First off the usual caveat - this does not constitute legal advice. However it does contain advice about how to check and ensure your website is accessible.
The European Accessibility Act (EAA) has been in effect since 2019. On 28 June 2025 its requirements became law across the European Union. The EAA applies to all products and services: physical, analogue and digital. It means that all relevant products and services made available on the EU market must comply with the accessibility requirements defined by the directive. The EAA applies to any business with at least 10 staff and a turnover above €2 million, whether or not it charges for it services.
This is a win-win for both consumers and businesses. Accessible services are better for everyone, whether or not you have a disability. Businesses get to ensure their products are available to the whole market – there are an estimated at 100 million people with disabilities in the EU alone. The EAA is designed to decrease the complexity of navigating different national regulations by introducing common accessibility standards across the EU, helping business reduce the cost of making their services accessible.
Does the EAA apply in the UK or the US?
Yes, in as much as the EAA applies to any business that trades in the EU regardless of where it is based. So if your company wants to provide products or services to the EU it needs to be EAA compliant. Non-compliance with the EAA can lead to fines and ultimately the termination of EU market access.
While the EAA has not been implemented here in the UK, we have the Equality Act 2010 (which replaced the Disability Discrimination Act) which covers pretty much the same ground.
How does the EAA apply to websites?
The legislation includes mandatory accessibility requirements for all websites that provide products or services, for example online banking and e-commerce platforms. Public sector services were already covered by Web Accessibility Directive (and the Public Sector Bodies Accessibility Regulations in the UK).
The EAA directive is clear: all relevant websites should conform to the European Harmonized Accessibility Standards EN 301 549 (PDF), which in turn say that websites should follow the Web Content Accessibility Guidelines 2.1 to level AA (WCAG 2.1 AA).
WCAG 2.1 AA is already an industry standard for accessibility, so the EAA is not demanding more than should be there already. As far as we’re concerned at Clearleft, accessibility is - and has always been - a fundamental part of what constitutes professional website design and development. Anything less is unprofessional, and you should view it and your suppliers that way, whether they are independent freelancers, Big 5 consultants, CRM software sellers, or for that matter your staff.
We recommend following WCAG 2.2 as the latest version of the guidelines at time of writing. WCAG 2.2 has some useful clarifications and additions, and is backwards compatible with WCAG 2.1.
What are the key accessibility requirements of the EAA?
WCAG looks daunting to the uninitiated. There’s a lot to take in and it can be hard to know where to start. WCAG and the EAA’s requirements can be summarised by the POUR principles which require products and services to be Perceivable, Operable, Understandable, and Robust. Jeremy recently explained these as:
- Perceivable: content will be legible, regardless of how it is accessed.
- Operable: core functionality will be available, regardless of how it is accessed.
- Understandable: content will make sense, regardless of how it is accessed.
- Robust: content and core functionality will still work, regardless of how it is accessed.
How do I know if my website is EAA compliant?
Ultimately you’ll need to commission an accessibility audit, ideally one that includes testing with users. We can help you with that (contact us for a quote), but before you do, there’s some testing you can do for yourself. As we wrote recently, not all accessibility issues are created equal. This doesn’t just mean in their severity. Some issues can, and should, be caught early on, while other issues can only be found later.
Jeremy expalins how to run your own accessibility audit using automated tools. It’s really important to understand that automatic tools are helpful but only catch a minority of problems. Some aspects of WCAG cannot be completely tested with automated tools. These criteria require manual testing because they involve meaning, usability, intent, or user experience that automated tools cannot fully evaluate. For example a tool can tell you if there is alt text present for all your images, but they can’t tell you whether that text provides a suitable alternative to the image (if it doesn’t, it fails). Automatic tools can’t tell you if you pass, but they can highlight failures that are often readily fixable.
Remember you’ll need to test as many representative pages as possible, not just your home page.
What do I do if i find accessibility problems?
If your initial audit finds problems, fix what you can (speak to us about helping you with that) and commission a full accessibility audit. A good audit will come back with recommendations for where and why there are problems, and how improvements and fixes could be made. Thereafter you’ll need the services of an experienced front-end developer to implement the necessary code changes.
Don’t be tempted into paying for so-called accessibility overlays. These are no guarantee of making you accessible, and can do more harm than good. Ideally accessibility is not something you do afterwards. It is not an add-on or an option. It should be an integral part of the design and development process, a built in consideration from the start.
You should remember that fixing technical issues alone will not make your site accessible. Accessibility is not a one-time deal, it needs to be addressed constantly with: video captions, helpful alt text on images, unique text for links, properly structured textual content, colour contrast in charts and graphs, and so on. In recognition of this, the EAA legislation requires accessibility commitments and best practices at an organisational level. This includes official accessibility statements (which show intent but are largely meaningless if not adhered to) and providing specialised accessibility training to staff in both technical and content roles.
In summary
The European Accessibility Act will ensure fair and equitable access to products and services for everyone in the EU. It brings best practise into law by specifying WCAG as the standard to follow for web accessibility. It’s great that accessibility is now legal requirement, but above all it is the right thing to do.
You can learn more about the subject by reading our blog posts on accessibility and listening to the our podcast episode on accessibility.
