Web Accessibility: does your website comply with the new regulation?

European Accessibility Act: an introduction

Digital accessibility is becoming an increasingly important priority within the European Union.

With the entry into force of the European Accessibility Act (EAA) on June 28, 2025, many companies will have to comply with new standards to ensure that their digital products and services are accessible to everyone, including people with disabilities. Failure to do so could lead to penalties, as well as reputational damage.

This article explores the objectives of the EAA, the companies involved, the required changes, and the opportunities that come with adopting inclusive practices.

If you need accessibility consulting for your accessibility statement and to adapt your website to the European Accessibility Act, we at SAY can help you: contact us.

What we’ll cover in this article:

What is the European Accessibility Act?
Who must comply?
Accessibility requirements
EAA exemptions
Responsibilities in private companies
Obligations: Accessibility Statement
Penalties for non-compliant companies
Opportunities for companies
How to comply with the EAA?

1. What is the European Accessibility Act?

The European Accessibility Act (EAA) is a directive adopted by the European Union to harmonize accessibility rules across all member states. Its main goal is to improve access to key products and services for people with disabilities, reducing both digital and physical barriers.

The directive was created to address three main needs:

Social inclusion: ensuring that people with disabilities can fully participate in economic and social life.
Regulatory harmonization: eliminating discrepancies between different national legislations.
Competitiveness improvement: offering companies a single market with common rules.

2. Who must comply with the European Accessibility Act?

The European Accessibility Act (EAA) imposes obligations on various entities, including companies, public bodies, and service providers within the European Union.

Those who must comply include:

Manufacturers: must ensure their products meet accessibility requirements.
Distributors and retailers: must verify that products placed on the market are compliant with the EAA.
Service providers: must make their platforms and digital tools accessible.
Importers: must ensure that imported products meet European accessibility requirements.

The main services affected:

E-commerce: websites and apps of online stores must be accessible.
Banks and financial services: online banking and ATMs must be usable by all.
Transport: travel information (trains, buses, planes, ferries) must be accessible.
Telecommunications: electronic communication services must guarantee accessibility.
E-books and reading software: must be readable also by people with visual or cognitive disabilities.

The main products affected:

Computers and operating systems
Smartphones and other mobile devices
ATMs and payment terminals
Ticket machines and interactive kiosks
TVs and multimedia equipment

3. Accessibility requirements

The European Accessibility Act (EAA) requires that websites and mobile applications meet specific accessibility standards so that people with disabilities can use them without barriers.

3.1 Reference standard

Websites must comply with the Web Content Accessibility Guidelines (WCAG) 2.1, at least at level AA. These standards define the rules for making content accessible to people with visual, hearing, motor, and cognitive disabilities.

3.2 Specific requirements for a compliant website

Perceivability

Alternative text (alt text) for images and non-text content.
Adequate contrast between text and background (at least 4.5:1 for normal text and 3:1 for large text).
Compatibility with screen readers (e.g., VoiceOver, NVDA, JAWS).
Subtitles for audio and video content.
Transcriptions for audio files and audio descriptions for videos.

Operability

Keyboard navigation without the need for a mouse.
Visible focus on interactive elements (e.g., buttons, links, forms).
Avoid flashing content to prevent epileptic seizures (no flashes more than 3 times per second).
Adjustable reading times to avoid content disappearing too quickly.

Understandability

Clear and readable texts with simple language.
Understandable error messages with suggestions on how to fix them.
Clear labels and instructions in forms (e.g., “Enter your email” instead of “Required field”).

Robustness

Compatibility with assistive technologies such as screen readers, braille displays, and voice input software.
Correct semantic HTML to support assistive tools.
Well-structured code to ensure functionality across different devices and browsers.

3.3 Accessibility for Mobile Apps

Mobile applications must comply with the same principles as websites, including:

Compatibility with built-in screen readers (e.g., VoiceOver on iOS, TalkBack on Android).
Text alternatives for visual elements.
Navigation without mouse or touchscreen (e.g., through voice commands or keyboard).

3.4 Deadlines and penalties

The compliance deadline is June 28, 2025.
Non-compliant websites and apps may face penalties and restrictions in EU markets.

Find out if your site meets the required standards: request a tailored consultation now!

4. Are there exemptions to the EAA?

The European Accessibility Act (EAA) provides some exemptions for specific categories of companies, even though the main goal is to make as many products and services as possible accessible. The exemptions currently in place are the following:

4.1 Micro-enterprises (fewer than 10 employees and annual turnover below €2 million)

Micro-enterprises that provide services may be exempted from the application of the EAA. However, this exemption does not apply to products: if a company sells products covered by the regulation, these must still be accessible.

For example: 1) A small online shop with fewer than 10 employees might not be required to make its website compliant with the EAA. 2) A company that produces electronic devices (e.g., smartphones) must instead comply with accessibility standards, regardless of its size.

4.2 Companies for which accessibility would represent a “disproportionate burden”

The EAA allows for a temporary exemption if a company demonstrates that complying with accessibility rules would entail excessive costs or serious economic impacts compared to the benefits. However, to obtain this exemption, the company must provide concrete evidence that implementing accessibility would have a disproportionate financial impact. Companies are expected to:

Explore alternative solutions to guarantee at least a minimum level of accessibility.
Periodically update their assessment to verify whether the situation has changed.

