Preparing for the European Accessibility Act: Steps to Ensure Compliance

According to the European Blind Union there are now over 30 million blind and partially sighted people across geographical Europe, and an average of 1 in 30 Europeans experiencing sight loss. For these individuals, everyday tasks are unnecessarily exacerbated by poorly designed products and support services that make their use simply inaccessible. The European Accessibility Act (EAA) is designed to address this.

With the June 28th 2025 deadline fast approaching for the European Accessibility Act (EAA), is your business prepared?

The European Accessibility Act (EAA) aims to create a more accessible digital and physical world. For any company offering products or services in the EU, this Act introduces clear obligations, with the potential for serious consequences in case of non-compliance.

Contents

• Understanding the Scope and Impact of the European Accessibility Act
  
• Who Does the EAA Apply To?
  
• Key Sectors and Services Affected
  
• A Broader Accessibility Mandate
• Step-by-Step Roadmap to Compliance
  
• Consequences of Failing to Act
  
• A Strategic Imperative
  

Understanding the Scope and Impact of the European Accessibility Act

At its core, the European Accessibility Act (EAA) is designed to standardize accessibility requirements across the EU, eliminating the confusion around national regulations that have historically made compliance complex and inefficient.

The EAA creates fairness for individuals with disabilities and also gives businesses a clear, unified framework for designing accessible products and their associated services for European consumers.

Who Does the EAA Apply To?

Although the Act is primarily aimed at the EU, its impact extends globally, establishing a new standard for accessibility worldwide. Organizations outside the EU that offer products or services within the Union will need to adhere to its accessibility requirements. Meeting these standards will not only help minimize legal risks but also enable businesses to engage with a broader customer base.

If your product or service reaches an EU consumer, whether you’re based in Berlin, Boston, or Japan, you are within the scope of the EAA.

Key Sectors and Services Affected

The EAA casts a wide net, targeting both digital experiences and physical interfaces across several sectors. Below are some of the primary areas that will be impacted:

E-Commerce Platforms and Payment Systems

• Online marketplaces, retail stores, and digital shopping carts must be navigable by screen readers and keyboard-only users.
• Payment authentication steps must support alternative input methods and be clearly understandable by all users.

Websites and Mobile Applications

• All user-facing content must meet WCAG 2.1 Level AA standards.
• This includes not just text and navigation, but multimedia content, forms, buttons, and interactive elements.
• Mobile applications must offer consistent accessibility across iOS and Android platforms.

Media Services and Public Information Platforms

• Streaming services, news sites, and content portals must include features like subtitles, captions, audio description, and keyboard-accessible media controls.
• Public sector websites, including those providing legal or civic information, must also comply to ensure access to essential services.

Self-Service Terminals

ATMs, ticketing machines, check-in kiosks, and other interactive hardware must include:

• Tactile interfaces and audio output
• Clear visual contrast
• Logical navigation for users with cognitive or physical impairments

Public Transportation Information Systems

Systems for purchasing tickets, viewing schedules, or receiving real-time updates (online or in-station) must:

• Support alternative input and output formats
• Be usable by people with low vision, mobility impairments, or cognitive disabilities

A Broader Accessibility Mandate

When evaluated according to WCAG standards, most websites fall short of compliance.

In fact, a WebAIM survey examining the top one million websites revealed that 95.9% had identifiable WCAG violations on their homepages, averaging 56.8 errors per page. The most frequently encountered accessibility problem was low-contrast text, affecting 81% of homepages.

As well as this, Accessibility.com found that 2,281 website accessibility lawsuits were filed in 2023, and 26% of those lawsuits were filed against companies that had been sued previously.

While the EAA heavily references the Web Content Accessibility Guidelines (WCAG 2.1), it expands the mandate far beyond websites and apps.

The EAA introduces expectations for hardware design, customer service accessibility, and cross-device consistency, ensuring people with disabilities can complete tasks independently and without barriers.

It moves the conversation from merely “accessible websites” to a full-spectrum view of accessibility that includes:

• Device operability
• Information clarity
• Service and support
• Physical usability
• Accessible user journeys across digital and real-world touchpoints

This expanded view of accessibility establishes a higher standard for compliance, encouraging businesses to adopt a comprehensive approach. It involves integrating inclusive design principles throughout all phases of product development, service delivery, and customer support.

