EAA FAQ: Scope, Penalties, and Ongoing Compliance Requirements

The EAA has been enforceable since June 28, 2025. This FAQ explains how the European Accessibility Act affects businesses, detailing its scope, penalties, and practical compliance steps.

If your company operates in more than one EU country, now is the time to review how accessibility is monitored, documented, and maintained. Book a meeting with UsableNet to assess your current approach and identify any gaps.

The European Accessibility Act (EAA), formally known as Directive (EU) 2019/882, establishes accessibility requirements for digital products and services sold in the EU. With enforcement active, compliance is no longer a one-time milestone; it is an ongoing responsibility.

To help navigate compliance, we’ve compiled clear answers to the most common legal and practical questions we've received in the last couple of weeks surrounding the EAA and its implementation in each EU member state.

What is the EAA, and how does it relate to WCAG?

The European Accessibility Act is a pan-EU law that requires certain digital goods and services to be accessible to persons with disabilities. While the EAA doesn’t mandate WCAG by name, most EU member states are aligning their national laws with WCAG 2.1 AA or the broader EN 301 549 standard, which references WCAG.

Does the EAA apply to my company?

The EAA applies if you:

• Sell digital products (e.g., ATMs, smartphones, e-readers)
• Provide digital services (e.g., ecommerce platforms, banking, ticketing, transport apps)
• Operate within the EU or provide services to EU consumers
  
  

Microenterprises (fewer than 10 employees and under €2 million turnover) are exempt. All others must comply. Learn more about which businesses are in scope.

What happens if we are not compliant?

Non-compliance risks include:

• Investigations by your country’s enforcement authority
• Fines, which vary by member state      
• Public exposure on non-conformance registers
• Loss of contracts, especially in public procurement
  
  Each member state defines its penalties, but enforcement is mandatory across the EU.

Amounts shown are statutory maxima for first‑tier infractions. Recurring or severe breaches may result in higher sanctions.

How will EAA enforcement work?

Enforcement is handled at the national level. Each EU country designates one or more National Enforcement Authorities (NEAs). They are actively responsible for:

• Receiving and investigating complaints
• Conducting audits
• Ordering remediation
• Imposing sanctions or referring to a court
  
  

How long do we have to fix an accessibility issue after a complaint?

It depends on the country, but most allow:

• 30–90 days to respond to an initial inquiry
• 3–6 months to complete remediation

Can we be fined in multiple countries for the same issue?

Yes. If you provide services or sell products in multiple EU countries, you may face parallel investigations and fines in each jurisdiction. Coordination is encouraged—but not guaranteed.

Example: A cloud platform with users in Germany and France could be investigated separately by each country’s NEA.

How do we Demonstrate Ongoing Compliance?

Provide the NEA with:

• An accessibility audit report
• A remediation plan with clear timelines
• Logs or screenshots of progress
• Staff training records and budgets
• An updated accessibility statement

This documentation can help delay or avoid enforcement actions.

What is a "declaration of conformity" under the EAA?

For digital products, a declaration of conformity is a signed legal statement that the product meets EAA requirements. See the official EU template here: EUR-Lex Annex III

What are the best steps to Maintain Compliance?

1. Audit your sites, apps, and documents for WCAG 2.1 AA conformance.
2. Publish an accessibility statement on every applicable interface (here’s why that’s essential)
3. Train your staff on accessibility and EU-specific legal obligations
4. Build a remediation roadmap with budget and timelines
5. Document everything—you need to show your progress

Need More Help?

With enforcement underway, these resources can support your ongoing compliance efforts:

🎥 Watch the EAA webinar series led by UsableNet accessibility experts—with legal insights from Reed Smith LLP in the first session—this series breaks down who’s in scope, what EN 301 549 requires, and how to build a lasting accessibility strategy.

🧩 EN 301 549 vs. WCAG: What’s the Difference?

 This brief blog explains how the EAA standard builds upon WCAG and what that means for your website, apps, and documents.

✅ Visit the EAA Resource Hub Checklists, tools, and blog posts—organized in one place to make your compliance journey easier.

How UsableNet Can Support EAA Compliance

At UsableNet, we provide solutions to help businesses comply with EAA and EN 301 549 standards—whether you're just getting started or need full-service support.

UsableNet Assistive is a fully managed service designed to ensure EAA compliance with minimal effort from your internal team. Our accessibility experts handle remediation and ongoing monitoring, aligning your websites and apps with WCAG and EN 301 549 standards. By proactively maintaining accessibility, we help you reduce compliance risk while delivering a seamless experience for EU customers.

Accessibility as a Service (AaaS) - Our AaaS program provides the guidance, training, and tools your team needs to build accessibility into day-to-day workflows. This approach supports long-term EAA compliance through usability testing by people with disabilities, expert support, and continuous adaptation as EU regulations evolve.

AQA Accessibility Testing Platform helps your team identify, track, and resolve accessibility issues with real-time insights. Our automated testing platform seamlessly integrates into existing workflows to assess conformance with EN 301 549, streamlining compliance and enhancing usability for all customers who require assistance under active EAA enforcement.