The European Accessibility Act (EAA) has been enforceable since June 28, 2025.
That is not a warning date. It is not a soft launch. Enforcement is live, fines are real, and regulators across Europe have already begun sending notices to businesses that failed to act.
European Accessibility Act compliance is now a legal requirement for most private companies selling digital products or services to customers in the EU. This includes businesses based outside Europe. If your website, app, or digital service has European users, this law applies to you.
This guide covers everything you need to know: who must comply, what the technical standard requires, how fines are structured across EU member states, what happened in the first months of enforcement, and how to build an action plan that gets you compliant fast.
Key Takeaways
- The EAA has been in force since June 28, 2025. All new products and services must comply now. Existing services have until June 28, 2030.
- The technical compliance standard is EN 301 549 v3.2.1, which incorporates WCAG 2.1 Level AA in full.
- The EAA covers private sector businesses, including ecommerce, banking, transport, telecoms, and digital media services.
- Non-EU businesses serving EU customers must also comply.
- The only exemption is microenterprises providing services: fewer than 10 employees and under €2 million annual turnover. Product manufacturers must comply regardless of size.
- Fines vary by country and can reach €1,260,000 (Hungary) or €1,000,000 (Spain). Daily penalties for ongoing violations can add up fast.
- France, Germany, and Norway are already enforcing. Major retailers received formal notices in late 2025.
- You need a published accessibility statement. It is mandatory under the EAA.
- An accessibility audit followed by remediation is the fastest path to compliance.
What Is the European Accessibility Act?
The European Accessibility Act is an EU Directive (2019/882) that sets harmonized accessibility requirements across all 27 EU member states. Its goal is to remove the patchwork of national accessibility laws and replace them with a single standard that applies across the bloc.
The key word is “harmonized.” Before the EAA, companies operating across Europe had to navigate different rules in different countries. Germany had one standard, France had another, and Spain had a third. The EAA ends that fragmentation.
The EAA covers both physical and digital products and services. For digital compliance, the standard is EN 301 549, which maps to WCAG 2.1 Level AA.
The law was adopted in 2019, transposed into national laws by member states by June 2022, and became enforceable on June 28, 2025. Existing services have until June 28, 2030, to achieve full compliance, but all new products and services must meet the standard from day one.
Who Must Comply with the EAA?
This is where many businesses get confused. The EAA is not just for government agencies or large corporations. It applies to private companies of almost any size.
You must comply if you:
- Sell or provide covered products or services to customers in any EU member state
- Operate a website, mobile app, or digital platform serving EU users
- Provide ecommerce, banking, transport, telecommunications, or media services in the EU
- Are based outside the EU but serve EU customers
The scope is intentionally broad. A company headquartered in the US, India, or Australia that sells to German or French customers must meet EAA requirements.
The only exemption that applies to most small businesses is the microenterprise rule for service providers: fewer than 10 employees AND annual turnover or balance sheet under €2 million. If you are a service-based micro-business below both thresholds, you are exempt.
This exemption does NOT apply to product manufacturers. A hardware company with 8 employees still must comply.
What Digital Products and Services Does It Cover?
The EAA’s digital scope covers more than just websites. Here is what falls under the law:
Websites and mobile apps for covered sectors are the most common compliance concern. If your website takes payments, delivers services, or provides content to EU users, it is in scope.
Ecommerce platforms must have accessible product listings, checkout flows, cart updates, payment forms, error messages, and order confirmations. This includes embedded third-party payment tools like Stripe or PayPal.
Banking and financial services including online banking portals, investment platforms, and insurance services must be accessible.
Transport services including airline booking sites, rail ticketing, real-time travel information, and transport apps are covered.
Telecommunications services including broadband, VoIP, and associated apps are in scope.
E-books and digital publishing platforms must provide accessible reading experiences.
Audiovisual media services including on-demand streaming platforms fall under the EAA.
If your business falls into any of these categories, European Accessibility Act compliance is not optional.
What Is EN 301 549 and How Does It Relate to WCAG?
EN 301 549 is the European harmonized standard for ICT (Information and Communications Technology) accessibility. It is the official technical benchmark for EAA compliance.
The current version is EN 301 549 v3.2.1. Its web chapter incorporates WCAG 2.1 Level A and Level AA success criteria in full. This means:
- If your website meets WCAG 2.1 Level AA, you meet the web-related requirements of EN 301 549.
- If you have a WCAG 2.1 AA audit report and conformance documentation, you have the evidence base for EAA compliance.
However, EN 301 549 goes further than WCAG in some areas. It includes requirements for hardware accessibility, software running on devices, ATMs, ticketing kiosks, and real-time communication tools. For most web and mobile teams, WCAG 2.1 AA is the practical target.
