The European Accessibility Act became enforceable on 28 June 2025. A year on, there is enough data to say what actually happened, and the picture is more mixed than either the alarmists or the people who ignored it expected.
What the law requires
The EAA is Directive (EU) 2019/882. It requires that certain consumer-facing products and services be accessible to people with disabilities.
The technical standard is EN 301 549, which for websites and mobile applications references WCAG 2.1 Level AA. That is the practical target.
Covered services include e-commerce, consumer banking, telecommunications, passenger transport including ticketing and travel information, e-books, and audiovisual media services. Covered products include computers, smartphones, payment terminals and self-service kiosks.
It applies to any business offering those services to EU consumers, regardless of where the business is based.
Who is genuinely exempt
Two exemptions, both narrower than commonly assumed.
Microenterprises providing services. Fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million. Both conditions must be met. Eight employees and €5 million in turnover does not qualify.
Two important limits on this. It applies to service obligations only, so a microenterprise that manufactures a covered product is still caught on the product side. And there is no general exemption for small businesses as a category. The threshold is specific.
Disproportionate burden. Available in individual cases, but it requires a documented, formal assessment. It is not a position you can adopt informally and it is assessed strictly.
There is also an exception for archived content, meaning material not updated after the enforcement date. Active services do not benefit from it.
What the first year showed
Transposition is formally complete across all 27 member states, though implementation quality varies considerably.
Penalty ceilings differ sharply by country, ranging from around €5,000 at the low end to figures approaching a million euros in some jurisdictions, with at least one member state calculating penalties as a percentage of turnover. Most authorities issue a remediation order before imposing a financial penalty, which means the realistic first consequence is a deadline to fix things rather than an immediate fine.
Automated scanning of large EU-facing e-commerce properties found fewer than half passing at WCAG 2.1 AA. Enforcement so far has concentrated on larger operators and on complaints, which is the usual pattern with new market surveillance regimes.
The Commission is required to review the Directive by June 2030, including the scope of the microenterprise exemption. That is worth noting for anyone currently relying on it.
What to do if you are covered
Run an automated scan first. Free and paid tools will catch a meaningful share of issues in minutes. They will not catch everything, but they establish a baseline and they are the cheapest possible starting point.
Fix the common failures. In practice most sites fail on the same handful of things: insufficient colour contrast, images without alternative text, forms without proper labels, functionality that cannot be reached by keyboard alone, video without captions, and headings used for visual styling rather than structure.
Test with a keyboard. Unplug the mouse and try to complete a purchase. This single test surfaces a surprising number of blocking problems and costs nothing.
Publish an accessibility statement. Required, and frequently missing. It should describe your conformance level, known limitations and how to report problems.
Document your progress. Good faith under the EAA means demonstrable, documented movement toward conformance, not perfection on day one. A dated remediation plan is worth having if an authority asks.
Avoid overlay widgets. The scripts that promise instant compliance through a single line of JavaScript do not deliver it. Accessibility organisations have been consistent on this, and in some jurisdictions their use has attracted attention rather than deflecting it. Fix the underlying markup.
Why this is worth doing anyway
Around 87 million people in the EU have some form of disability. Accessible sites work better for everyone, including people on phones in bright sunlight and people with temporary impairments.
There is also a search dimension. Proper heading structure, alternative text and semantic markup are things accessibility and search engines both want. Accessibility work tends to improve technical SEO as a side effect.
The vendor question
If you buy software that faces your customers, your compliance depends partly on the vendor's. Ask directly what their conformance position is and whether they can provide documentation.
European vendors tend to be better prepared here, since it is their home regulation. It is a fair question to ask during evaluation, alongside the data processing agreement and the security documentation. A vendor who cannot answer it in 2026 has not been paying attention to their own market.
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