EU Accessibility Act (EAA) Compliance Guide
The European Accessibility Act (EAA, Directive 2019/882) requires websites and digital services serving EU customers to meet WCAG 2.1 AA accessibility standards. Enforcement began June 28, 2025. This guide explains what the EAA requires, who must comply, penalties, and how to achieve compliance using automated scanning.
What is the EU Accessibility Act?
The European Accessibility Act is EU legislation (Directive 2019/882) that requires products and services to be accessible to people with disabilities. It covers websites, mobile applications, e-books, banking services, e-commerce, transport, and telecommunications. The technical standard referenced by the EAA for web accessibility is WCAG 2.1 AA.
Who Must Comply with the EU EAA?
The EU EAA applies to:
- Websites and mobile apps serving EU customers
- E-commerce platforms selling to EU consumers
- Banking and financial services with digital interfaces
- Transport services with digital booking systems
- Telecommunications services
- E-books and digital publications
- Non-EU companies providing digital services to EU customers
What Does the EAA Require for Websites?
The EAA requires websites to meet WCAG 2.1 AA standards, which include 30 success criteria across four principles:
Perceivable
- Text alternatives for all non-text content (alt text on images)
- Color contrast minimum 4.5:1 for normal text
- Text resizable to 200% without loss of content
- Information not conveyed by color alone
Operable
- All functionality available via keyboard
- Descriptive page titles
- Clear link purposes
- Visible focus indicators
- Multiple ways to navigate (menu, search, sitemap)
Understandable
- Page language declared in HTML
- Consistent navigation across pages
- Form errors identified and described in text
- Form inputs have labels and instructions
Robust
- Valid HTML markup
- Proper ARIA roles, names, and values for custom components
- Status messages announced to assistive technology
EU EAA Compliance Checklist
- Run an automated accessibility scan to identify violations
- Fix color contrast issues (minimum 4.5:1 ratio)
- Add alt text to all informative images
- Fix heading structure (h1 → h2 → h3, no skips)
- Add labels to all form inputs
- Ensure all interactive elements work with keyboard only
- Add main, nav, header, footer landmarks to all pages
- Set the HTML lang attribute on every page
- Make link text descriptive (remove "click here")
- Add visible focus indicators for keyboard users
- Test with a screen reader (NVDA or VoiceOver)
- Re-scan after fixes to verify compliance
- Set up regular rescans (quarterly or monthly)
What Are the Penalties for EAA Non-Compliance?
Penalties vary by EU member state but can include:
- Fines: Up to EUR 100,000 per violation in some member states
- Legal action: National enforcement bodies can take legal proceedings
- Public procurement exclusion: Non-compliant businesses excluded from government contracts
- Compliance orders: Mandated to fix accessibility issues within a timeframe
- Publication of non-compliance: Some countries publish names of non-compliant businesses
- France saw the first EAA lawsuits in November 2025
- 2026 is the first full year national authorities are actively supervising against the deadline
- Existing products and services have until June 28, 2030 to comply
Penalties by EU Member State
| Country | Max Fine | Enforcement Body |
|---|---|---|
| 🇮🇪 Ireland | €60,000 | National Disability Authority |
| 🇸🇪 Sweden | €900,000 | Agency for Participation |
| 🇫🇷 France | €150,000 (civil) / €750,000 (aggravated) | Derections Régionales |
| 🇩🇪 Germany | €100,000 | BAGUS |
| 🇮🇹 Italy | €60,000 | AGID |
| 🇪🇸 Spain | €30,000–€150,000 | Different autonomous communities |
| 🇳🇱 Netherlands | €90,000 | Authority for Digital Accessibility |
| 🇧🇪 Belgium | €80,000–€200,000 | Regional authorities |
Penalty figures are based on national implementing legislation as of July 2026. Verify with the relevant national enforcement body for the most current figures.
How to Achieve EAA Compliance
Step 1: Scan Your Website
Run an automated accessibility scan with ComplyKeep to identify WCAG 2.1 AA violations. The free plan scans up to 20 pages and provides a summary. The Full Report at EUR 29 provides detailed fix instructions for every issue found.
Step 2: Fix Critical Issues First
Address critical and serious violations first — these carry the highest legal risk. Common critical issues include missing form labels, no keyboard navigation, and missing main landmarks.
Step 3: Fix Moderate Issues
Moderate issues like color contrast and heading order affect the majority of websites. ComplyKeep's report provides specific WCAG criterion references and fix instructions for each issue.
Step 4: Conduct Manual Testing
Automated scanning catches 30-40% of WCAG issues. Manual testing with a screen reader (NVDA for Windows, VoiceOver for Mac) and keyboard-only navigation is needed for full compliance. Test all interactive elements and content reading order.
Step 5: Document Compliance
Keep records of your accessibility scans, fixes applied, and manual testing results. This documentation demonstrates good-faith compliance efforts if questioned by enforcement bodies.
Step 6: Set Up Ongoing Monitoring
Websites change constantly. New content, design updates, and code changes can introduce new accessibility barriers. ComplyKeep's Monitor Pro plan provides weekly automated rescans to catch issues before they become legal liabilities.
Check Your EAA Compliance Now
Scan your website against WCAG 2.1 AA standards in under 2 minutes — free, no signup required.
Run Free Accessibility Scan →Frequently Asked Questions
Does the EAA apply to small businesses?
Microenterprises (under 10 employees and under EUR 2 million annual turnover) are exempt from some EAA obligations for services. However, the exemption does not apply to products. Small businesses should still aim for WCAG 2.1 AA compliance to avoid legal risk and serve all customers.
Does the EAA apply to non-EU companies?
Yes. The EAA applies to any business providing digital products or services to EU customers, regardless of where the business is based. A US, UK, or Irish company with EU customers must comply with the EAA for its website and digital services.
What is the difference between ADA and EAA?
The ADA (Americans with Disabilities Act) is US legislation that has been interpreted to require website accessibility under Title III. The EAA is EU legislation specifically covering digital products and services. Both reference WCAG 2.1 AA as the technical standard. The EAA has a clearer enforcement framework and specific penalties, while ADA enforcement is through private lawsuits.
How long does EAA compliance take?
For a small website (under 20 pages), compliance can be achieved in 1-2 weeks after identifying issues. For larger sites, it may take 1-3 months. The timeline depends on the number of violations and development resources available. Running a ComplyKeep scan first gives you a clear picture of the work required.