WCAG 2.2 is not yet mandated by the EAA, but adopting it is wise. It adds important criteria including better focus indicator requirements (WCAG 2.4.11 Focus Appearance) and drag-and-drop alternatives (WCAG 2.5.7).
EAA Enforcement Has Started: Real Examples from 2025 and 2026
The first months of EAA enforcement made clear that regulators are not bluffing.
France moved first. In November 2025, the DGCCRF (France’s consumer protection agency) sent formal enforcement notices to four major retailers: Auchan, Carrefour, E.Leclerc, and Picard. Inspections found systematic failures including broken keyboard navigation, missing alternative text for product images, and non-compliant checkout flows. These are exactly the issues that a WCAG 2.1 AA audit would have identified and fixed.
Germany saw a wave of private warning letters (called Abmahnungen) within weeks of the national EAA law (BFSG) taking effect in August 2025. German law allows competitors and advocacy groups to send enforceable warning letters for accessibility violations, making enforcement faster and broader than government-only action.
Norway (which applies the EAA through the EEA agreement) imposed daily fines on the HelsaMi health portal operated by Norsk Helsenett for persistent keyboard accessibility failures. The fine was NOK 50,000 per day (approximately €4,500). By December 2025, the accumulated total had exceeded NOK 3,500,000, which is over €315,000. This is the clearest signal of what ongoing non-compliance costs.
The pattern is clear. Regulators are targeting the most visible failures first: missing alt text, broken keyboard navigation, and inaccessible checkout flows. These are also the most common WCAG failures, which means most non-compliant sites are already on the radar.
EAA Fines by Country: What You Actually Risk
The EAA requires member states to set penalties that are “effective, proportionate, and dissuasive.” Each country set its own fine structure. Here is a summary of key markets:
Germany: Up to €100,000 per violation under the BFSG. Private Abmahnungen can add legal costs on top of regulatory fines.
France: €5,000 to €250,000 per violation. An additional €25,000 per year for failing to publish a required accessibility statement.
Spain: Tiered fines ranging from €301 for minor infractions up to €1,000,000 for very serious violations. Authorities can also suspend business activity for up to three years.
Hungary: Up to €1,260,000. One of the highest caps in the EU.
Sweden: Approximately €900,000 maximum.
Netherlands: Up to €250,000.
Finland: Up to €150,000.
Ireland: Up to €60,000.
Daily penalties for ongoing non-compliance are available in several member states and can reach €1,000 per day. The Norway example above shows how daily fines compound into very large totals quickly.
For businesses with revenue in multiple EU countries, the same violation could trigger enforcement in multiple jurisdictions. This is not theoretical. The EAA explicitly allows member state authorities to coordinate enforcement across borders.
EAA vs ADA vs Section 508: How They Compare
If you are already managing ADA compliance for your US audience, understanding how the EAA fits in is important.
ADA (Americans with Disabilities Act): A civil rights law covering US businesses. For websites, the DOJ’s 2024 rule under Title II requires WCAG 2.1 Level AA for state and local government entities. Private businesses use WCAG 2.1 AA as the accepted benchmark in litigation.
Section 508: Applies to US federal agencies and their contractors. Based on WCAG 2.0, with the 2017 Refresh bringing it up to date.
EAA: Covers private sector businesses across all 27 EU member states, plus non-EU businesses serving EU customers. Requires EN 301 549, which maps to WCAG 2.1 Level AA.
The practical implication for most businesses: WCAG 2.1 Level AA is the shared technical baseline across all three frameworks. Achieving WCAG 2.1 AA gets you very close to compliance with all three, though the documentation requirements (VPAT for US contracts, accessibility statement for EAA) differ.
For a full breakdown of how these frameworks interact, read our guide: Which Accessibility Framework Actually Matters?
What Your Website Actually Needs to Meet EAA Standards
Achieving European Accessibility Act compliance at the WCAG 2.1 AA level means addressing issues across four categories: perceivable, operable, understandable, and robust content.
Here are the most critical requirements most websites fail on:
Color contrast is the single most common failure. Normal text needs a contrast ratio of at least 4.5:1 against its background. Large text (18pt or 14pt bold and above) needs 3:1. The 2026 WebAIM Million report found contrast failures on 83.9% of websites.
Alternative text for images is required for all meaningful images. Decorative images should have empty alt attributes (alt=””). Product images, infographics, and buttons with icons need descriptive alt text that conveys the same information a sighted user would get.
Keyboard accessibility means every function on the site must work without a mouse. Forms, menus, modals, carousels, and checkout steps must all be navigable using Tab, Enter, Space, and arrow keys.
