The European Accessibility Act — formally Directive (EU) 2019/882 — entered into force on June 28, 2025. For the first time in European history, private sector businesses are subject to legally binding accessibility requirements for their digital products and services. This is not a recommendation, a best practice or a voluntary standard. It is law, and enforcement has already begun.
What the EAA Requires
For websites and digital services, the EAA requires compliance with WCAG 2.1 Level AA — the internationally recognised Web Content Accessibility Guidelines developed by the World Wide Web Consortium (W3C). These guidelines are organised around four principles: Perceivable, Operable, Understandable and Robust.
In practical terms, this means websites must:
- Provide text alternatives for all non-text content (images, icons, graphs)
- Ensure all functionality is available by keyboard, not just mouse
- Declare the page language so screen readers can apply correct pronunciation
- Ensure sufficient colour contrast between text and background
- Provide captions for video content
- Ensure forms have properly labelled input fields
- Allow users to navigate content using headings and landmarks
Beyond technical compliance, businesses must also publish an accessibility statement explaining their current compliance status, provide a feedback mechanism for users to report barriers, and cooperate with regulatory requests for accessibility information.
Who Does the EAA Cover?
The EAA covers businesses providing consumer-facing digital services including e-commerce, banking, transport booking, telecommunications and professional services. If your website sells products or services to consumers in EU or EEA countries, you are likely in scope.
The regulation applies based on where your customers are located, not where your business is registered. A US business selling to European customers is subject to the EAA. An Icelandic business with European customers is subject to the EAA.
The Microenterprise Exemption — What It Actually Means
The EAA includes an exemption for microenterprises — businesses with fewer than 10 employees and annual turnover below €2 million. This exemption is narrower than most business owners assume.
First, both thresholds must be met simultaneously. A business with 8 employees but €3 million in turnover does not qualify. A business with €1.5 million turnover but 12 employees does not qualify.
Second, the exemption only applies to EAA obligations. GDPR applies to every business regardless of size. A microenterprise with a website that collects personal data still has full GDPR obligations.
Third, the exemption does not protect against ADA lawsuits in the United States, which have no size threshold and which have been filed against businesses with as few as one employee.
Enforcement Is Already Underway
Within weeks of the June 2025 deadline, French disability advocacy organisations filed formal legal notices against major retailers for EAA non-compliance. Sweden began market surveillance in October 2025. Denmark started actively contacting businesses about compliance status in October 2025. The Norwegian HelsaMi health portal received daily fines of €4,500 for persistent keyboard accessibility failures, accumulating to over €300,000.
The enforcement pattern following GDPR — initial focus on larger businesses expanding to smaller ones over time — is already repeating with the EAA. The businesses that act now are positioning themselves ahead of the enforcement curve. Those that wait are building a liability that grows with every passing month.
The Business Case Beyond Compliance
An accessible website is not only a legal requirement — it is a better website. According to Eurostat, 101 million people in the EU — one in four adults — have some form of disability that affects how they use digital services. Accessibility improvements that help screen reader users also help older users with declining vision. Captions that help deaf users also help users watching video in a noisy environment. Keyboard navigation that helps users with motor impairments also helps power users who prefer not to reach for the mouse.
The businesses that invest in accessibility now will have a more inclusive, higher-performing website and legal compliance. The businesses that wait will eventually be required to make the same investment — under regulatory supervision and possibly while managing a fine.