EAA Compliance: A Practical Guide to Complying With the European Accessibility Act

Introduction

EAA compliance is no longer something you can push to next quarter's roadmap.

The European Accessibility Act (EAA) became enforceable across the EU on June 28, 2025, and national authorities are already acting on it: French regulators have taken major retailers to court over inaccessible websites and apps within months of the deadline passing.

If your business sells products or services to EU consumers and you haven't mapped out what the law requires, you're behind – but not too far behind to catch up properly.

This guide walks through what you need to do to be EAA compliant, who it applies to, and the technical requirements behind it.

You'll get a straightforward EAA compliance checklist, the rules around video and language, what happens if you don't comply, and how to keep your website compliant as it keeps changing, not just on the day you pass an audit.

What is EAA compliance?

The European Accessibility Act, which is also known as EU Directive 2019/882, sets accessibility requirements for a defined list of products and services sold across the European Union, and EAA compliance means that anything you sell or offer that falls within its scope has to meet the requirements as outlined in the directive.

Rather than inventing new accessibility rules from scratch, the EAA is built on an existing European standard: EN 301 549.

That standard is grounded in the same four principles used by the Web Content Accessibility Guidelines: content has to be perceivable, operable, understandable, and robust.

In practice, EN 301 549 incorporates WCAG success criteria at Level AA, so if your website already targets WCAG AA, or is ADA compliant, you have a genuine head start.

Common accessibility issues – like missing alt text, poor color contrast, and keyboard traps – are exactly what EN 301 549 and WCAG are built to catch.

EAA compliance isn't limited to websites. It covers physical products like ATMs and ticketing machines, the accessibility of customer support, the technical documentation you publish, and the way you describe your own accessibility features.

A retailer's website might pass a technical accessibility audit and still fall short of EAA compliance if its accessibility statement is missing or its support line has no accessible alternative for a customer who can't use the phone.

That combination of digital accessibility standards, legal obligations, and documentation is what makes EAA compliance a bigger project than your typical accessibility audit.

Who does EAA website compliance apply to?

EAA website compliance applies to a broad range of products and services.

The law covers any business, EU-based or not, that sells qualifying products or services to consumers in the EU market. If you have EU consumers, size and location outside the EU don't exempt you.

Products and services covered by the regulations include:

• Computers, smartphones, and their operating systems
• ATMs, self-service terminals, and payment terminals
• Web accessibility on e-commerce websites and apps
• Banking services for consumers
• Passenger transport services across air, rail, bus, and waterborne travel, including websites, apps, and travel information
• E-books and e-readers
• Electronic communications, such as messaging and video calling

For most companies with a digital storefront, digital services, or a customer account area, EAA website compliance puts the entire consumer-facing site and mobile app in scope – not just a single accessibility page.

There are two exceptions when it comes to EAA requirements:

1. Microenterprises – businesses with fewer than 10 employees and no more than €2 million in annual turnover – are exempt from the service-related requirements, though they still have to meet accessibility obligations when it comes to product requirements if they manufacture covered hardware.
2. Any organization can also claim a disproportionate burden exemption for a specific requirement if meeting it would impose a genuinely excessive cost relative to the benefit, but this needs evidence – evidence that has to be documented and kept on file.

Around 100 million people in the EU live with a disability, according to the European Commission, so remaining EAA compliant is important for every business. That number constitutes a sizeable share of EU consumers who can't complete a purchase or manage an account if your website has accessibility barriers.

EAA compliance requirements

EAA compliance requirements fall into three groups: technical, informational, and organizational.

To meet technical requirements, you need to conform to EN 301 549, which covers accessibility standards for hardware interfaces, software, websites, and apps.

For a website or app, this means meeting the relevant WCAG success criteria: text alternatives for images, sufficient color contrast, full keyboard operability, clear labels for form fields, and compatibility with assistive technologies like screen readers.