Step-by-Step Roadmap to Compliance

Assessment & Impact Scoping

1. Audit Your Products and Services
   Identify which offerings fall under the EAA’s scope. This means both direct-to-consumer platforms and any systems that involve customer interaction.
2. Evaluate Current Accessibility Gaps
   Benchmark against WCAG 2.1 standards for digital assets and review physical designs and customer service touchpoints.
3. Involve Legal and Risk Teams
   Ensure your legal counsel understands national variations in enforcement and reporting expectations.
4. Get Leadership Buy-In
   Share the business case: avoiding fines and reputational risk, improving customer reach, and fulfilling your accessibility commitments.

Design Your Accessibility Roadmap

Include product managers, engineers, compliance officers, designers, customer service, and legal stakeholders.

1. Develop a Phased Plan
   – Fix known accessibility blockers on core platforms.
   – Ensure physical and digital product interfaces meet EAA standards.
   – Embed accessibility into all future design and procurement decisions.
2. Prioritize Early Wins
   Consider implementing Accessible Customer Service as a pilot, like using tools such as Be My Eyes for live, accessible support for blind and low-vision users.

Implementation and Testing

Build or revise platforms with universal design principles, not retrofitted fixes.

1. Train Your Teams
   Offer targeted training for developers, designers, content creators, and frontline customer support.
2. Test with Real Users
   Engage users with disabilities to validate the accessibility and usability of your solutions.
3. Document and Report
   Prepare transparency reports that demonstrate accessibility compliance. Ensure your documentation is itself accessible.

Future-Proofing Beyond 2025 and EAA Compliance

1. Continuously Monitor and Improve
   Accessibility is not a one-and-done project. Schedule periodic audits and user testing post-2025.
2. Leverage Assistive Technologies and Innovation
   Invest in tools like:
   – Conversational AI for accessible customer service
   – NLP-powered speech interfaces
   – AR navigation tools for public space accessibility
   – Automated accessibility checkers for dev environments
3. Think Beyond Compliance
   The most forward-thinking organizations such as Microsoft and Apple, use accessibility to drive innovation, increase market reach, and build stronger customer trust

While accessibility has often, and wrongly been viewed as a recommendation, with the June 28th data for EAA compliance, it is now a legal obligation. As such, organizations that delay or deprioritize compliance expose themselves to significant and avoidable risks.

Consequences of Failing to Act

Unlike earlier accessibility laws, the EAA includes specific enforcement mechanisms, empowering consumer protection authorities and courts to take action when accessibility standards are not met.

Each EU member state is required to define and enforce penalties for non-compliance under the EAA and the consequences will be substantial. These include:

• Monetary fines: Comparable to GDPR penalties in scale, especially for repeat or large-scale violations.
• Litigation: Both individuals and disability rights organizations will have legal standing to bring forward claims against non-compliant companies. Lawsuits could be public, costly, and prolonged.
• Regulatory investigations: Failure to produce clear documentation or accessibility audit trails may trigger full regulatory reviews and public enforcement actions.

Market Exclusion and Lost Revenue

One of the most direct consequences of non-compliance is being barred from selling your products or services in the EU. Regulators have the authority to:

• Remove non-compliant products from distribution and app stores
• Block access to online services or platforms within EU territories
• Disallow public procurement bids from non-accessible vendors

This poses an existential risk to businesses that rely on EU customers, partners, or supply chains. It also creates barriers to future growth, especially for digital-first companies expanding into European markets.

Brand Damage, Lost Trust, and Customer Churn

A recent Acquia survey revealed that poor digital accessibility can have a direct and significant impact on a company’s bottom line. Over half of respondents (51%) said they would likely switch to a more accessible alternative, while 42% indicated they would stop using a brand’s services altogether if accessibility issues were present.

Failing to meet accessibility standards signals a lack of concern for a significant segment of your user base. Risks include:

• Public backlash on social media and review sites
• Negative media coverage, especially if users with disabilities are denied access or support
• Loss of contracts with corporate or government clients who have their own inclusion mandates
• Reduced customer loyalty, especially among Gen Z and Millennial consumers who prioritize ethical and accessible businesses

A Strategic Imperative

With the European Accessibility Act (EAA) taking effect on 28th June 2025, companies that delay compliance risk not just enforcement penalties and restricted market access, but also the erosion of consumer trust in a world that increasingly values inclusion.

However, businesses that take a proactive approach gain much more than compliance. They will build trust, improve usability for everyone, and position their brand as a leader in accessible innovation. Prioritize quick wins, like making customer support more accessible, and partner with accessibility technology experts such as Be My Eyes.

Want to learn more? Download our Free EAA eBook to learn how your organization can prepare for 2025 and beyond.