EAA Compliance Guide for European Websites

The European Accessibility Act (Directive 2019/882) became enforceable across EU member states on 28 June 2025. Almost a year in, enforcement is underway and the message from regulators is clear: they are prioritising visible non-compliance and missing accessibility statements. French regulators have already filed cases against four grocery retailers, Sweden's PTS has begun e-commerce audits, and the Netherlands' ACM is prioritising non-reporters. This guide is the short version of what your team needs to know.

What is the EAA, exactly?

The EAA is an EU directive that harmonises accessibility requirements for products and services sold in the European single market. It was adopted in 2019 with a six-year transposition window, which is why most companies only started paying attention in 2024. Each member state has now written its own national law: Germany's BFSG, France's adaptation of articles L412-13 and following of the Code de la consommation, Portugal's Decreto-Lei n.º 82/2022, and so on - but they all implement the same baseline.

The technical baseline for websites is EN 301 549, the European standard for ICT accessibility. EN 301 549 in turn references WCAG 2.1 Level AA as the criterion for web content. So when someone asks "what does EAA compliance mean for my website?", the practical answer is: meet WCAG 2.1 AA.

Who has to comply?

The EAA applies to a defined list of products and services, not to "all websites". For digital products it covers:

• E-commerce sites that sell to consumers in the EU
• Banking services and consumer financial services
• Passenger transport services (booking, tickets, real-time travel info)
• E-books and dedicated reading software
• Audiovisual media services and access services
• Telecoms services and consumer terminal equipment

There is a microenterprise exemption for service providers with fewer than 10 employees and an annual turnover or balance sheet under €2 million. If you're a tiny SaaS, read this carefully. The exemption applies to services, not to products. And there is no exemption from the EAA's labelling and information obligations even for microenterprises that sell exempt products.

If you sell to consumers in the EU and you don't fit a clear exemption, assume you are in scope.

What does compliance look like in practice?

For the typical web team, EAA compliance means three things:

1. Your site meets WCAG 2.1 AA. That's 50 success criteria across the four POUR principles (Perceivable, Operable, Understandable, Robust). Around 30 of them can be tested automatically with tools like axe-core; the rest require manual review.
2. You publish an accessibility statement. EN 301 549 §6.2 requires a documented, public statement describing your conformance status, any non-conformant content, the contact channel for accessibility complaints, and the date of the most recent review.
3. You can demonstrate ongoing monitoring. Member states' market surveillance authorities can ask you to show evidence that accessibility is part of your development process. In practice, that means scheduled scans, an issue backlog, and a rough remediation cadence.

The fines

Fines vary by member state, but they are not symbolic:

• France can fine up to €250,000 per infringement, with daily penalties for ongoing non-compliance.
• Germany's BFSG allows fines up to €100,000 per case.
• Norway fined a health-app vendor €5,360 per day until the issues were resolved.
• Portugal, under Decreto-Lei n.º 82/2022, can impose contra-ordenações up to €44,891.81 for very serious violations.

The message from regulators in 2025 has been consistent: they are not prioritising "perfect" compliance, they are prioritising visible non-compliance and missing accessibility statements. A site with a documented statement and a remediation backlog is treated very differently from a site with no statement at all.

How to start

If your website has never been audited, this is the realistic minimum first sprint:

1. Run an automated baseline scan of your top 10 pages - homepage, signup, checkout, account, and the highest-traffic landing pages from your analytics. Tools like axe-core, WAVE, or the free mandatiq scanner catch the obvious issues: missing alt text, low contrast, unlabelled form fields, missing landmarks. This is ~70% of the violations on most sites and you can fix them in days.
2. Triage the rest manually. Keyboard navigation, focus order, screen-reader labels on custom widgets, and visible focus indicators are the high-impact items that no scanner will catch reliably. Budget half a day with a real screen reader (NVDA on Windows, VoiceOver on macOS - both free).
3. Publish your accessibility statement. Do this even if your site isn't fully compliant yet. A statement that says "we conform to WCAG 2.1 AA except for these four issues, which we plan to fix by Q3" is worth more legally than no statement at all.
4. Schedule recurring scans. Weekly is overkill; monthly is the sweet spot for most teams. The point is to catch regressions before they accumulate.

Where to go from here

The EAA is not going away, and 2026 is when most regulators start their first proactive audit cycles. The teams that ship now spend a few days per quarter on accessibility maintenance. The teams that wait spend weeks recovering from a complaint.

If you'd like a snapshot of where your site stands today, run a free WCAG 2.1 AA scan. We'll show you your top violations and the WCAG criteria they map to — no signup needed.