Is the European Accessibility Act the end of the world as we know it?
The European Accessibility Act is about to shake things up across the EU, aiming to make accessible products and services the norm, not the exception.
The European Accessibility Act (EAA) is here, and with it, a comprehensive set of accessibility requirements is now in effect across Europe.
This isn’t a small regional regulation; it simultaneously applies in 27 countries under the European Union’s umbrella, aligning them under one common set of rules. In practice, that means a company operating in France, Germany, or any other EU nation will face the same accessibility obligations and standards. Here’s where it now applies:
Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden. Phew! 😮💨
This is going to be a long one, there's a lot that the EAA covers, so what's the TLDR? For businesses, this date marks a major shift. The era of patchwork national accessibility rules is ending; a unified standard now prevails across the EU . With no more excuses, companies and organisations will be expected to meet these accessibility requirements or face consequences; read on to find out more.
What is the European Accessibility Act and Who Needs to Comply?
The EAA (formally EU Directive 2019/882) is a landmark law aimed at eliminating barriers in the internal market by standardising accessibility requirements for products and services across EU member states. Previously, rules varied from country to country, leading to fragmentation. Now, under the EAA, all EU nations share common accessibility standards, making it easier for businesses to sell compliant products and services throughout Europe. This “design for all” approach aligns with the principles of the UN Convention on the Rights of Persons with Disabilities, emphasising that products and services should be usable by everyone without special adaptation.
Who must comply?
In short, most businesses that operate in or sell to the EU. The EAA places obligations on a wide range of economic operators, from manufacturers and service providers to importers and distributors, anyone placing in-scope products or services on the EU market. If your company is based in the EU or you offer products/services to customers in the EU, you’ll likely be required to meet EAA standards. (There are limited exceptions for the very smallest “micro-enterprises” and cases of undue burden, but these are narrow carve-outs.) For everyone else, June 28, 2025 is a firm deadline.
Notably, the law applies to new products placed on the market and new service contracts from that date forward. In other words, any covered product first sold or service contract agreed after June 28, 2025 must be accessible. Products already on the market before that date get a bit of breathing room, they must be made compliant by June 28, 2030 at the latest (a transitional period intended to give companies time to update or phase out older models). But don’t let that later date lure you into complacency: for new offerings, the clock is ticking now.
Key Areas of Compliance: Where Accessibility Must Be Achieved
Companies and organisations will no longer have any excuses, under the EAA they are required to be accessible in the following areas of products and services. The law targets a range of sectors and technologies that are considered most vital to persons with disabilities (and which previously had inconsistent rules across Europe).
Websites and Mobile Applications (including E-commerce)
The digital gateways to your business must be accessible. This includes company websites, online e-commerce platforms, mobile apps for services, and other internet-delivered services. Whether it’s an online retail site, a banking app, a video streaming platform or a public transport booking site, if it serves European consumers it needs to comply with the EAA’s accessibility criteria (largely based on the POUR principles: Perceivable, Operable, Understandable, Robust, aligned with WCAG guidelines ).
In practical terms, that means features like text alternatives for images, proper colour contrast, keyboard navigation, captions on media, and so on should be in place so that users with visual, auditory, motor or cognitive disabilities can use your site or app. After June 2025, an inaccessible website or app isn’t just bad form, it’s illegal in these markets.
Self-Service Terminals: ATMs, Ticketing & Check-In Machines
The EAA covers public-facing self-service devices that people use to buy tickets, get cash, check in for travel, or similar tasks. Think of bank ATMs, train station ticket kiosks, airport check-in machines, parking payment terminals, vending machines, and the like. These machines must be usable by people with disabilities.
For example, an ATM should have tactile keys or an audio output option for blind users, height and reach considerations for wheelchair users, and clear on-screen navigation.
If your business deploys kiosks or self-service points, you’ll need to ensure their hardware and software meet the new standards (or plan to upgrade them). The days of a visually-impaired customer struggling with a ticket machine with no audio assistance should become a thing of the past.
Computers, Smartphones and Operating Systems
The law isn’t limited to niche devices; it also targets mainstream consumer tech. Manufacturers of computers, laptops, tablets, smartphones, and their operating systems will need to build in accessibility. This might include screen reader compatibility, assistive tech support (e.g. magnifiers, switch controls), accessible documentation and user guides, and other “built-in” features.
