European Accessibility Act Checklist for Businesses (EAA 2025)

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Since 28 June 2025, the European Accessibility Act (EAA) has required a wide range of products and services sold to consumers in the EU to be accessible. Many businesses only discovered the law when a client, a partner or a lawyer asked about it. Many others still assume it doesn’t apply to them because they are small, or because they are based outside Europe.

This guide explains the EAA in plain language and gives you a practical checklist. It’s written for founders, product owners and marketing teams, not lawyers. It is not legal advice: rules are enforced through each EU country’s national law, so check the specifics for the markets you sell into.

Key takeaways

The EAA (Directive (EU) 2019/882) applies to products and services placed on the EU market or provided to EU consumers, regardless of where the business is based.
Covered services include e-commerce, consumer banking, e-books, electronic communications, parts of passenger transport, and access to audiovisual media services.
Microenterprises providing services are exempt, but microenterprises making covered products are not.
In practice, websites and apps are expected to meet WCAG-based requirements, with EN 301 549 as the main technical reference.
Services must publish information about how they meet the accessibility requirements, usually as an accessibility statement.

What is the European Accessibility Act?

The EAA is an EU directive that sets common accessibility requirements for certain products and services. Each member state has transposed it into its own national law, with its own enforcement authority and penalties. The goal is to remove barriers for the tens of millions of people in the EU who live with a disability (the European Commission estimates around 87 million), and to replace a patchwork of national rules with one set of requirements.

Does it apply to you?

Work through these questions.

1. Do you sell to consumers in the EU?

The EAA is about products and services offered to consumers. If you sell to EU customers, even from India, the US or the UK, it can apply to you. Being based outside the EU does not exempt you.

2. Is your product or service covered?

Services covered include:

E-commerce: any service selling products or services to consumers online, including websites and mobile apps with a checkout.
Consumer banking services: online banking, payment services and related apps.
E-books and dedicated reading software.
Electronic communications services, such as phone and messaging services.
Services providing access to audiovisual media, such as streaming platforms’ websites and apps.
Elements of passenger transport services (air, bus, rail, waterborne): websites, apps, electronic tickets and real-time travel information.

Products covered include computers and operating systems, smartphones, e-readers, consumer terminal equipment for TV and communications, and self-service terminals such as ATMs, ticket machines and check-in kiosks.

3. Are you a microenterprise?

A microenterprise has fewer than 10 employees and annual turnover or balance sheet total of no more than €2 million. Microenterprises that provide services are exempt from the EAA’s requirements. Microenterprises that manufacture or sell covered products are not exempt, although they have lighter documentation obligations.

If you’re a small agency building websites for clients, note that your client’s obligations matter too. An e-commerce business with 50 employees is covered, even if the agency that built its site is tiny.

What does “accessible” mean under the EAA?

The directive sets out functional accessibility requirements in its annexes: information must be perceivable, operable, understandable and robust, which mirrors the WCAG principles. In practice:

Websites and apps are generally assessed against EN 301 549, the European standard for ICT accessibility. The latest version, EN 301 549 v4.1.1 (published September 2026), adopts WCAG 2.2 Level AA for web content and maps its requirements to the EAA. It is expected to be cited in the EU Official Journal as the harmonised standard for the EAA around the end of 2026. The previous version referenced WCAG 2.1 AA, so if you are starting work now, target WCAG 2.2 AA.
Documents, such as PDFs and e-books, are expected to be accessible too.
Support services, such as help desks and call centres, must provide information about the service’s accessibility in accessible formats.

The EAA compliance checklist

Step 1: Map your scope

List every website, app and digital channel EU consumers use.
Identify which are covered (checkout, banking, booking, e-book delivery and so on).
Include third-party components: payment widgets, chatbots, booking engines, cookie banners.
Note documents customers rely on: invoices, contracts, terms, e-tickets.

Step 2: Audit against WCAG

Run automated scans to catch obvious issues quickly.
Do a manual audit of key user journeys (sign-up, search, product page, checkout, account) with keyboard, screen readers and zoom. My screen reader testing guide shows how to start.
Prioritise findings by user impact and legal risk, not just by count.

Step 3: Fix the barriers

Fix blocking issues in key journeys first: keyboard traps, unlabelled form fields, inaccessible payment steps, missing error messages. See accessible forms and keyboard accessibility.
Fix systemic issues in your design system or theme so fixes apply everywhere.
Ask vendors of third-party components for their accessibility conformance documentation.
Don’t rely on an overlay widget. It won’t make an inaccessible site compliant.

Step 4: Publish accessibility information

Write an accessibility statement that explains how your service meets the requirements, known limitations, and how users can report problems or request alternatives.
Link it from your footer and from relevant places in your app.
Make the statement itself accessible.

Step 5: Build it into your process

Add accessibility acceptance criteria to new features.
Train designers, developers and content editors.
Re-test after major releases.
Set up a process to respond to accessibility complaints quickly.

Exemptions and transition periods

The EAA includes some limited flexibility:

Disproportionate burden: a business can argue that meeting a requirement would impose a disproportionate burden. This requires a documented assessment, must be reviewed regularly, and is not a general excuse.
Fundamental alteration: requirements don’t apply where they would fundamentally change the nature of the product or service.
Transition periods: service contracts agreed before 28 June 2025 can continue unchanged until they expire, but no later than 28 June 2030. Self-service terminals already in use can continue until the end of their economically useful life, up to 20 years.

These are narrow. For most online businesses, the practical path is to make the website and app accessible.

What happens if you don’t comply?

Enforcement is handled by national market surveillance authorities in each member state, and penalties are set nationally. Depending on the country, they can include fines and orders to correct or withdraw a service. Beyond fines, there is reputational risk, lost sales from the large number of customers with disabilities and older customers, and the cost of rushed remediation.

How much does compliance cost?

It depends on the size of the site and how accessible it already is. A small e-commerce site built on a reasonable theme can often fix most issues in weeks. A large, custom application built without accessibility in mind can take much longer. The single biggest cost driver is how late you start: fixing a design system once is far cheaper than fixing hundreds of pages one by one.

Conclusion

The EAA isn’t going away, and it applies to more businesses than most people think, including many outside the EU. Map your scope, audit your key journeys, fix the blocking issues, publish an honest accessibility statement and build accessibility into how you work. Doing that well also makes your product easier to use for every customer.

If you need an independent audit against WCAG 2.2 and EN 301 549, see my accessibility audit services for EU and US businesses.

European Accessibility Act Checklist: What Small and Medium Businesses Need to Do

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