.4.11 Focus Not Obscured, 2.5.7 Dragging Movements and 2.5.8 Target Size (Minimum). If your last audit was done against WCAG 2.1, there are almost certainly new gaps in your product. See our guide to WCAG color contrast ratios and touch target size requirements for two of the most frequently violated criteria.
Penalties for Non-Compliance by Country
Each EU member state sets its own penalty regime when transposing the EAA into national law. The ranges are significant:
| Country | Maximum administrative fine | Additional measures |
|---|---|---|
| Germany | Up to €100,000 per violation | Market withdrawal, criminal liability for repeat offenders |
| France | Up to €50,000 per service; up to €250,000 for legal entities | Public naming, ARCOM referrals |
| Spain | €301 – €1,000,000 depending on severity | Temporary suspension of service |
| Italy | Up to 5% of annual turnover | AgID enforcement orders |
| Netherlands | Up to €103,000 per violation | Public enforcement registry |
| Ireland | Up to €60,000 on summary conviction; unlimited on indictment | Injunctions, criminal prosecution for wilful non-compliance |
Beyond fines, the more damaging consequence is often procurement disqualification. Enterprise RFPs and public-sector tenders now routinely require a VPAT or Accessibility Conformance Report. Missing documentation means missing the shortlist.
The 12-Step EAA Compliance Checklist
Work through these steps in order. Most teams can complete the audit phase in 4–6 weeks and reach documented conformance in 3–6 months.
Phase 1 — Scoping (Week 1)
1. Map your in-scope surfaces. List every public-facing website, web application, mobile app, email template and self-service terminal your organization operates for EU consumers. Include checkout flows, account dashboards, support portals, help docs and marketing pages.
2. Identify your legal entity structure. The EAA obligates manufacturers, importers, distributors and service providers differently. A US SaaS selling to EU consumers is a service provider and must comply directly.
3. Confirm the applicable standard. For almost all digital services, the standard is WCAG 2.2 AA via EN 301 549. Document this decision.
Phase 2 — Audit (Week 2–6)
4. Run automated scanning as a baseline. Tools like axe DevTools, Lighthouse, WAVE and Pa11y will catch 30–40% of WCAG issues — mostly machine-checkable ones like color contrast, missing alt attributes and ARIA syntax errors. This is necessary but not sufficient.
5. Commission an expert manual audit. The 60–70% of issues automated scanners miss — meaningful alt text, logical reading order, keyboard flow, screen reader experience, error recovery — require human evaluation. A professional WCAG 2.2 AA audit maps each finding to a specific success criterion and delivers a stakeholder-ready PDF report.
6. Test with assistive technologies. At minimum, test primary user flows with:
- NVDA + Firefox (most common free screen reader on Windows)
- JAWS + Chrome (dominant screen reader in enterprise environments)
- VoiceOver + Safari (iOS and macOS)
- Keyboard-only navigation (no mouse, no trackpad)
- 200% browser zoom and 400% in reflow mode
7. Include user testing with people with disabilities. WCAG conformance is a floor, not a ceiling. Testing with real users surfaces usability issues that no automated or expert audit will catch.
Phase 3 — Remediation (Week 4–20)
8. Prioritize by severity and user impact. Not all issues are equal. A keyboard trap on your checkout page is critical; a slightly imperfect heading hierarchy on a marketing page is not. Categorize findings as Critical / Major / Minor and sequence accordingly.
9. Fix root causes, not symptoms. Avoid accessibility overlay widgets that try to patch issues at runtime — they do not create EAA conformance and are widely rejected by the accessibility community.
10. Embed accessibility in your development process. Add axe-core to CI, create accessible component patterns in your design system, require accessibility acceptance criteria on every ticket. A one-time audit decays in months without process.
Phase 4 — Documentation (Week 16+)
11. Publish an accessibility statement. The EAA requires service providers to publish a clear statement covering: the applicable standard, conformance level, any non-conforming content with justification, accessibility feedback mechanism and enforcement procedure contact.
12. Maintain a VPAT / ACR. A Voluntary Product Accessibility Template (VPAT) documents your conformance at a success-criterion level. Enterprise buyers and public-sector procurement teams will ask for it. Update at each major release.
The Most Common EAA Compliance Gaps
Across the hundreds of audits published under the EAA in the past year, the same issues come up repeatedly:
- Insufficient color contrast on secondary buttons, placeholder text, inline links and disabled states (WCAG 1.4.3)
- Missing or unhelpful alt text on product images, icons and infographics (WCAG 1.1.1)
- Form fields without programmatic labels — especially modern floating-label patterns that break in screen readers (WCAG 1.3.1, 3.3.2)
- Keyboard traps in custom modals and dropdowns (WCAG 2.1.2)
- Missing focus indicators after CSS resets strip the default outline (WCAG 2.4.7)
- Non-semantic markup — div soup with ARIA bolted on instead of native HTML elements (WCAG 4.1.2)
- Inaccessible custom components — date pickers, comboboxes, toast notifications built from scratch without ARIA patterns (WCAG 4.1.2)
- Video without captions or audio descriptions (WCAG 1.2.2, 1.2.5)
- Dynamic content changes not announced to screen readers (WCAG 4.1.3)
See our overview of accessibility compliance for small businesses for remediation approaches to each of these.
What About Existing Content and Legacy Systems?
The EAA provides a transition period: services already in use before 28 June 2025 have until 28 June 2030 to come into full conformance. That sounds generous, but there are important caveats:
- Any new service launched after 28 June 2025 must comply from day one
- Any substantial change to an existing service resets the clock
- The 2030 deadline is not a safe harbor — complaints can be filed today, and regulators are already acting on them
- Commercial reality (enterprise RFPs, procurement requirements) is moving faster than the regulatory deadline
How Accessibility Compounds Into Business Value
Treating EAA compliance as pure overhead misses the point. Accessible products perform better for all users:
- SEO uplift: Semantic HTML, alt text, clear heading hierarchy and captions directly feed search ranking signals
- Conversion lift: Inclusive design research consistently shows 10–20% conversion improvements on accessible sites — see our analysis of how inclusive design boosts conversions
- Market reach: Roughly 15% of the global population lives with some form of disability; many more benefit from accessible design temporarily or situationally
- Brand reputation: Accessibility lawsuits and public compliance lists are indexed by search engines — non-compliance is a lasting brand issue
Next Step: Audit Your Site This Quarter
If you have not formally audited your website against WCAG 2.2 AA in the past 12 months, the fastest way to understand your exposure is a structured audit that maps each issue to a specific success criterion and delivers a PDF report you can share with stakeholders, legal teams and clients.
Heurilens is launching a dedicated Accessibility Audit that combines automated WCAG 2.2 AA scanning with expert review, screen reader testing and a prioritized remediation plan. Built for agencies, e-commerce operators and SaaS teams who need EAA-ready documentation without a multi-week consultancy engagement. Join the waitlist to get early access and a launch-day discount.
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