Focus indicators must be visible. When a keyboard user tabs through the page, a clear visual indicator must show which element has focus. Removing the default browser outline without providing a replacement is a WCAG violation.
Form labels must be programmatically associated with their inputs. Placeholder text alone does not qualify. Every input needs a <label> element that stays visible and is announced by screen readers.
Error messages must be specific and actionable. “Invalid entry” fails. “Please enter a valid email address, for example name@example.com” passes.
Page titles must be unique and descriptive. Every page on your site should have a title that identifies both the page content and the site name.
Language attributes must be set on the <html> element so screen readers use the correct pronunciation.
Video and audio content must include captions (for pre-recorded video), audio descriptions (where video content conveys information not available in the audio), and transcripts.
ARIA use must be correct. Incorrect ARIA is worse than no ARIA. Use native HTML elements first and add ARIA only where native semantics are insufficient.
These requirements apply equally to your checkout pages, product listings, customer account areas, and any third-party embedded tools your site uses.
The EAA Accessibility Statement: What to Include
Publishing an accessibility statement is a legal requirement under the EAA. It must be published on your website and kept up to date.
Your accessibility statement must include five core elements:
1. Compliance status. Declare whether your site is fully compliant, partially compliant, or not yet compliant with EN 301 549 / WCAG 2.1 AA. Be honest. Partially compliant with a remediation timeline is far better legally than claiming full compliance when you are not.
2. Known inaccessible content. List what is not yet accessible and explain why. Acceptable reasons include: the content is exempt (archived), the content is third-party and outside your control, or remediation is in progress with a stated timeline.
3. Remediation timeline. If you have known issues, state when they will be fixed. This shows good faith and reduces regulatory risk.
4. Contact information. Provide a way for users to report accessibility issues and request accessible alternatives. This should be a working email or contact form, not a generic catch-all address.
5. Standard and version. Name the standard (EN 301 549 v3.2.1, WCAG 2.1 Level AA), the version of the product or service tested, and the date of the most recent assessment.
In France, failing to publish an accessibility statement at all carries an additional fine of €25,000 per year, separate from the main penalties for inaccessible content.
Your EAA Compliance Action Plan
Here is a practical step-by-step plan to achieve European Accessibility Act compliance.
Step 1: Run an accessibility audit. Start with a professional accessibility audit that covers both automated scanning and manual testing. Automated tools catch roughly 30-40% of issues. Manual testing by accessibility experts, including testing with screen readers like JAWS, NVDA, and VoiceOver, is required to catch the rest. The audit gives you a full picture of your compliance gaps and a prioritized remediation list.
Step 2: Fix critical issues first. Not all failures carry equal risk. Start with issues that block users from completing key tasks: inaccessible checkout, broken form submission, missing alt text on product images, and keyboard traps. These are also the issues regulators are targeting first.
Step 3: Remediate systematically. Work through your audit findings methodically. Accessibility remediation should be part of your development workflow, not a one-time fix. Build accessibility requirements into your design system, component library, and QA process.
Step 4: Test with real users. Involve people who use assistive technologies in your testing process. Screen reader users and keyboard-only users will identify issues that automated tools and sighted testers miss.
Step 5: Publish your accessibility statement. Once you have completed your audit and begun remediation, publish your accessibility statement. Update it as you fix issues.
Step 6: Set up ongoing monitoring. Accessibility is not a one-time project. New pages, new features, and third-party updates can introduce new barriers. Accessibility monitoring and governance keeps you compliant as your site evolves.
Step 7: Document your conformance. Consider producing a VPAT or ACR (Accessibility Conformance Report) to document your compliance status formally. This is especially valuable if you sell to enterprise customers or government entities who require procurement documentation. See our VPAT and ACR documentation service.
If you are an ecommerce business, our eCommerce accessibility specialty page covers the specific requirements for product listings, cart flows, and checkout steps.
Not sure where to start? Contact HalfAccessible for a free consultation.
The Bottom Line
European Accessibility Act compliance is live. Enforcement has started. France, Germany, and Norway have already sent notices and imposed fines.
The standard is WCAG 2.1 Level AA via EN 301 549. If you have EU customers and a website, app, or digital service, you are in scope. The microenterprise exemption is narrow. Waiting for 2030 carries real legal and reputational risk.
The fastest path forward is a professional accessibility audit to identify your gaps, followed by systematic remediation, an accessibility statement, and ongoing monitoring.
HalfAccessible helps businesses of all sizes achieve and maintain EAA compliance. Start with our accessibility audit services or contact us to discuss your situation.
