The European Accessibility Act (EAA) – Must Haves, Should Haves and Would Haves

Helen Burge , Director of Accessibility

February 18th, 2025

As the Director of Accessibility at Testlio, my hope with this article is to help you understand what the EAA is, what you need to think about, and how you can prepare. 

Why Does Accessibility Matter?

The most important part of the EAA is making sure your users are not disabled by your content. Accessibility helps everyone who might have a moment (lack of sleep, so blurry eyes), temporary (broken arm that will mend but less movement), or permanent (no eyesight) disability. It is important to not stop any potential client from using your services as it can cause not only a potential loss of revenue but also a potential loss of goodwill. 

What Services Are Included In The EAA?

• Computers
• Smartphones
• Ebooks
• PDFs
• Electronic documentation
• Televisions
• Public services
• Automated telling machines
• Ticketing machines
• Transportation
• Banking
• E-commerce sites

Who Is Responsible For Meeting The Guidelines?

It is not about where you are based but where you trade. If you are providing any of the above items in an EU country and have more than 10 employees and a turnover of €2 million per year, the EAA applies to you. Items being sold, maintained, or created after June 2025 are in scope to be accessible to the public. 

What Are The Guidelines To Be Followed?

Most people will agree that EN 301 549 should be covered. However, for software, most guidelines point to the Web Content Accessibility Guidelines (WCAG) version 2.1, with some checks for documentation. The EAA is more about each country enforcing accessibility, but how you measure accessibility is not prescriptive on how you meet user needs.

So try to follow EN 301 549 to check your products for accessibility.

Do I Need An Accessibility Statement?

Not for the EAA, but it might be helpful to have one. The EAA directive refers to companies having publicly available proof of how they ensure accessibility compliance.

Since it’s the simplest way to share information, several accessibility vendors have told audiences that an EAA directive requires them to have an accessibility statement on their website. This statement could include what guidelines you have tested against, known issues or methods to navigate, and how to contact your company if a user wants to share feedback.

However, this is not a mandate set by the EAA. It could be mandated by a country enforcing EAA. Still, the main purpose of the EAA directive is to ensure you have evidence that accessibility work is being carried out on your products. This can be an audit report you share, an Accessibility Conformance Report (ACR), or an accessibility statement. 

What Are The Different Laws I Must Be Aware Of When Trading In Europe?

There are 27 member states of the EU, and each has its own laws and regulations on enforcing the EAA. Some countries have financial penalties, and others include jail time. How the penalties are set will vary on how they find the faults, notify you of the findings, and what timelines and processes they have in place to let you address the concerns. It is not likely that a financial penalty will be issued upon finding a fault with your service. For specific details on compliance, you should refer to the Web Accessibility Laws & Policies list for the countries you trade in. 

How Will The EAA Be Enforced?

Since each country is responsible for enforcing EAA in its own way, its regulatory processes and department structure will vary from others. However, all countries have designated departments for monitoring, reporting, and enforcement, whether as separate teams or operating under a single team. 

Generally, it is more likely a user will report you to the governing body, which investigates the report and then passes it on to the enforcement team to notify you of the findings, the next steps, and the timeframe you have to address the issue. However, the monitoring team could still investigate you without a user complaint.

Conclusion

Focusing on being compliant with no blockers for users is the best way to ensure you do not have any legal proceedings started in any of the 27 member states of the EU. To achieve this, it’s important you understand your users and test your software in environments reflective of their real-world conditions. 

Testing these in-the-wild scenarios isn’t just comprehensive but also complex to manage with in-house teams alone. This is where Testlio can help. Our accessibility testing solutions are customized to your unique needs, including region-specific compliance requirements. 

With a highly-vetted global network of testers, we help brands audit their digital experiences for accessibility in real-world scenarios across 150+ countries and 600K+ devices. Every engagement is supported by our industry-leading client services team, who ensure you receive actionable insights and strategic guidance to address accessibility issues proactively and reduce the potential risk from evolving regulations and laws. 

Reach out to a member of our team to learn how we can help you deliver digital experiences that aren’t just accessible but also intuitive, reliable, and optimized for every user journey.