By 2025, new computers and phones sold in the EU should have accessibility features out-of-the-box, which many modern devices (like iPhones with VoiceOver, etc.) already do, but the EAA will make it a uniform requirement. If your company produces software or hardware for the EU market, you’ll need to follow the relevant European standards (such as EN 301 549 for ICT accessibility) to ensure your product complies.
Telecommunications and Media Services
Telephony services and equipment, as well as audio-visual media services, are also in scope. This means telephone networks and smartphone communication services must accommodate users with disabilities (for instance, compatibility with relay services for deaf users, or accessible interfaces on telephone devices).
For media, the Act covers television broadcast services and related consumer equipment. Providers of digital TV services, streaming platforms, set-top boxes, and TV interfaces will need to ensure features like subtitles, audio description, and easy-to-navigate menus.
Essentially, from your cable box to your Netflix app, the user experience should be barrier-free. If you’re in telecom or media, be prepared to offer things like accessible customer service lines (text relay or chat for those who can’t use voice calls) and accessible content delivery.
Banking and Financial Services
The Act explicitly includes consumer banking services. Banks and financial institutions must ensure their services are accessible, this spans everything from online banking websites and mobile banking apps to payment terminals and ATMs (which overlap with self-service terminals mentioned above).
Features like accessible PIN pads, speech output for card readers, or simply an easy-to-use, WCAG-compliant online banking portal are no longer optional. Considering how essential banking is in daily life, this area is a high priority: a customer with a visual impairment, for example, should be able to check their account or make a payment as independently as any other customer.
The EAA mandates that from the interface to the information provided (statements, forms, etc.), no customer is left in the dark (figuratively or literally).
Transportation Services
If your business involves passenger transport (airlines, bus companies, rail operators, ferry services, etc.), note that services related to air, bus, rail, and waterborne passenger transport are within the EAA’s reach. This doesn’t mean you must make the vehicles themselves accessible (that’s covered by other regulations), but the digital services and electronic systems around travel must be.
For instance, websites and apps for booking tickets or checking schedules must be accessible, as should interactive self-service ticket kiosks at stations (again, overlapping with the kiosk category). Real-time travel information systems, electronic boarding passes, and on-board entertainment or info systems likely also fall under accessibility requirements.
Travellers with disabilities should be able to independently plan trips, buy tickets, check in, and access travel info thanks to accessible tech. Given the tight timelines travel can involve, an inaccessible app or ticket machine can literally mean a missed train or flight, the EAA is here to prevent that scenario.
E-Books and Digital Publishing
The EAA also covers e-books and dedicated e-readers or e-reading software. Publishers and distributors of e-books will need to ensure their digital publications are accessible (for example, supporting text-to-speech, adjustable font sizes, and proper structural markup for navigation by screen readers).
If your company produces e-book content or e-reader devices/apps, you will have to follow accessibility guidelines so that readers with disabilities (visual impairments, dyslexia, etc.) can enjoy the content. This could entail providing alt text for images in e-books, ensuring compatibility with screen reader software, and enabling easy navigation (like jumping by chapters or sections with assistive tech). The goal is that a person who is blind can pick up an e-book from an online store and read it with a screen reader just as smoothly as a sighted person would read visually.
Summary of the EAA's Scope
As you can see, the scope of the EAA is broad, touching many aspects of the digital economy and everyday life, from the device in your pocket, to the ATM on the street corner, to the app you use to order dinner.
It’s truly a comprehensive effort to make products and services “accessible for all”. Businesses should review these categories closely to determine which apply to them. Many will find that multiple categories apply (e.g. a bank has to worry about ATMs, website/app, and documents; a telecom operator might have web, mobile, and equipment obligations). The key takeaway is that if you provide any of the above products or services in the EU market, you need to bake in accessibility by design going forward.
The good news is that by doing so, you’re not just avoiding fines, you’re opening your doors to a larger customer base (people with disabilities represent over 100 million consumers in the EU ) and offering a better experience for everyone.
Enforcement, Fines and Risks: What Happens if You Don’t Comply?
So, what if a company drags its feet or ignores these requirements? In short: it’s not worth the risk. The EAA has teeth! 🧛🏻♂️
Enforcement is handled at the national level, meaning each EU member state will have its own regulatory bodies (often called “market surveillance authorities”) to monitor compliance and address violations. These authorities can investigate complaints, conduct inspections, and impose penalties. Crucially, the directive mandates that penalties for non-compliance be “effective, proportionate and dissuasive”, in other words, not just a token slap on the wrist.
