The European Accessibility Act Is Now in Force

The European Accessibility Act (EAA) entered into force on June 28, 2025. If your organization sells or provides digital products or services in the EU — websites, mobile apps, e-commerce platforms, banking portals, e-book readers, ticketing systems — this law now applies to new products launched from that date forward.

This is not a drill. Member states transposed the EAA into national law, and enforcement mechanisms are live in all 27 EU countries. Here is what you need to understand before your next release.

What Is the European Accessibility Act?

The EAA (Directive 2019/882) is EU legislation that mandates digital accessibility for a broad range of products and services. It aims to harmonize accessibility requirements across the EU's internal market, replacing a patchwork of national rules with a single standard that businesses can work to once and apply across all member states.

The EAA covers: e-commerce services, banking and financial services, audio-visual media services, electronic communications, e-books and dedicated software, ticketing and check-in machines, and ATMs and other self-service terminals.

Notably, the EAA does not cover every website in the EU. Small enterprises (fewer than 10 employees and annual turnover or total annual balance sheet not exceeding €2 million) are exempt from most product obligations. However, if your organization exceeds that threshold and you are providing any of the listed services digitally, you are in scope.

What Does "In Force" Mean for Your Product?

The EAA's timeline has two tracks:

New products and services launched from June 28, 2025 onward must meet EAA requirements at the time of launch. There is no grace period for new releases.

Existing products and services already on the market before June 28, 2025 have until June 28, 2030 to come into compliance. This five-year window is designed to give organizations time to remediate their existing digital infrastructure, not to delay indefinitely.

The distinction matters. If you are deploying a net-new product feature, a redesigned user flow, or a freshly launched service after June 28, 2025, the new-product track applies and compliance is required now.

Who Is Affected?

The EAA applies to businesses that:

• Are established in the EU, or
• Offer products or services to EU consumers from outside the EU (the "place of establishment" test)

If your SaaS product has European customers, you are almost certainly in scope regardless of where your company is headquartered. The EAA is consumer-protection legislation — it follows the customer.

Service providers (as opposed to product manufacturers) have some flexibility on how they achieve compliance, but the outcome standard is the same: the service must be accessible to people with disabilities.

What Technical Standard Applies?

The EAA does not specify pixel-level technical requirements directly. Instead, it references EN 301 549, the harmonized European standard for ICT accessibility. EN 301 549 in turn incorporates WCAG 2.1 Level AA as its web content accessibility baseline.

In practice, meeting WCAG 2.1 AA is the path to EAA compliance for web products and services. This means:

• Perceivable: Alt text on images, captions on video, sufficient color contrast (4.5:1 for body text), text resize up to 200% without loss of functionality.
• Operable: Full keyboard navigation without mouse dependency, no seizure-triggering content, sufficient time for time-limited content, skip navigation links.
• Understandable: Consistent navigation, error identification and correction, language of page declared in HTML.
• Robust: Content parseable by assistive technologies, ARIA used correctly, interactive elements are programmatically determinable.

One important note: WCAG 2.2 was published in October 2023 and introduces 9 additional success criteria. While WCAG 2.1 AA remains the formal EAA baseline, auditors and enforcement bodies may increasingly reference 2.2, particularly for new products. Getting to 2.2 now avoids a second round of remediation.

What to Do Now

If you sell digital products or services in the EU and your organization is above the SME threshold, here is the priority list:

Audit your current state. Run an automated scan against your live URLs — automated tools can catch roughly 30–40% of WCAG violations in a single pass. That is a fast way to surface the high-severity issues before an enforcement body does.

Scan your codebase. Many accessibility issues live in component code — missing ARIA labels, interactive elements with no keyboard handler, form inputs without associated labels — and never surface as runtime URL violations until users hit them in uncommon states. Static code analysis catches these before they ship.

Include accessibility in your PR workflow. Every new pull request is a potential regression. Catching WCAG violations at the code-review stage is dramatically cheaper than remediating post-launch — and it prevents new violations from entering the product between audit cycles.

Document your conformance posture. The EAA requires organizations to provide an accessibility statement. Make it honest: state the standard you target, list known exceptions with explanations, and provide a mechanism for users to report issues.

Plan for 2030, not just today. If you have existing services in the remediation window, build a roadmap. The five-year period sounds long, but compliance at scale takes time — especially for legacy systems with deep accessibility debt.

The EAA represents a genuine shift in how the EU treats digital accessibility: from a best practice to a legal obligation. The technical path to compliance is well-defined. The question now is whether your product can demonstrate it.