The European Accessibility Act: a 2025 guide
The European Accessibility Act stopped being a future problem on 28 June 2025. Since that date, Directive (EU) 2019/882 applies to in-scope products and services sold to consumers in the European Union, and market surveillance authorities in each member state can now act on complaints. This guide covers what the law actually says, who it touches, and what a sensible response looks like for the people who build and maintain websites.
Where the EAA came from
For two decades, EU accessibility rules concentrated on the public sector. The Web Accessibility Directive of 2016 required government websites and apps to conform to a technical standard and to publish accessibility statements, but a private online shop had no equivalent obligation. The EAA closes that gap. It was adopted in 2019, member states transposed it into national law by June 2022, and the obligations for services took effect in June 2025.
The reasoning behind it is an internal market argument as much as a civil rights one: 27 different national accessibility regimes make it expensive to sell across borders, and roughly 100 million people in the EU live with some form of disability. One harmonized set of requirements serves both problems.
Who is in scope
The EAA lists product categories (computers, payment terminals, e-readers, self-service kiosks) and service categories. The service list is the one that matters for web work:
- E-commerce services, meaning essentially any website or app through which consumers can conclude a contract or purchase
- Consumer banking services
- Electronic communications services
- Access to audiovisual media services
- Elements of air, bus, rail, and waterborne passenger transport, including ticketing and real-time travel information
- E-books and dedicated reading software
E-commerce is the broadest hook. A retailer in Lyon, a SaaS product with an EU checkout, a booking widget on a hotel site: all plausibly in scope. The seller does not need to be established in the EU; selling to EU consumers is what counts.
There is one significant carve-out. Microenterprises providing services, defined as fewer than ten employees and no more than 2 million euros in annual turnover or balance sheet, are exempt from the service obligations. Two cautions apply. First, the exemption covers services, not products. Second, larger partners often push conformance requirements down contractually, so a micro-agency building a shop for a mid-size retailer will still be asked to deliver accessible work.
What conformance means technically
The directive itself is written as functional requirements: information must be perceivable and understandable, interfaces must be operable, content must work with assistive technologies. To get a presumption of conformity, you meet the harmonized standard, EN 301 549, whose web chapter incorporates WCAG 2.1 Level AA.
So the practical target for a website is not new or exotic: WCAG 2.1 AA, the same baseline used by courts in the United States and by public sector rules across Europe. If a site genuinely meets 2.1 AA and can show it, the technical side of the EAA is substantially handled. Targeting WCAG 2.2 AA instead is a reasonable forward-looking choice, since 2.2 includes everything in 2.1.
How enforcement actually works
Because the EAA is a directive, enforcement is national. Each member state designated authorities and set penalties, which range from fines of a few thousand euros to six-figure amounts and, in some states, exclusion from public procurement. There is no EU-level accessibility police; there are Irish, German, Dutch, French regimes with a shared rulebook.
Most regimes are complaint-driven. A consumer or advocacy organization reports an inaccessible service, the authority requests information, and the provider must demonstrate conformance or commit to remediation on a timeline. This shapes the correct strategy: the businesses in a bad position are not those with a known issue list and a documented fix program, but those with nothing to show at all.
A realistic program for an agency or site owner
- Establish the baseline. Audit the real user journeys against WCAG 2.1 AA, including logged-in flows such as account pages and checkout, which is where e-commerce obligations actually bite. Automated testing finds roughly half the criteria; a manual review covers the rest.
- Prioritize by user impact. Blocking failures in forms, navigation, and payment come before cosmetic contrast issues on a rarely visited page.
- Fix and record. Keep a dated record of what was found, what changed, and when a fix was verified. This record is your evidence if an authority ever asks.
- Publish an accessibility statement that reflects the true state, including known limitations and a working feedback channel.
- Re-audit on a cadence. Sites regress. Quarterly is a common rhythm for actively developed sites.
Documentation deserves emphasis because it is the cheapest insurance available. An authority that receives a complaint and finds a current statement, an audit history, and an active remediation log will behave very differently than one that finds silence.
Where tooling fits
The audit-fix-document loop above is exactly what Complaudax is built for: it audits pages in your own browser session, including behind logins, keeps every issue per client and site until it is fixed, and generates the conformance report and statement from real history. The free plan covers a full single-client workflow, which is enough to run your first EAA baseline audit end to end.
The EAA does not demand perfection overnight. It demands that accessibility become a maintained property of a service, with evidence. Start with the baseline audit, and the rest of the program follows naturally.