EAA 2025: Top Questions Answered Ahead of the Deadline

The European Accessibility Act (EAA) is now in effect. As of June 28, 2025, businesses that operate in—or offer digital services to—the EU must meet accessibility requirements for websites, mobile apps, and digital products.

Over the past few months, UsableNet has hosted three webinars, each tailored to key areas of EAA compliance—from legal obligations and testing to implementation strategy. Across all sessions, the same questions came up. In this blog, we answer the most common ones—so your team can move forward with clarity and confidence.

Why was the European Accessibility Act created?

The EAA harmonizes accessibility standards across all EU member states. It aims to reduce fragmentation in national accessibility laws and improve access to digital products and services for the more than 87 million people in the EU living with disabilities.

The EAA references EN 301 549, which requires WCAG 2.1 Level AA conformance for websites, apps, and other digital interfaces.

Related: Understanding EN 301 549 for EAA Compliance

Who benefits from the Act?

While the EAA directly benefits individuals with disabilities, it also improves usability for:

• Older adults and people with temporary impairments

• Public institutions evaluating vendors

• Businesses seeking simpler cross-border digital compliance

How do businesses benefit from compliance?

• One set of requirements for all EU countries

• Improved usability and conversions across audiences

• Stronger brand reputation through inclusion

• Reduced legal and financial risk

Watch: Understanding EAA Compliance: What Businesses Need to Know

Does the EAA apply to websites accessible from the EU?

Yes. If your website or app is available to EU consumers—and those users can interact, purchase, or register—you may be required to comply, even if you don’t have a physical presence or local domain in the EU.

Watch: “EAA Compliance Blueprint: Building an Accessibility Testing Program”

How does the EAA apply to country-specific domains Vs. a .com site serving the EU?

• Those sites must comply individually if you operate country-specific domains like .fr or .it.

• If EU consumers access your services through a .com, that site must comply with the EAA.

In both cases, compliance includes meeting WCAG 2.1 AA and demonstrating ongoing accessibility maintenance and monitoring.

WCAG 2.1 is the legal requirement—should I aim for 2.2?

Yes. While WCAG 2.1 AA is the current legal requirement under EN 301 549, WCAG 2.2 has already been published and is expected to be the next version incorporated into EN 301 549, as discussed in our most recent webinar sessions.

WCAG 2.2 adds success criteria that improve accessibility for users with cognitive and motor disabilities. Adopting WCAG 2.2 now not only future-proofs your efforts but also strengthens usability for a broader audience.

Read more about moving from WCAG 2.1 to WCAG 2.2

What are the penalties and risks of failing to comply with the EAA?

Each EU country enforces the EAA individually, but potential consequences include:

• Fines or penalties

• Criminal enforcement in some jurisdictions

• Removal from the market for repeated violations

• Exclusion from public procurement

• Reputation damage from inaccessibility

In addition to all 27 EU Member States, countries participating in the EU single market through membership in the European Economic Area (EEA) are also subject to the EAA. This includes Iceland, Liechtenstein, and Norway, even though they are not in the EU.

Read more: The European Accessibility (EAA): Your Comprehensive Guide

What accessibility statements or reporting are required?

The EAA requires that each website and mobile app falling under its scope include an accessibility statement. This statement must:

• Declare the level of WCAG conformance.

• Acknowledge any known issues or exceptions

• Include a contact mechanism for feedback and requests

While the EAA doesn’t define a single reporting format, Member States may also expect proof of ongoing monitoring or user testing documentation.

Need help? Watch our webinar on accessibility policies and statements

Is training required?

The EAA does not explicitly require training, but accessibility training is strongly encouraged. Countries like France and Germany have indicated that demonstrating team awareness, especially among developers, QA, and content teams, may be part of enforcement expectations.

Training internal teams helps reduce risk and supports ongoing accessibility compliance.

Does The EAA cover Career Sites And Post-Login Pages?

Yes. If EU users interact with any part of your digital experience—including job applications, dashboards, or checkout flows—those areas must also meet accessibility requirements.

This includes pages and tools that require login or registration, not just your public-facing homepage.

Want hands-on support? Join UsableNet at Accessibility Days in Italy

If you're based in Europe, join us at Accessibility Days in Milan, Italy’s largest digital accessibility event. UsableNet will host a workshop on implementing EAA compliance—ideal for teams looking to strengthen their digital accessibility programs and maintain ongoing compliance.

What Your Team Can Do Next

Explore Our Webinars Related to EAA Compliance Topics

• Understanding EAA Compliance: What Businesses Need to Know

• EAA Compliance Blueprint: Building an Accessibility Testing Program

• How Accessibility Policies and Statements Support Compliance