For example: A tech startup with a limited budget might obtain a temporary exemption for certain features of its website but would still need to provide accessible alternatives.

4.3 Products and services already regulated by other EU legislation

Some sectors may be partially excluded from the EAA because they are already subject to more specific accessibility regulations.
For example: Digital public services are already regulated by EU Directive 2016/2102 on the accessibility of public administration websites and mobile applications.

5. Responsibilities in private companies

The responsibility for the accessibility of a website within a private company depends on the organizational structure of the company, but in general it involves several key roles.

5.1 Main roles responsible for accessibility in a private company

CEO (or Managing Director) and Company Management – Responsible for business strategy and legal compliance. They must ensure that accessibility is part of the corporate culture and allocate resources to implement it.

IT Manager / Chief Technology Officer (CTO) – Oversees the technical compliance of the website and digital applications. Coordinates development and ensures that accessibility is integrated into IT processes.

Web Developer / UX Designer – Developers and designers play a central role in ensuring that the site complies with WCAG standards and is compatible with assistive technologies. They must follow accessibility best practices in both code and design (e.g., color contrast, navigability, screen reader compatibility).

Marketing Manager / Digital Manager – Must ensure that digital content is accessible (e.g., alt text for images, videos with subtitles, readable text). Works closely with the development team to guarantee a good user experience for everyone.

Compliance Manager / Legal Officer – Ensures that the company complies with current regulations (e.g., European Accessibility Act, WCAG 2.1, EN 301 549). Supports the company in managing accessibility statements and the required documentation.

HR / Staff Training – Must ensure that employees involved in the design, development, and management of the site receive training on digital accessibility.

Customer Support / Help Desk – Must be ready to receive reports about accessibility issues and support users with disabilities in using the site.

5.2 Suggestions on how to manage accessibility in a company

Create a dedicated accessibility team, or assign an internal accessibility manager.
If the company lacks expertise or time, appoint an external manager for the accessibility statement.
Perform accessibility testing with automated tools and real users.
Constantly monitor compliance with standards and keep the site updated.
Train staff on digital accessibility and inclusive user experience.

6. Obligations: Accessibility Statement

The EAA requires the adoption of accessibility standards for digital products and services. In particular, companies must comply with the criteria defined by EN 301 549, which incorporates the WCAG 2.1 (Web Content Accessibility Guidelines).

Public accessibility statement on the website, specifying the level of compliance and any limitations.
Accessible feedback to allow users to report accessibility issues.

6.2 What is the Accessibility Statement?

The Accessibility Statement is a public document that describes the level of accessibility of a website, an app, or a digital service, indicating any barriers and the measures adopted to improve accessibility. Companies covered by the EAA are required to prepare this document annually.

6.2 What is it for?

To inform users about how accessible the service is.
To demonstrate compliance with regulations (such as the European Accessibility Act – EAA or the EU Web Accessibility Directive – WAD).
To provide a feedback mechanism, allowing users to report accessibility issues.

6.3 What should it include?

Compliance status with standards (e.g., WCAG 2.1 AA).
Any remaining barriers.
Actions in progress to improve accessibility.
Contact information to report accessibility issues.
Date of the last review.

6.4 Where should it be published?

It must be easily accessible from the website (usually in the footer or in the “Accessibility” section). The company must carry out continuous monitoring and updates to ensure compliance with the standards.

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7. Penalties for Non-Compliant Companies

Companies that fail to comply with the regulation may be subject to sanctions and restrictions. Member States will be responsible for enforcing the law and may impose:

Fines and financial penalties.
Obligation to withdraw non-compliant products from the market.
Bans on commercialization within the EU.
Reports from users and associations defending the rights of people with disabilities.

In addition, companies risk damaging their reputation and losing business opportunities related to digital inclusion.

8. Opportunities for Companies

Beyond regulatory obligations, the EAA offers numerous opportunities for companies that embrace digital accessibility:

Market expansion: by improving accessibility, companies can reach a wider audience, including 135 million people with disabilities in Europe.
Improved UX (User Experience): inclusive design enhances navigation for all users.
Competitive advantages: accessible companies will be able to stand out from the competition.
Financial and tax benefits: in some countries, adopting digital accessibility measures may be incentivized through tax relief.
Brand strengthening: demonstrating commitment to inclusion improves corporate reputation and corporate social responsibility (CSR).

9. How to Comply with the European Accessibility Act?

Companies can start the compliance process by following these steps. The recommendation is to consult an agency specialized in accessibility, like us , and proceed step by step:

9.1 Accessibility Audit

Conduct a thorough evaluation of the website, apps, and digital products to identify any accessibility barriers.

9.2 Technical and UI/UX Adjustments

Implement improvements in code and design to comply with WCAG 2.1 guidelines, or use AI widgets capable of ensuring compliance.
Ensure that content is accessible via screen readers and other assistive technologies.

9.3 Training and Awareness

Involve development, marketing, and design teams to adopt an accessibility mindset.
Organize workshops on best practices and regulatory standards.

9.4 Testing with Real Users

Work with people with disabilities to test implemented solutions and improve product usability.

9.5 Continuous Monitoring

Accessibility is not a project with a deadline, but a continuous process. Companies must regularly update their products and services to ensure constant compliance with standards.

Do you need accessibility consulting for your Accessibility Statement and to make your website compliant with the European Accessibility Act?