Fines
Companies that fail to meet accessibility requirements can face significant fines and financial penalties. Each country sets its own fine structure, and they vary widely, but none are trivial.
For example, one country might impose fines on the order of €5,000–€20,000 per violation, while another can go much higher, up to €500,000 or more in total penalties. In some cases, fines can even reach 5% of a company’s annual turnover for serious or repeated violations. Spain’s implementation, for instance, allows fines up to €1,000,000 for the most severe infringements.
The penalties can also escalate if problems aren’t fixed: regulators may levy daily cumulative fines for ongoing non-compliance, such as an additional fine (say €500–€1,000) per day until you remedy the issue. This means a stubborn failure to comply could snowball into hundreds of thousands of euros in fines over time.
Furthermore, because enforcement is nation-by-nation, a company operating in multiple EU countries could theoretically be fined by each country for the same accessibility lapses. In other words, non-compliance isn’t just a one-time hit, it can pummel you from all sides if you don’t address it promptly.
Market Restrictions
Beyond fines, regulators have other tools. Under the EAA, authorities can require businesses to take corrective action and even issue “stop orders” for products or services that flout accessibility rules. This could mean that a non-compliant product is barred from being sold, or a service that doesn’t meet the standards is ordered to halt operations until it’s fixed.
Imagine having to pull your flagship product off the EU market or shut down your app in Europe because it isn’t accessible, the financial and reputational damage from that alone would be devastating, even before any fines are counted. Non-compliance would mean losing access to the entire EU customer base!
Lawsuits and Legal Action
The EAA also empowers consumers and advocacy groups. Individuals who encounter barriers can report non-compliance to the national authority or take the issue to court, and organisations representing disabled consumers can act on their behalf. We’ve seen in other contexts (like the famous National Federation of the Blind vs. Target lawsuit in the U.S.) that failing to provide accessible services can lead to costly legal settlements and a lot of bad press.
Under the EAA framework, expect that advocacy groups in Europe will be vigilant and quick to call out companies that don’t follow the law. The possibility of discrimination claims or class-action style lawsuits (depending on national legal systems) is very real if a company is egregiously ignoring accessibility. At the very least, a formal complaint process can force you into remediation under the watch of regulators.
Essentially, the EAA adds a strong legal backing to what disabled customers have long demanded, equal access. Companies would be wise to treat accessibility complaints with the same seriousness they’d treat a data privacy complaint under GDPR.
Reputational Risks
Even if fines and legal actions aren’t enough incentive, consider the reputational damage. In the age of social media and heightened social responsibility, being named as a company that shuts out people with disabilities can seriously hurt your brand. Regulators may publish the names of offenders or the media might latch onto high-profile cases. Customers, investors, and partners increasingly value inclusion, you don’t want to be the company making headlines for the wrong reasons. As the Henderson Chambers accessibility law review succinctly put it, non-compliance can lead to “significant fines, reputational damage, and restrictions on access to the EU market”. That trifecta can be existentially threatening to a business.
In short, failing to comply with the EAA is playing with fire. The financial penalties alone could be steep, but the cumulative impact across multiple countries, potential removal from the market, lawsuits, and brand harm make it a risk simply not worth taking. The smart move for businesses is to approach accessibility proactively: conduct audits, fix issues before the 2025 deadline, and integrate inclusive design into your regular development cycle. The EAA enforcement regime is designed to catch laggards and push them into line, better to get ahead of it on your own terms.
Think of accessibility compliance as you would security or privacy compliance; it’s now a baseline expectation, not a nice-to-have. And remember, by doing the right thing, you’re not just avoiding punishment, you’re likely to gain customers and goodwill. Many companies are already proudly advertising their accessibility conformance as a competitive advantage. With enforcement looming, it’s time to ensure you can confidently say the same.
Beyond the EU
“But wait,” you might say, “didn’t the UK Brexit out of EU laws? Does the EAA apply to us here in the UK?” That’s a good question. Whilst it technically doesn’t apply to the UK and the rest of the world, as everyone knows, a “technical no” leaves a lot of wiggle room, so you’re not completely off the hook.
The EAA governs any in-scope products or services provided to consumers in the EU, regardless of where the provider is based. So if you’re a UK company (or a U.S. company, or anywhere else) and you want to sell in Europe or continue serving EU customers, you must meet these requirements.
