Having come into force in late June, the EAA is about to shake up the digital landscape as we know it. Digital Design Director Tom Alexander outlines what the legislation means for businesses today – and where to begin with the thorny question of compliance.
With more than 100 million people living with a disability in the EU today, the focus of the European Accessibility Act (EAA) couldn’t be clearer: to remove barriers to digital accessibility and create a more inclusive digital world. Put simply, it’s designed to harmonise accessibility requirements across the EU, improve the availability of accessible products and services, and create equity for the elderly and people with disabilities.
And as legislation that covers everything from websites and apps to smartphones and PDFs, it will have far-reaching consequences for those working in
So which businesses will be impacted? The EAA applies to every business that targets EU consumers, even non-EU companies (like those in the UK or US). What’s less clear is whether B2B organisations are exempt, but the consensus seems to be to proceed with caution. If your website includes ESG content, investor content or careers pages – anything that might be accessed for someone’s personal interest – you might find yourself falling under the EAA requirements.
There are some exemptions, though:
- Microenterprises: Businesses with fewer than 10 employees or a turnover of less than €2 million that don’t manufacture products with obligations for product accessibility are exempt.
- Pre-existing digital content: Content available before 28 June 2025 doesn’t need to be fully accessible until 2030. But any new updates or changes made after 28 June 2025 must follow the EAA accessibility rules. Some older content might be exempt if fixing it’s too difficult or expensive, but businesses must be able to prove this if asked.
What do the requirements actually cover?
The EAA directive follows the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, along with technical standards outlined in EN 301 549. These are generally considered the gold standard when it comes to accessible digital design, and include things like:
- Sufficiently descriptive alt tags for imagery.
- Captions and transcripts for video and audio content.
- Consistent semantic HTML and appropriate ARIA roles.
- Strong colour and text contrast.
- Media player controls that pause, stop or hide auto-play content.
- Clear descriptive labels, form fields, tables and clear error messaging.
- Logical page structures with readable content.
- Properly tagged PDFs and documents.
- Keyboard navigability and compatibility with screen readers.
- An accessibility statement which includes compliance status.
What are the penalties for failing to comply?
The consequences can be serious.
- Legal penalties: Fines and enforcement actions vary by country but can hit the €500,000 mark.
- Blocked market access: Products or services could be removed from the EU market.
- Consumer complaints: Users can take legal action over accessibility barriers.
- Reputational damage: Non-compliance can undermine brand trust and shake investor confidence.
Why is this such an important piece of legislation?
The EAA isn’t a box-ticking exercise or a bureaucratic formality; it’s an opportunity to improve how your business communicates and expand the number of people accessing your content. And there are strategic benefits to bear in mind too.
Harmonising accessibility rules across the EU significantly reduces the complexity and cost of complying with a mixed bag of different national regulations. It also strengthens brand reputation and extends your reach to individuals reliant on accessible digital experiences.
