European Accessibility Act 2025: Requirements for Websites

The EAA applies to “economic operators” that place covered products on the EU market or provide covered services to EU consumers. This includes manufacturers, importers, distributors, and service providers. Crucially, the EAA applies based on where your customers are, not where your company is located.

This means that a U.S.-based e-commerce company selling to customers in Germany, a Canadian SaaS provider serving clients in France, or an Australian bank with EU account holders all fall within the scope of the EAA if their products or services are “placed on the market” or provided in the EU.

There is one important exemption: microenterprises (companies with fewer than 10 employees and annual turnover or balance sheet total not exceeding 2 million euros) that provide services are exempt from the EAA. However, microenterprises that manufacture, import, or distribute covered products are not exempt. And even exempt microenterprises may still be subject to other accessibility laws in their member state.

A “disproportionate burden” defense is also available, allowing businesses to argue that specific accessibility requirements would impose an undue burden relative to their resources. However, this defense requires documented assessment and is expected to be narrowly interpreted by regulators.

The EAA requires member states to establish “effective, proportionate, and dissuasive” penalties for non-compliance. Because the EAA is a directive, each member state sets its own specific penalties. This means the consequences of non-compliance will vary depending on which EU country's market you are serving.

Penalties can include:

• Fines: Financial penalties that vary by member state. Some countries are expected to impose fines proportional to revenue, similar to GDPR-style enforcement.
• Market restrictions: Authorities can prohibit non-compliant products or services from being offered on the EU market.
• Corrective orders: Mandatory remediation within specified timeframes.
• Public disclosure: Some member states may publicly name non-compliant businesses.

Beyond direct penalties, non-compliance carries significant reputational risk. European consumers and businesses are increasingly aware of accessibility requirements, and failure to comply can damage brand trust and customer loyalty.

With the June 2025 enforcement deadline, organizations should be actively preparing now. Here is a practical roadmap:

1. Determine if the EAA applies to you. Review whether your products or services fall within the EAA's scope and whether you serve EU consumers. If you sell online to EU customers, the answer is likely yes.
2. Audit your website against WCAG 2.1 AA. Use an automated WCAG checker to get a baseline assessment. Automated tools catch 30–40% of issues and provide a prioritized list of fixes.
3. Conduct manual testing. Test keyboard navigation, screen reader compatibility, and content readability. Use our WCAG checklist to methodically verify each criterion.
4. Fix identified issues. Prioritize barriers that block core user journeys: navigation, search, product browsing, checkout, account management, and customer support.
5. Check color contrast. Use a color contrast checker to verify all text and interactive elements meet the required 4.5:1 and 3:1 ratios.
6. Publish an accessibility statement. Document your commitment to accessibility, the standard you target, known limitations, and how users can report issues.
7. Set up ongoing monitoring. Accessibility is not a one-time project. CompliaScan's monitoring plans provide continuous scanning and alerts so you catch regressions before regulators do.