For instance, a UK-based e-commerce website that ships to France or Germany will need to ensure its site and processes are EAA-compliant, or risk being barred from those markets.
The Act places obligations on economic operators outside the EU when they trade with the EU. As an expert legal analysis put it, “the EAA places obligations on UK businesses supplying in-scope products and services in the EU”. This isn’t limited to manufacturers; it includes distributors and retailers too. So even if your base country doesn’t mandate accessibility, the moment you cross the Channel (even digitally), EU law kicks in.
Essentially, Brexit or not, if you want access to 450 million EU consumers, you’ll need to play by EU accessibility rules.
Businesses in Northern Ireland should be especially alert. NI shares a land border with the Republic of Ireland (an EU member) and under the post-Brexit arrangements (like the Windsor Framework), Northern Ireland often aligns with certain EU single market rules for goods. While the exact applicability of the EAA to NI could be complex, the practical point is that many NI companies trade directly with Ireland and other EU markets. If you’re an NI-based company offering, say, software or services that are used by customers in Ireland, those offerings will fall under the EAA.
Moreover, keeping NI regulations in step with EU equality and accessibility advancements is important to avoid a divergence in citizens’ rights. Even absent a legal mandate, it would be a mistake for Northern Irish organisations to assume the EAA has nothing to do with them, the cross-border nature of commerce in Ireland means EAA compliance is very much a live issue.
In short, UK (and particularly Northern Irish) companies should treat the EAA as a de facto requirement if they have any European market presence. It’s better to build to the highest standard and be safe, rather than assume you’re exempt and get an unpleasant surprise when your product is flagged at an EU customs checkpoint, or your EU clients ask why your accessibility statement is missing.
Even outside of Europe, the EAA is part of a global trend. Just as GDPR (EU data privacy law) ended up influencing practices worldwide, the EAA’s high bar for accessibility will likely set expectations that reach beyond Europe’s borders. Companies in North America, Asia, and elsewhere that never previously considered EU accessibility rules might find that to remain competitive or to enter EU markets, they need to adopt these standards.
Countries and regions often look to each other’s laws, the existence of a comprehensive EU Act could inspire or pressure other governments to enhance their own accessibility regulations. Smart businesses will stay ahead by aligning with EAA standards globally, essentially “future-proofing” their products; Accessibility is becoming a baseline expectation worldwide, not just in Europe.
Remember, while the UK doesn’t have an EAA clone, the Equality Act 2010 still requires businesses to make “reasonable adjustments” to avoid discriminating against disabled customers, and public sector websites and apps in the UK already have to follow legally mandated accessibility standards (under the Public Sector Accessibility Regulations).
In summary, the EAA extends far beyond the EU’s borders. If you’re a business leader anywhere and have customers in Europe (or plan to), you should be paying close attention. The smart approach is to incorporate the EAA’s principles into your products now, it’s easier to build it right than to retrofit under regulatory pressure. Consider it an investment in global best practice.
How CIVIC Can Help You Meet Accessibility Goals (and EAA Requirements)
If all of this feels a bit overwhelming, you’re not alone. Many companies are currently asking themselves, “Are we ready for the EAA? Where do we even start to become compliant?” The good news is you don’t have to navigate this journey by yourself. CIVIC, as a digital solutions provider with deep expertise in accessibility, can be your guiding partner in this process. In fact, if you’re worried about the EAA, CIVIC can help turn that worry into confident action.
At CIVIC, we understand that accessibility is more than a tick-box exercise, it’s about making your digital content work for everyone. We combine practical know-how with a deep understanding of the latest regulations to ensure your online presence is rewarding for all users. Our team has been following the European Accessibility Act closely (along with standards like WCAG and UK-specific guidelines), and we’ve been helping organisations anticipate these changes. Here are some of the ways we support our clients on accessibility:
Accessibility Evaluations & Audits
We offer thorough accessibility audits for websites, mobile apps, and other digital platforms. This typically involves automated scanning to catch obvious issues and skilled manual testing by our experts (including testers with disabilities) to find the less obvious barriers. The result is a detailed assessment of where your product stands against EAA/WCAG standards and a clear roadmap of what needs fixing. Think of it as an accessibility health check for your digital assets, you’ll know exactly which parts of your site or app are falling short (be it missing alt text on images, poor keyboard navigation, forms that aren’t labelled properly, etc.) and we’ll prioritise recommendations to help you fix them efficiently.
