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The European Accessibility Act: Technical Aspects of Compliance

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The European Accessibility Act (EAA) is a landmark European Union (EU) regulation aimed at ensuring people with disabilities can access goods and services—including many types of digital experiences—without barriers. Enacted in 2019, the EAA synchronizes accessibility requirements across EU Member States.  

The EAA covers a broad range of industries and applies to any organization that serves consumers in the EU—no matter where they’re based. With regard to digital accessibility, EAA compliance can be achieved through conformance to specific technical requirements, including those outlined in EN 301 549 (the harmonized European digital accessibility standard). If your business is impacted by the EAA, it’s crucial that you understand and implement these technical requirements to avoid penalties.  

EAA technical requirements 

The EAA’s core objective is to remove barriers to access for consumers with disabilities. To achieve this aim, the law outlines requirements for functional accessibility, mandating that organizations ensure their digital experiences are perceivable, operable, understandable, and robust.  

The best way for organizations to prove compliance with these functional requirements is to conform with EN 301 549, which incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA criteria. Meeting these standards involves:  

  • Ensuring compatibility with screen readers, keyboard navigation, and other assistive technologies 
  • Improving website readability and usability through accessible themes, color combinations, and focus indicators 
  • Incorporating captions into video content, as well as providing audio descriptions and transcripts  

Importantly, businesses providing products and services covered by the EAA must ensure all online touchpoints—including websites, apps, and checkout flows—meet the law’s accessibility requirements.  

EAA compliance checklist 

Now that you’re aware of the EAA’s requirements, how can you get started bringing your digital experiences into compliance? Below, we’ve outlined a general roadmap for meeting your obligations. Because your business may not have the internal resources and expertise to complete these steps alone, we recommend working with a third-party expert to ensure you uphold your responsibilities under the EAA: 

1. Audit existing products and services 

  • Obtain an evaluation of current digital products, websites, and mobile apps to identify areas of non-conformance with EN 301 549 and WCAG 2.1. These evaluations should be performed by accessibility experts and include functional testing by native users of assistive technologies.  

2. Fix identified accessibility issues 

  • Create a plan to address potential violations identified during the accessibility audit, prioritizing those that pose the greatest barriers to usability for people with disabilities. 
  • Implement fixes for critical accessibility barriers, ideally in collaboration with an external expert. 

3. Train teams on accessibility standards and best practices 

  • Provide role-appropriate training on accessibility strategies and EAA requirements for designers, developers, and other teams across your organization. 

4. Monitor compliance and collect feedback 

  • Schedule regular compliance testing for your digital products and services.  
  • Use automated tools to continuously identify potential EAA violations. 
  • Set up feedback mechanisms to surface accessibility issues encountered by users. 
  • Establish a dedicated team to oversee EAA compliance and promptly respond to user feedback. 

Addressing country-specific requirements 

While the EAA sets a common framework for compliance across the EU, individual Member States are responsible for transposing this framework into their national laws. Individual countries’ transpositions may include unique nuances. For instance, some Member States have outlined additional requirements and specific enforcement mechanisms: 

  • France requires some organizations to create annual and multi-year action plans for digital accessibility.  
  • Spain allows for substantial penalties for EAA violations.  
  • In Ireland, EAA non-compliance may be punishable with jail time. 

Businesses operating in the EU should track local legislation to ensure full accessibility compliance across different countries. 

Challenges and opportunities posed by EAA compliance 

At first, meeting the EAA’s technical requirements may be challenging, particularly for businesses with legacy systems or limited resources.  

Remediating accessibility issues in existing websites, content, and digital services can be time-consuming. Additionally, as previously mentioned, organizations may need to invest in specialized training and third-party support to meet EAA requirements. And to stay EAA-compliant, organizations must equip their teams with technology to continuously monitor websites, apps, and other digital content for accessibility barriers.  

However, the short-term costs of achieving EAA compliance pay off in long-term gains. Digital accessibility offers significant advantages to businesses: 

  • Expanded market access: Ensuring products and services are accessible will help businesses cater to the more than 85 million people with disabilities in the EU, as well as aging populations with similar needs both inside and outside the economic region. 
  • Improved usability: Accessibility features benefit a wide audience, enhancing the user experience for everyone—not just people with disabilities. For example, adding captions to videos not only helps customers who are deaf or hard-of-hearing, but also those who prefer watching content in quiet environments. 
  • Enhanced reputation: EAA compliance demonstrates a commitment to inclusivity, strengthening a brand’s image and aligning with corporate social responsibility goals.  

The EAA: A pathway to innovation and inclusivity 

The EAA represents a significant step toward a more inclusive society, harmonizing accessibility standards across the EU and reducing barriers for people with disabilities. While compliance may require time and resources, the long-term benefits of complying with the European Accessibility Act by 2025 far outweigh the upfront costs.  

By adopting universal design principles, adhering to EN 301 549 technical standards, and being aware of country-specific requirements, businesses can successfully navigate this legislative shift. Beyond legal obligations, the EAA is a call for innovation and inclusivity, paving the way to a more accessible future. 

FAQs 

What is the European Accessibility Act (EAA), and who does it apply to? 

The European Accessibility Act (EAA) is an EU law aimed at ensuring that goods and services are accessible to people with disabilities across all Member States. It applies to businesses operating in key sectors such as banking, transport, telecommunications, e-commerce, and consumer electronics. The EAA sets harmonized accessibility standards for new products and services introduced after 2025. 

What technical standards should you follow for EAA compliance? 

To comply with the EAA, businesses must meet accessibility requirements that align with internationally recognized standards like: 

  • WCAG 2.1 Level AA for digital accessibility (websites, apps, and other digital interfaces). 
  • EN 301 549, which provides detailed technical guidance for accessible information and communications technology (ICT) in the European context. It incorporates principles and success criteria from WCAG. 

Additionally, businesses should consider the requirements of any country-specific transpositions of the EAA. 

What steps can businesses take to ensure compliance with the EAA? 

Businesses can follow these steps to achieve compliance: 

  • Obtain an accessibility audit to identify compliance gaps in existing products, services, and digital platforms. 
  • Implement WCAG 2.1 and EN 301 549 standards for websites and mobile apps, ensuring compatibility with assistive technologies like screen readers. 
  • Upgrade physical devices to include features like tactile feedback, adjustable settings, and alternative input options. 
  • Train employees to understand accessibility principles and assist customers with disabilities effectively. 
  • Monitor and adapt continuously, incorporating feedback from users and staying updated with evolving accessibility standards and country-specific regulations.