European Accessibility Act: a practical guide for small teams

What the EAA is

The European Accessibility Act is an EU directive that sets common accessibility rules for key products and services across all member states. It has applied since 28 June 2025. For most digital businesses, it means your website, web app, and mobile app must be usable by people with disabilities, including people who use screen readers, keyboards, voice control, or zoom.

Who it applies to

The EAA covers businesses that offer these services to consumers in the EU:

• E-commerce: any website or app that sells products or services online.
• Banking and financial services for consumers.
• E-books and the software used to read them.
• Electronic communications and access to audiovisual media services.
• Passenger transport services: websites, apps, e-tickets, and real-time travel information.

It also covers products such as computers, smartphones, e-readers, ATMs, and ticket machines. If you run a SaaS sold only to businesses, the EAA may not apply directly, but your customers who sell to consumers will increasingly expect it from their vendors.

Exemption: micro-enterprises providing services (fewer than 10 people and €2 million or less in annual turnover or balance sheet) are exempt from the service requirements. There is also a "disproportionate burden" exception, but you must document the assessment and it does not cover simply not wanting to spend the money.

What it requires

• Accessible content and interfaces. In practice: meet EN 301 549. Version 3.2.1 points to WCAG 2.1 AA for the web, and the newer 4.1.1 points to WCAG 2.2 AA, so we recommend targeting WCAG 2.2 AA.
• Information about accessibility. Service providers must explain how the service meets the requirements, usually in an accessibility statement.
• Ongoing conformance. New features and content must stay accessible, not just the version you audited once.

A 7-step plan for small teams

1. Confirm scope. List the sites, apps, and flows customers use: browsing, sign-up, checkout, account, support.
2. Run automated checks. Automated tools such as axe-core find roughly a third to a half of WCAG issues quickly: contrast, missing labels, alt text, ARIA misuse. Run them on every template, not only the home page.
3. Test manually. Use the site with only a keyboard. Try a screen reader (VoiceOver on Mac, NVDA on Windows) on your key flows. Zoom to 200% and 400%.
4. Fix by impact. Start with anything that blocks a task: checkout, forms, login, and navigation. Fix shared components first so every page benefits.
5. Publish an accessibility statement with your standard, status, known issues, and contact details. Use our free statement generator.
6. Add a feedback channel and reply within a set time.
7. Build it into your process. Check accessibility in design reviews, pull requests, and before every release, so you do not drift out of conformance.

The issues audits find most

WebAIM's yearly analysis of the top million home pages finds the same handful of problems year after year:

WCAG 2.2 adds a few that catch modern designs: focused elements completely hidden under sticky headers (2.4.11), touch targets smaller than 24×24 pixels (2.5.8), and drag-only interactions without an alternative (2.5.7).

Why overlays are not the answer

Accessibility overlays add a widget on top of your site and promise compliance with one line of code. They do not change your underlying HTML, they often conflict with the assistive technology people already use, and sites using them still receive complaints and lawsuits. Fixing the code is the only durable route. See our comparison with accessiBe.