The European Accessibility Act

What the EAA is

The European Accessibility Act is Directive (EU) 2019/882. A directive is not law by itself: each EU member state writes its own statute to implement it. That is why the obligation is broadly the same everywhere in the EU while the enforcement body, the procedure and the size of the fine are different in every country.

The date that matters is 28 June 2025. Since then, the national laws implementing the EAA apply to the products and services it covers. There is no grace period for services that were already being sold.

What the directive requires, in one sentence: the covered products and services have to be usable by people with disabilities, and the provider has to be able to say how.

Who is in scope

The EAA covers services sold to consumers in the EU. The categories that matter most for a web agency are:

• E-commerce — anything a consumer can buy online. This is the category most agency clients fall into.
• Consumer banking services.
• E-books.
• Electronic communications services.
• Passenger transport services.
• Access to audiovisual media services.

Two things surprise people. First, the act binds any business selling to EU consumers, wherever the business itself is established — a shop in London, Zurich or São Paulo that ships to Germany is not outside it. Second, it is about who you sell to, not about how big your website is: a small shop with twelve product pages is in scope on the same terms as a marketplace.

What “accessible” means in practice

The directive itself describes outcomes, not HTML. The technical yardstick is the harmonised European standard EN 301 549, and for web content EN 301 549 points at the Web Content Accessibility Guidelines (WCAG) at level AA. The version it currently references is WCAG 2.1 AA.

So the practical target for a website is: pass the WCAG level A and level AA success criteria. That is a concrete, testable list — contrast ratios, keyboard operation, form labels, names for controls, page structure, a declared language, and so on.

Rampsight tests against WCAG 2.2 at levels A and AA. WCAG 2.2 does not change the criteria that came before it: the W3C states that content conforming to WCAG 2.2 also conforms to WCAG 2.1 and WCAG 2.0. Testing the newer version therefore covers the baseline EN 301 549 references and adds the criteria that were introduced since. How the WCAG levels and versions fit together.

The microenterprise exemption

Microenterprises that provide services are exempt. A microenterprise is a business with:

• fewer than 10 people, and
• an annual turnover or balance sheet total of €2 million or less.

Both conditions have to hold. And the exemption covers services only — it does not exempt products. A very small company that sells a physical product covered by the act is not carried out of scope by its headcount.

For an agency this exemption is worth checking early, because it decides whether a client has a legal deadline or a commercial argument. It is not, however, a reason to leave a site inaccessible: an exempt shop still loses the customers who cannot complete the checkout.

Products already on the market: the 2030 transition

Products that were already placed on the market before 28 June 2025 have a transition period. They may continue to be used until 28 June 2030, or until their next major update, whichever comes first.

The clause that catches people out is the second half. A major update ends the transition early. Teams sometimes read “2030” as five spare years and then ship a redesign in the meantime, which brings the deadline forward to the day of that release.

Penalties differ by country

The directive does not set penalties. Each member state does, in its own implementing law, and the range is wide:

• Germany — fines of up to €100,000 under the BFSG, with the amount depending on severity, intent or negligence, and the size of the company. Germany also allows competitors and qualified trade associations to send a cease-and-desist notice. The German rules in detail.
• Ireland — fines of up to €60,000.

Those two numbers are examples of the spread, not a table of Europe. If your client sells across several countries, the exposure is the strictest regime among them, and the answer to “how much could this cost us” belongs to a lawyer in that country rather than to us.

It is also worth saying plainly that fines are rarely the first thing that happens. A complaint, an enforcement authority asking questions, or a large customer requiring accessibility in a tender usually arrives long before a penalty does.

What an agency should do for its clients

1. Sort the portfolio by scope. Which clients sell to consumers in the EU? Which of those are microenterprises providing services? That single pass turns a vague worry into a short list.
2. Get a baseline. Scan each site in scope and record where it stands today. A number and a list of located failures is something a client can act on; “your site may not be compliant” is not.
3. Fix in order of severity and reach. A contrast failure in a template that appears on every page is worth more than a rare edge case. Fix the code — templates, components, the design system — not the symptom on one page.
4. Add the human pass. Keyboard operation, screen reader behaviour, whether alternative text is actually meaningful, whether error messages help. Automated tools do not cover this, and it is where the real barriers usually are.
5. Publish an accessibility statement. It says where the site stands, what is not fixed yet, and how a user can report a problem. What a statement has to contain.
6. Keep monitoring. Accessibility is not a state a site reaches; it is a property that a release can break. Scheduled scans are how you find out in the same week rather than at the next audit.

For an agency this is a retainer, not a project. A scan of 100 to 1000 pages per site, run on a schedule and reported under your own brand, is a service you can price and renew. How agencies package this.

What a scan can and cannot prove

Be careful with the word “compliant” in front of a client. Nobody can hand them a certificate of conformance based on automated testing, and any vendor who offers one is selling something we would not.