Does the European Accessibility Act (EAA) apply to my business?

It applies to any business selling products or services to EU consumers (e-commerce, banking, transport ticketing, e-books), including companies based outside the EU. Microenterprises providing services (fewer than 10 employees and under 2 million euro turnover) are exempt, though their business customers may still demand conformance contractually.

Which WCAG version does the European Accessibility Act (EAA) require?

The referenced standard is EN 301 549, which incorporates WCAG 2.1 AA for web content. WCAG versions are backwards-compatible, so building to the current WCAG 2.2 AA satisfies the older versions laws cite and protects you as standards are updated.

Does an accessibility overlay or widget make me compliant?

No. Overlay widgets inject a script that tries to repair issues in the browser at display time. Regulators and courts have rejected this approach: the US FTC fined a leading overlay vendor $1 million in 2025 for deceptive compliance claims, the European Commission has stated overlays do not confer conformance, and hundreds of US lawsuits in recent years have been filed against sites that were running an overlay at the time. Real compliance means fixing your actual markup and keeping evidence that you did.

Can an automated scan alone make me compliant?

Not by itself, and any vendor claiming otherwise is misleading you. Roughly a third of WCAG success criteria can be checked by a machine, though those criteria account for the majority of violations found in real audits by volume. An automated scan is the fastest way to find and fix the bulk of your issues and to prove ongoing diligence, but full conformance also requires human judgment for things like alt-text quality, logical reading order, and form error recovery. The strongest position combines automated monitoring with a periodic manual audit.

European Accessibility Act (EAA): website compliance, explained

The European Accessibility Act (EAA) applies to any business selling products or services to EU consumers (e-commerce, banking, transport ticketing, e-books), including companies based outside the EU. It has been enforced since June 28, 2025.

The technical benchmark is EN 301 549, which incorporates WCAG 2.1 AA for web content. In practice, that means your site must be perceivable, operable, understandable, and robust for users with disabilities, from screen-reader users to keyboard-only navigation to low-vision users who need sufficient color contrast.

Timeline and current status

The EAA was adopted in 2019, member states transposed it into national law by June 2022, and the obligations for new products and services took effect on June 28, 2025. Services already on the market before that date have a transition window running to June 28, 2030, but any substantial redesign or relaunch typically restarts the clock and brings the site into scope immediately.

What enforcement actually looks like

National market-surveillance authorities can order remediation, block services, and impose fines. The first private lawsuits were filed in France in late 2025, and in 2026 a French court ordered a major retailer to make its site and app accessible under a daily penalty.

What WCAG requires, in plain terms

WCAG (Web Content Accessibility Guidelines) is organized around four principles: content must be perceivable (e.g. images have text alternatives, text has sufficient contrast), operable (everything works with a keyboard, users have enough time, nothing traps focus), understandable (pages are readable, predictable, and help users avoid mistakes), and robust (markup is parseable by assistive technologies like screen readers). Each guideline has testable success criteria at three levels: A (minimum), AA (the level essentially every law references), and AAA (aspirational). Conformance at AA means meeting all A and AA criteria. The current version is WCAG 2.2, published in October 2023, which added nine criteria to WCAG 2.1, including minimum target sizes for buttons and links, visible focus indicators, and easier authentication.

The violations that actually show up on real sites

Across the millions of pages tested in large-scale studies like WebAIM's annual survey of the top one million homepages, the same handful of failures dominate: low-contrast text (found on roughly four out of five homepages), images missing alternative text, form inputs without labels, empty links and buttons, and missing document language. In our own scans of e-commerce sites, we also routinely find keyboard traps in carousels and mega-menus, focus indicators removed with CSS, modal dialogs that screen readers never announce, and touch targets far below the 24 by 24 pixel minimum WCAG 2.2 requires. Most of these are cheap to fix individually. The expensive part is finding them all and keeping them fixed as the site changes, which is exactly what automated monitoring is for.

Why overlays and widgets don't help

Regulators on both sides of the Atlantic have rejected overlay widgets as a compliance shortcut. The US FTC fined a leading overlay vendor $1M in 2025 for deceptive 'one-line-of-code compliance' claims, and the European Commission has stated overlays do not confer conformance. Compliance means fixing your actual markup, and being able to prove you did.

What a defensible position looks like

Enforcement bodies and plaintiffs' lawyers respond to evidence: a documented scan history, a prioritized remediation log, and visible progress. A site with a timestamped record of continuous scanning and fixing is in a categorically stronger position than one with no paper trail, even at the same level of technical conformance. That evidence trail is also what an accessibility statement, a VPAT, or a response to a demand letter gets built from.

Compliance checklist

Run an automated WCAG scan of your key pages (home, product/service, checkout or contact)
Fix critical and serious violations first, since these carry the most legal and usability weight
Keep a dated log of what was found and what was fixed
Re-scan on a schedule; every deploy and CMS edit can introduce regressions
Add a manual audit for the criteria automation can't check (roughly two-thirds of WCAG)
Publish an accessibility statement describing your conformance status and contact route

Frequently asked questions

Does the European Accessibility Act (EAA) apply to my business?: It applies to any business selling products or services to EU consumers (e-commerce, banking, transport ticketing, e-books), including companies based outside the EU. Microenterprises providing services (fewer than 10 employees and under 2 million euro turnover) are exempt, though their business customers may still demand conformance contractually.
Which WCAG version does the European Accessibility Act (EAA) require?: The referenced standard is EN 301 549, which incorporates WCAG 2.1 AA for web content. WCAG versions are backwards-compatible, so building to the current WCAG 2.2 AA satisfies the older versions laws cite and protects you as standards are updated.
What are the penalties for non-compliance?: National market-surveillance authorities can order remediation, block services, and impose fines. The first private lawsuits were filed in France in late 2025, and in 2026 a French court ordered a major retailer to make its site and app accessible under a daily penalty.
Does an accessibility overlay or widget make me compliant?: No. Overlay widgets inject a script that tries to repair issues in the browser at display time. Regulators and courts have rejected this approach: the US FTC fined a leading overlay vendor $1 million in 2025 for deceptive compliance claims, the European Commission has stated overlays do not confer conformance, and hundreds of US lawsuits in recent years have been filed against sites that were running an overlay at the time. Real compliance means fixing your actual markup and keeping evidence that you did.
Can an automated scan alone make me compliant?: Not by itself, and any vendor claiming otherwise is misleading you. Roughly a third of WCAG success criteria can be checked by a machine, though those criteria account for the majority of violations found in real audits by volume. An automated scan is the fastest way to find and fix the bulk of your issues and to prove ongoing diligence, but full conformance also requires human judgment for things like alt-text quality, logical reading order, and form error recovery. The strongest position combines automated monitoring with a periodic manual audit.