Informational requirements cover what you publish. Products need instructions and safety information in accessible formats. Services need an accessibility statement, covered below, plus any user documentation written in plain language.

Organizational requirements cover how your business demonstrates and maintains compliance.

Manufacturers, importers, distributors, and service providers each have distinct obligations as economic operators:

• Manufacturers run a conformity assessment and prepare technical documentation before placing a product on the EU market.
• Service providers have to assess their services against EN 301 549, keep records of that assessment, and be ready to show it to an enforcement authority on request.

What should an EAA accessibility statement include?

An accessibility statement is one of the most concrete EAA compliance requirements. At minimum, it should include:

• Your organization's name and contact details
• A description of the accessibility features already in place
• Any known limitations, and the reason for them, whether that's a documented disproportionate burden exemption or a fix still in progress
• An accessible support channel for customers to report a barrier
• Contact information for the relevant enforcement authority in each EU member state where you operate
• The date the statement was last reviewed

Keep the statement honest. A statement that claims conformance hands enforcement authorities and customers a specific, checkable claim to hold you to. Overclaiming does more damage to your ability to demonstrate EAA compliance than no statement at all.

When was the deadline for EAA compliance?

EU member states had until June 28, 2022, to write the EAA into their own national laws. That date was a transposition deadline for governments, not a compliance deadline for businesses.

The more recent deadline was June 28, 2025, when the EAA became directly enforceable. From that date, new products and services placed on the EU market have to comply.

There are a couple of exceptions to keep in mind. Service contracts already in place before June 28, 2025 can run their course, up to five years, without being renegotiated to ensure compliance.

Self-service terminals already in use before that date can also stay in service until the end of their working life, capped at 20 years.

None of that changes the fact that if you're only considering EAA compliance requirements now, the deadline has already passed, and every month of delay adds to your exposure.

EAA Compliance Checklist

There's no shortcut that skips steps, but there is a fastest realistic path to full EAA compliance. This EAA compliance checklist will work for most teams:

1. Confirm the EAA applies to you. Check your products and services against the covered list above, and check whether the microenterprise exemption applies.
2. Audit what you have today. Treat this like any other website QA testing review, scored against EN 301 549 and WCAG success criteria for every website, app, and self-service product in scope. Include support channels and documentation, not just the interface.
3. Prioritize by risk and reach. Fix barriers that stop someone from completing an entire task, like checking out or logging in, before cosmetic issues that just look untidy. A missing alt tag is less impactful than a checkout button a screen reader can't reach.
4. Fix the issues. Assign each finding to whoever owns that part of the product, with enough detail that they can reproduce and verify it without going back to whoever ran the audit.
5. Write the accessibility statement. Use the components listed above, and publish it somewhere easy to find. Most teams link it from the footer.
6. Prepare technical documentation. Keep records of your conformity assessment, your accessibility statement history, any disproportionate burden assessments, and evidence of the training in step seven, in case an enforcement authority asks.
7. Train the teams who affect the product. Support agents, content editors, developers, and QA testers all need to know enough to avoid reintroducing issues you've already fixed.
8. Set up ongoing monitoring. EAA compliance isn't a one-time project. New pages, new features, and CMS updates can all introduce new barriers, so you need a process that catches them as they ship, not at the next scheduled audit.

Don’t treat the deadline as a finish line, but as the start of an ongoing process.

EAA video and multimedia compliance

EAA accessibility compliance video requirements are some of the easiest to miss. A site can pass a technical accessibility audit on its page structure while its video library stays completely inaccessible.

For pre-recorded video content, you need:

• Captions. A same-language text version of spoken dialogue and relevant sounds, including speaker identification, not just auto-generated subtitles with no quality check.
• Audio description. A narrated track, inserted into natural pauses in the dialogue, that describes on-screen action, settings, and text a viewer who can't see the screen would otherwise miss.

One detail that sometimes catches international teams out is that captions and audio description need to be in the language of each market you serve, not the language the video was originally produced in. A French customer needs French captions and French audio description, even if the video itself was shot and edited in English.

