The European Accessibility Act has been enforceable since 28 June 2025 and reaches any company selling covered services to EU consumers — including companies outside the EU. To get ready: document your covered journeys, target WCAG 2.1 AA, test priority journeys with keyboard and screen readers, fix shared components first, and publish an accessibility statement.
Need it done for you? Book an EAA readiness review — we audit your priority journeys, document findings for your legal team, and deliver a fixed-price remediation plan.
Does the European Accessibility Act apply to your website?
The EAA, formally Directive (EU) 2019/882, covers consumer-facing digital services: e-commerce websites and apps, banking and financial services, transport booking and ticketing, telecom services, e-books and media platforms. The trigger is where you sell, not where you are headquartered — a US, UK or UAE company serving EU consumers is in scope exactly like an EU company. The first EAA lawsuits were filed in France in November 2025, and the Dutch authority ACM is already testing checkouts worldwide.
Before doing anything technical, build a six-question applicability record and hand it to qualified counsel. Counsel decides whether the Act applies; your job is to give them facts, not conclusions:
- Who uses each public journey? Record whether it serves consumers, businesses, staff or partners. Include the route, its purpose and a current screenshot.
- What can a visitor complete? List purchases, bookings, payments, applications, registrations and account tasks. Keep transactional and informational journeys separate.
- Where is the service offered? Record the markets selectable during checkout, booking, delivery or account creation. Website language alone does not establish the service area.
- Which entity provides the service? Name the contracting or operating entity so counsel gets organisation facts, not assumptions.
- When did material features change? Record the original launch, significant releases and the build now in production, each tied to a release record.
- Which third parties enter the journey? Identify payment, booking, identity, chat, video, consent and document components — and who can change each one.
Ask counsel a precise question: which laws and national implementations apply to these recorded services, and which technical standard and version should the project adopt? Reopen the decision whenever the facts change — adding checkout, public booking or a new served market changes the service profile that was reviewed. Microenterprises (fewer than 10 employees and under €2 million annual turnover) are exempt from the EAA's service obligations in most transpositions, but confirm your status rather than assuming it.
For the enforcement picture behind this urgency, see our European Accessibility Act enforcement data. Our EAA accessibility compliance service overview explains how a structured assessment works.
What technical standard should you target?
The EAA's harmonised technical standard is EN 301 549 — currently version 3.2.1 as the presumptive standard of conformity, with v4.1.1 expected to take over. It incorporates WCAG 2.1 Level AA in full. In project terms, WCAG 2.1 AA means a defined, testable set of criteria across four principles: content must be perceivable (contrast, alt text, captions), operable (keyboard access, visible focus, no traps), understandable (clear labels, error messages, consistent navigation) and robust (valid markup that assistive technology can parse).
Practically, that translates into: 4.5:1 colour contrast for normal text, full keyboard operability of every interactive element, meaningful headings and link text, labelled form fields, descriptive alternative text for images, and error messages that screen readers announce. Because the same WCAG 2.1 AA benchmark is what US courts use under the ADA — where 4,928 digital accessibility lawsuits were filed in 2025 — one target covers both exposures. Get the standard, version and jurisdictions frozen in writing with counsel before design, code or content acceptance criteria are created.
Teams coordinating a wider launch can pair this with our Core Web Vitals 2026 launch checklist, and SEO-friendly web development builds accessibility into the same QA pass as performance and indexing.
How do you audit a website for EAA readiness?
Turn the approved target into assigned work with an acceptance register — one owner per area, one pass/fail test per item, one piece of evidence per result:
| Owner | Area | Pass/fail test | Evidence to keep |
|---|---|---|---|
| Design | Colour, focus, error states, resizing, narrow layouts | Test every approved component and state against its cited criterion | Token reference, annotated screenshot, viewport, citation |
| Code | Keyboard navigation, names, relationships, dialogs, messages, focus movement | Operate the rendered component with the inputs and assistive technology named in the plan | Route, build, browser, assistive technology, steps, defect link |
| Content | Headings, links, alternatives, labels, instructions, errors | Review the rendered page, including generated and translated states | Page checklist, reviewer, date, screenshot, correction |
| QA | Complete priority journeys | Finish each task with every method the approved plan requires | Step log, environment, failures, retest, acceptance record |
| Legal owner | Applicability and target | Confirm or reject the conclusion against retained authoritative sources | Dated instruction, jurisdiction, source URL, review trigger |
Keyboard navigation means completing interactive tasks without a pointing device. A useful record covers focus order, visible focus, unreachable controls, keyboard traps, dialogs, validation and the route back from an error. A successful Tab sequence on the homepage proves nothing about checkout or booking — test complete journeys. For numerical checks such as contrast ratios, retain the colours and states tested, the tool and version, the measured result and the approved threshold. The WebAIM Million 2025 report found 94.8% of top homepages fail basic WCAG checks, with low contrast on 79.1% of pages — these are the defects the register is designed to catch systematically.
Our technical SEO audit surfaces the template-level issues an accessibility audit will also flag, and the website development process shows how audit phases fit a build timeline.
How do you test the journeys that matter most?
Walk a realistic scenario end to end — for example, a visitor who selects an appointment, enters contact details, corrects an error and receives confirmation:
- Open the service page. Record whether the title, heading, explanation and next action form a meaningful sequence.
- Choose a service. Reach and operate the selector by keyboard; compare the visible wording with what the screen reader announces.
- Select a date and time. Record focus order, instructions, unavailable choices and selected state; flag anything requiring a pointer.
- Enter contact details. Compare visible labels with conveyed field names and pre-submission instructions.
- Trigger an error. Leave one required field incomplete; record focus position, the conveyed message and the route back to the field.
- Submit. Record whether the control operates and how processing, success or failure is communicated.
