Accessibility checklist: is your website ready for the European Accessibility Act?

Accessibility of digital and physical services has been a topic of growing importance for years – but now, the European Union is placing legal weight behind it. On June 28, 2025, the European Accessibility Act (EAA) will come into full effect across the EU, establishing binding requirements for accessibility. Which organizations must comply with the directive? What are the risks of non-compliance? And, most importantly, how can you ensure your digital service meets EAA standards? Read on to find out.

When does the European Accessibility Act (EAA) come into effect?

That’s a more complex question than it may seem. The EAA, as an EU directive, officially entered into force in April 2019. Member states were then given three years to transpose the directive into national law. Following that, organizations were granted an additional three years – until June 28, 2025 – to ensure their products and services comply with the new accessibility requirements.

The EAA implementation dates:

• April 2019 – the EAA came into force as an EU directive. This meant that member states were given time to adopt the necessary national legislation (known as transposing the directive into national law).
  
• June 28, 2022 – this was the deadline by which member states had to enact and publish national laws in line with the EAA.
  
• June 28, 2025 – this is the final deadline by which businesses and organizations must ensure their products and services comply with the accessibility requirements set out in the EAA.

That means, if your service is not properly adjusted to the accessibility requirements of the act, your business may face legal consequences and penalties – especially if a complaint is filed or your organization is audited.

What if your company doesn’t comply with the EAA?

The enforcement mechanisms and penalties for non-compliance are determined individually by the EU member states. They may include fines or restrictions on product and service distribution.

More details can be found in our previous article on EAA >>

Who is required to comply with the accessibility requirements described in the EAA?

As an EU directive, the act mainly affects companies and organizations offering specific products and services in the EU. Its goal is to guarantee that people with disabilities can access important digital and physical services without obstacles.

Entrepreneurs (manufacturers, importers, distributors, service providers) offering products and services covered by the EAA

You are obliged to meet the requirements of the EAA if your company:

• operates in the EU market (even if it’s not located in the EU),
• employs 10 or more people or has an annual turnover or balance sheet total exceeding €2 million,
• and offers services or products at the EU market, including:

Products:

• Computers and operating systems
  
• Smartphones and payment terminals
  
• Televisions with interactive functions (e.g., set-top boxes, smart TVs)
  
• ATMs, ticket machines, check-in kiosks
  
• E-readers (electronic book readers)
  

Services:

• Retail banking services
  
• E-commerce (online stores)
  
• Passenger transport (websites and booking apps)
  
• Phone and digital communication services
  
• Audiovisual media services (e.g., streaming platforms)
  
• E-book services (selling and reading online)
  

Companies from outside EU

The EAA aims to ensure equal access to products and services for EU citizens. This means that even if your company is located outside the EU, you are still obliged to comply with the EAA if you offer aforementioned products or services to EU citizens.

Public institutions

Although the EAA primarily targets the private sector, its requirements complement pre-existing regulations for public institutions (e.g., the Web Accessibility Directive for public sector websites and mobile applications, Directive 2016/2102).

What about micro-enterprises?

Micro-enterprises (i.e., companies with fewer than 10 employees or an annual turnover and balance sheet total not exceeding €2 million) are exempt from the EAA requirements for service provision, but not necessarily from product-related requirements – depending on their role in the supply chain (e.g., as an importer). 

Although micro-enterprises are not legally required to comply with the EAA, this should not discourage them from adapting their services to meet the needs of people with disabilities and older adults.

According to Eurostat, there are approximately 101 million adults with disabilities in the European Union alone – representing around 27% of the population aged 16 and over.

By ensuring your services are accessible to all users, you gain a competitive advantage over businesses that fail to prioritize inclusivity.

How can I check if my web service meets the accessibility requirements of the EAA?

Step #1 Understand the applicable standards

The EAA builds on EN 301 549, which aligns closely with the Web Content Accessibility Guidelines (WCAG) 2.1, level AA. Your website should meet at least WCAG 2.1 AA compliance.

For more details on WCAG, check another article on our blog:

Why does web accessibility matter? >>

Step #2 Perform an accessibility audit

Use automated tools – for an initial check

If you decide to run the audit on your own, you can start with scanning your website for common accessibility issues with online tools. Such tools include, for instance, Google Lighthouse (in Chrome DevTools > “Lighthouse” tab), Siteimprove or Accessibility Insights.

The tools check for:

• Color contrast
  
• Missing alt text
  
• Keyboard navigation
  
• ARIA roles (attributes used in HTML to improve accessibility)
  
• HTML structure issues

Perform manual testing – important for full check

It’s crucial to realize that automated tools catch only ~30% of accessibility issues. Obligatory manual checks that should be performed include:

• Navigating your website only with a keyboard (no mouse)
  
• Using a screen reader (e.g., NVDA, VoiceOver)
  
• Checking form labels, focus states, and error messages
  

Step #3 Conduct a full WCAG 2.1 AA evaluation

Use the WCAG 2.1 AA checklist to assess compliance across:

• Perceivability: Text alternatives, captions, adaptable content
  
• Operability: Keyboard access, enough time, no seizures, navigation
  
• Understandability: Readable content, input assistance
  
• Robustness: Compatible with assistive tech
  

Checklists that may be helpful here:

• W3C WCAG Checklist
  
• WebAIM WCAG 2.1 Checklist
  
  

Step #4 Consider a professional audit

This step may be your #1 on the checklist, especially if your website is quite extensive and receives high-traffic. 

You can hire an experienced web accessibility specialist to perform the audit. This approach gives you more confidence and the feeling that every part of the website has been properly tested. What’s more, at the end of such a professional audit, you will receive a detailed report on the findings and a list of recommended improvements.

Make sure your website meets EAA requirements. Request accessibility audit >>

Step #5 Document your findings and remediation plan

EAA compliance is not just about testing. It also requires businesses to prepare:

• A statement of accessibility – that should be published on your website
  
• A plan for fixing issues – with timelines
  
• A way for users to easily report accessibility problems

Still not sure if your web service meets the EAA requirements?

While the EAA itself only outlines what products and services must be accessible and which functional requirements they must meet – such as perceivability, operability, understandability, and robustness – it doesn’t specify exact technical criteria like WCAG or code-level rules.

To define how to meet those requirements, the EAA relies on external, more detailed standards – primarily EN 301 549, which is based heavily on WCAG 2.1 AA for digital content. 

Making sure a website or an app meets all the requirements requires a mix of legal and technical knowledge, which is unique for digital service companies and advisors. 

Web accessibility has been one of ambiscale’s core services for years. It’s a significant part of our offer since 2019. Our certified specialists will verify if your web service or digital product meets the requirements of AEE. From professional audit to implementation of the accessibility improvements, we can get your business equally accessible to all your clients and 100% compliant with EAA.

Let’s talk.