Consultancy and Strategy
Compliance isn’t just one-and-done; it’s an ongoing process and often a cultural shift. Our consultants work with your team to develop an accessibility strategy that fits your organization’s workflows. We can review your design and development methodologies, product requirements, and documentation to pinpoint where accessibility needs to be integrated. From procurement policies (e.g., ensuring third-party software you buy is accessible) to design system updates (like setting colour contrast rules), we help embed accessibility principles organisation-wide. The goal is to move you from a reactive approach (“let’s fix issues for the audit”) to a proactive stance (“let’s build it accessible from the start”). This not only ensures sustained compliance but also can improve overall UX and innovation.
Accessibility Testing (User Testing)
There’s no substitute for getting real user feedback. CIVIC can conduct accessibility testing with representative user groups, people with various disabilities who use assistive technologies. We test your website or app at various stages (from prototype to live) to gather invaluable insights. Watching someone use a screen reader or navigate via keyboard on your site can reveal usability issues that automated tests might miss. We then help you interpret the results and adjust your product accordingly. Our philosophy is that testing with users should be part of your development cycle, not just a final checkbox, because it often leads to a better product for all users.
Training and Capacity Building
A long-term compliance strategy involves empowering your team. CIVIC offers training programmes to raise awareness and build skills in-house. From general accessibility awareness sessions for all staff (to foster an inclusive mindset) to role-specific workshops (like practical accessibility techniques for developers, or how to write accessible content for copywriters), we tailor the training to your needs. We even cover topics like how to use assistive tools in testing, so your QA teams can catch issues early. The idea is to upskill your workforce so that accessibility knowledge isn’t siloed, it becomes part of everyone’s job. When your designers and developers understand why a certain accessibility rule exists, they are far more likely to implement it proactively.
Ongoing Support and Monitoring
Compliance isn’t a one-time project, especially with the June 2025 deadline approaching and likely future updates to standards. We provide ongoing support packages where we periodically review your digital platforms, run regression tests after updates, and keep you informed of any changes in regulations or best practices. If the law or standards evolve (when WCAG 3.0 comes out, or a new national requirement in one of your markets), we’ll help you adapt. We will be your long-term “accessibility partner,” ensuring you not only meet the EAA now but continue to meet it and stay ahead of the curve.
In all these services, our approach is collaborative and tailored. We know that every business is at a different stage in their accessibility journey. Some may need a quick compliance audit to identify gaps; others may need a full strategy overhaul. Some have internal teams ready to fix issues, while others need more hands-on help implementing changes. Wherever you stand, we’re ready to meet you there and assist. We want to help you identify accessibility issues and put them right, and to build internal capacity so you can maintain accessibility as part of business-as-usual.
Importantly, making these changes is not just about avoiding fines or meeting a legal requirement. It’s about unlocking the benefits of inclusion: reaching more customers, improving user satisfaction, and strengthening your brand’s reputation as a forward-thinking, socially responsible organisation. Many of our clients find that accessibility improvements go hand-in-hand with overall better design and SEO benefits (since search engines like accessible sites too). So, think of compliance as both a duty and an opportunity.
If you’re concerned about the EAA or want to ensure you’re on the right track, we invite you to get in touch with CIVIC. We’re passionate about accessibility and have a track record of helping organisations of all sizes become more inclusive. Whether you need a quick consultation or a full project engagement, we’d love to chat about how we can support your specific needs.
“It’s the end of the world as we know it, and I feel fine”...do you?
The European Accessibility Act might indeed seem like "the end of the world as we know it." It’s a huge change that compels a new way of thinking about products and services. But we believe that with the right preparation, you should feel fine, even optimistic, about this new world of accessibility. The EAA is not about burdening businesses; it’s about levelling the playing field and unlocking markets that have long been underserved. It’s the dawn of a more inclusive economy, and that’s something we can all embrace.
Don’t wait until it’s too late. Ensure your business is ready for the European Accessibility Act today. Review the key areas we’ve outlined, start plugging any gaps, and consider enlisting expert help if needed. CIVIC is here to be that helping hand, whether it’s providing an evaluation, guiding your strategy, or just offering advice on next steps. Reach out to us for a consultation or check out our Accessibility Evaluations and Testing services to see how we can assist.
Get in touch with CIVIC and we’ll help you apprach the EAA with confidence. The clock is ticking, it might be the end of the world as we know it for inaccessible design… and that can only be a good thing.