- Read the confirmation. Check that the service, date, time, contact route and next action remain available.
A defect record should read like evidence: build number, route, browser and assistive technology, input method, the steps that passed, the step that failed and why, the assigned ticket. Preserve the original failure after correction — append the replacement build, the changed behaviour, the tester and the retest result — so a reviewer can distinguish a repaired defect from an unsupported declaration. This evidence pack is what regulators and litigators ask for first.
As the Peculiar Systems review of 15 months of EAA enforcement put it: "Regulators read the terms first. Customers start at the checkout." Test the checkout like a customer and document it like a regulator. Our web accessibility compliance guide covers the full testing methodology.
Should you remediate the existing site or rebuild?
Most sites can be remediated — rebuilding is justified only when recorded constraints make corrections unsafe, temporary or impractical. Decide from evidence after the audit, not from a supplier's preference for a larger engagement:
| Observed condition | Response | Decision evidence |
|---|---|---|
| A shared navigation, form or dialog fails across many routes and can be changed centrally | Remediate the component, retest every affected journey | Component inventory, corrected build, route-level retests |
| Most findings are headings, link wording, alt text or labels | Run governed content remediation first | Content inventory, ownership list, corrected pages |
| A third-party booking or payment component blocks completion with no supported fix | Escalate to the vendor, assess replacements | Reproduction steps, vendor response, integration constraints |
| Duplicated, unowned templates cannot receive a reliable global correction | Compare controlled template replacement with a wider rebuild | Template count, regression risk, migration scope, test plan |
| The CMS cannot store the labels, alternatives or relationships needed | Change the content model or platform layer | Model gap, proposed fields, migration test, editor workflow |
Group findings into shared components, page-specific content and third-party dependencies: fixing one owned component can repair dozens of journeys, while rebuilding surrounding layouts may leave a defective booking provider untouched. If a rebuild wins, protect your rankings with the website redesign SEO migration checklist, and scope the work through custom web application development or core web development services.
What goes into an accessibility statement?
An accessibility statement is a public account of your service's assessed status, known limitations, feedback route and review history. Draft it with legal, technical and content owners together:
- Service identity: name the website or digital service and the responsible organisation.
- Target and assessment: state only the standard, version, scope and result your retained records support.
- Known limitations: describe each unresolved barrier, the affected journey, the available alternative, the owner and the review point.
- Feedback route: provide a monitored contact method and ask for details that help reproduce a barrier.
- Assessment method: state whether testing was internal, independent or combined, with the assessment date.
- Escalation information: add a jurisdiction-specific route only after qualified review verifies it.
- Review history: record substantive changes without cosmetically refreshing the displayed date.
This is not finished statement copy — it is a drafting control. Counsel must confirm where the statement is legally required, what it must contain and where it must be linked. Use a stable URL and keep it reasonably discoverable. Note that Czechia's first EAA fines cited a missing accessibility paragraph in shop terms: the paperwork is inspected too.
Multilingual teams should also review the multilingual website architecture guide — statements, labels and error messages must work in every language you serve.
What does a compliant pre-launch workflow look like?
- Freeze the approved standard, version, criteria, jurisdictions and sources.
- Inventory priority routes, states, shared components and third-party boundaries.
- Run automated checks; retain the tool version, ruleset, build and output.
- Run keyboard-navigation tests through complete tasks.
- Run screen-reader tests with the combinations named in the plan.
- Test approved zoom and narrow-layout conditions.
- Correct findings and append retest evidence without deleting the initial failures.
- Obtain independent, legal and business-owner review.
Automated checks are a defect feed, not a verdict — they catch roughly a quarter to a third of real barriers. Human testing covers meaning, reading order, focus behaviour, error recovery and complete task performance. Neither method is a legal opinion. Keep the accessibility evidence pack separate from performance evidence, and give the legal owner applicability and governing sources, the technical owner component coverage and build identifiers, QA the environments and results, and the content owner headings, alternatives, labels and statement copy.
Frequently asked questions
Who decides whether the EAA applies to our website?
Qualified counsel or an authorised legal owner, working from verified official and national sources. A digital agency can document your website and implement an approved target, but it should not issue the legal conclusion.
What accessibility standard should we use?
EN 301 549 v3.2.1 is the current harmonised standard, incorporating WCAG 2.1 Level AA in full. Freeze the standard, version and jurisdictions in writing with counsel before creating acceptance criteria.
Can an automated scan prove our website passes?
No. Automated checks detect roughly a quarter to a third of real barriers. Follow them with keyboard-navigation and screen-reader testing of complete journeys, and retain the manual results as evidence.
Can we remediate our existing website instead of rebuilding it?
Usually yes. Remediate when your templates, components, content system and integrations allow reliable corrections. Rebuild only when documented constraints make corrections unsafe, temporary or impractical.
What happens if we do nothing?
Enforcement is active: lawsuits in France, market surveillance in Germany and Sweden, checkout testing by the Dutch ACM, and the first fines in Czechia. Beyond regulators, US litigation shows the private-enforcement pattern — 4,928 US suits in 2025, up 27% in federal filings. Penalties range from tens to hundreds of thousands of euros depending on the country.
Do we need an accessibility statement?
Most national implementations expect one, and it is cheap insurance: it shows regulators a documented assessment process, known limitations with workarounds, and a feedback channel. Have counsel confirm the requirements for your jurisdictions.
Conclusion
EAA readiness is a documentation discipline, not a one-time fix: inventory your exposure, freeze your target, test your journeys with real assistive technology, fix shared components first, and keep the evidence. The companies that do this now will experience the Act as routine compliance. Everyone else will meet it for the first time in a regulator's letter or a court filing.
Book your EAA readiness review — a documented audit of your priority journeys and a fixed-price remediation plan your team can execute.