Video accessibility failures are treated the same as any other EAA compliance gap. There's no separate, lighter penalty track for multimedia and non-compliant video content is exposed to the same fines and enforcement action covered in the next section.

Build captioning and audio description into your video production and localization workflow from the start, rather than retrofitting it market by market once legal flags a gap.

Maintaining EAA compliance over time

An audit tells you where you stand on the day it runs. It doesn't tell you what happens the next time someone ships a new landing page, redesigns a checkout flow, or adds a new form. The audit is a snapshot of your EAA compliance program, but your website isn't static.

Treat accessibility issues the same way you'd treat any other bug: something anyone on the team can flag as soon as they spot it, with enough technical context that a developer can act on it without a second round of questions.

Visual bug-reporting tools like Marker.io can help.

When a QA tester, content editor, developer, or accessibility expert finds a barrier, keyboard focus that disappears, or a form error that isn't announced to a screen reader, they can highlight it directly on the live page and file it as an annotated report, with browser, OS, console, and screen size data attached automatically, straight into Jira, Trello – or whatever bug tracker your developers already use.

If you run multiple sites, brands, or country versions of the same product, you have to be especially vigilant, as EAA compliance has to hold up market by market, in the local language, across every one of them.

A shared, visual way to report and route issues keeps legal, accessibility experts, developers, and QA looking at the same evidence instead of describing the same bug three different ways over email.

Marker.io can help you make sure the issues an audit or a manual accessibility check turns up actually get fixed, verified, and don't quietly resurface after the next release – the ongoing half of EAA compliance that a one-time audit can't cover on its own.

EAA compliance penalties and enforcement

Enforcement sits with each EU member state, so the specifics vary, but the pattern is consistent: national authorities can issue fines and demand corrective action, up to and including restricting a non-compliant product or service from the market until it's fixed.

The rules are already being enforced.

In November 2025, French disability rights organizations took four major grocery retailers to court over inaccessible websites and apps.

The first ruling rejected an argument that reaching roughly 71% of the relevant accessibility criteria was good enough and ordered the retailer to reach full compliance within six months, backed by a daily fine for every day it runs late.

The exact fine is, in many ways, less important than the precedent: partial progress is not a defense once an enforcement authority or a court gets involved. EAA compliance is judged on whether the barrier is actually gone, not on how much effort went into removing it.

Conclusion

EAA compliance goes beyond just a single accessibility audit, and it doesn't end on the day you pass one.

It covers the technical standard your product meets, the accessibility statement and documentation you can show an enforcement authority, and the ongoing process that keeps new barriers from creeping back in after every release.

Start with the checklist above: confirm whether the EAA applies to you, audit what you have, fix what's broken, and document the rest. Then build a process for what comes after the audit. That's the part that actually keeps you compliant for the long run.

If your team needs a faster way to turn accessibility findings, or any website bug, into fixes your developers can act on immediately, try Marker.io and see how much faster reported issues get resolved.

EAA Compliance FAQs

Does EAA compliance apply to businesses outside the EU?

Yes. If you sell a covered product or service to consumers in the EU market, EAA compliance applies whether your business is based in the EU or not. Having EU consumers creates the obligation, not where your office sits.

What's the difference between EAA compliance and WCAG conformance?

WCAG is a voluntary technical standard for digital content. EAA compliance is a legal obligation that includes WCAG-aligned technical requirements through EN 301 549, plus documentation, accessible support, and product requirements that go beyond a website's code.

Do small businesses need to comply with the EAA?

Most do. The only exceptions are made for microenterprises with fewer than 10 employees and no more than €2 million in annual turnover – and even then, only for service-related requirements, not for products a business manufactures.

Is EAA compliance a one-time certification?

There's no single certificate that proves EAA compliance forever. It's an ongoing obligation: products and services need to stay compliant as they change, which is why monitoring matters as much as the initial audit.