The European Accessibility Act (EAA) is a landmark EU directive aimed at making products and services – including websites and apps – accessible to people with disabilities across all member states. It was passed in 2019 and took full effect on 28 June 2025, establishing a common set of rules so businesses and consumers no longer face a patchwork of different national standards. In practical terms, if your business operates in the EU or serves customers in the EU, you are now required to meet specific accessibility requirements on your digital platforms. This isn’t just a bureaucratic box to tick – it’s about opening your doors to more customers and ensuring everyone can use your website. Let’s break down what the EAA means for you as a small business owner and how you can get your website compliant.
What Is the European Accessibility Act (EAA)?
The EAA is an EU-wide law that mandates accessibility for a range of everyday products and services – from ATMs and smartphones to e-books and e-commerce websites. Its core purpose is to remove barriers for people with disabilities by harmonizing accessibility requirements across Europe. Prior to the EAA, each country had its own rules, which was confusing and costly. Now, with one common standard, everyone is on the same page. This harmonization benefits businesses by reducing compliance costs and opening up cross-border trade opportunities. It also benefits the public by encouraging more accessible products at competitive prices and stimulating innovation in assistive technologies. In short, the EAA aims to make sure no one gets left behind – whether it’s a senior citizen struggling to use an app or a traveler with a visual impairment trying to book a train ticket.
When did it take effect?
The EAA officially came into force on 28 June 2025. From that date onward, any new product or service in scope must be accessible. (Existing offerings have a grace period – more on that later.) This means the law is not some far-off thing on the horizon; it’s already active right now. If you haven’t considered accessibility for your business website yet, now is the time. Compliance is no longer optional or “nice-to-have” – it’s the law.
Who Does the EAA Apply To?
One common misconception is that accessibility laws only affect big companies or public institutions. In reality, the EAA’s reach is very broad. It applies to any business (aside from some micro-business exemptions) that offers relevant products or services to consumers within the EU, regardless of where the business is located. In other words, even if your company is based outside Europe – say in the US or UK – if you sell or provide services to customers in the EU, you must comply. The EAA effectively makes accessibility a global consideration, much like how GDPR made the world pay attention to EU privacy rules.
Here’s who is covered by the EAA in a nutshell:
EU Businesses of All Sizes – Whether you’re a local shop with an online store or a growing startup, if you serve EU customers, the law covers you. Small and medium-sized businesses are definitely included. The only partial exception is for micro-enterprises (fewer than 10 employees and ≤ €2 million turnover), which the EAA exempts from certain service-related requirements to avoid undue burden. However, even micro businesses still need to meet accessibility rules for any physical products they sell, and they’re encouraged to follow the best practices for services too. After all, making your website accessible can help a tiny company punch above its weight in reaching customers. (Fun fact: There are over 100 million people with disabilities in the EU – a huge potential customer base you don’t want to exclude.)
Non-EU Companies with EU Customers – If you’re outside the EU but offer services or ship products to EU markets, the EAA requirements still apply to you. For example, a US-based e-commerce site or mobile app with European users is expected to comply just as an EU-based business would. The EAA’s intent is to create a level playing field and ensure EU consumers get accessible options, no matter where the provider is headquartered.
Range of Products/Services
The law isn’t limited to websites. It covers a list of products and services crucial to participation in modern life. This includes e-commerce websites and apps, online banking services, e-book readers, payment terminals, ticket vending machines, transport booking sites, and more. For most small businesses, the relevant point is: if you have a website, online store, or mobile app that consumers use, you should assume the EAA applies. Notably, public sector websites were already required to be accessible under a separate EU directive; the EAA now extends similar expectations to the private sector, including small businesses and retailers.
Are any small businesses exempt?
The EAA tried to be mindful of not overburdening the very smallest companies. If you’re a micro-enterprise (under 10 staff), and you provide services (like a small travel booking site, for instance), you officially fall outside the EAA’s service requirements. However, this exemption is limited. First, if you manufacture or sell physical products listed in the Act (say you create a gadget that falls under EAA scope), you still must meet the product accessibility specs. Second, even when legally exempt, it’s good business sense for micro and small firms to prioritize accessibility. As the European Commission notes, many accessibility features are encouraged for all, and smaller suppliers may need to comply indirectly to partner with larger companies or win certain contracts. Bottom line: unless you truly have zero customers with disabilities and no ambition to grow (an unlikely scenario!), it pays to make your website as accessible as possible, EAA mandate or not.
Key Accessibility Requirements (EN 301 549 & WCAG 2.1 AA)
So, what does “being accessible” actually mean for your website or app? The EAA itself is a law, not a technical manual, so it doesn’t spell out every design detail. Instead, it points to standards. The primary standard for digital accessibility under the EAA is EN 301 549, a European norm that contains specific accessibility requirements for ICT (Information and Communication Technology) products and services. If that sounds abstract, here’s the translation: EN 301 549 basically incorporates the Web Content Accessibility Guidelines (WCAG) – specifically WCAG 2.1 at the AA level – as the baseline for web and mobile accessibility. In other words, if your website conforms to WCAG 2.1 AA, you’re covering the bulk of EAA requirements for digital content. WCAG is an internationally recognized set of guidelines developed by the W3C, built on four core principles that your content must be Perceivable, Operable, Understandable, and Robust (POUR). Level AA (pronounced “double-A”) is the mandatory conformance level under the EAA, which means you need to meet all Level A and AA success criteria in WCAG 2.1 for your site. (There is a higher AAA level in WCAG for extra credit, but that’s not required by law and often not practical to achieve across an entire site.)
What are some of the key WCAG 2.1 AA requirements? In plain language, here are some of the most important things you need to do to have an accessible website:
Provide text alternatives for non-text content. Images should have alt text that describes them for someone using a screen reader. If you post videos or audio, include captions or transcripts so users who can’t hear can still get the information. Essentially, nobody should miss out on content because it’s locked in a format they can’t access.
Make your site usable with just a keyboard (no mouse required). Many people can’t use a mouse due to mobility or vision issues, so all functionality must work via keyboard alone (e.g. using the Tab key to navigate and Enter/Space to activate links and buttons). This means ensuring there are no “keyboard traps” (elements that a keyboard user can’t move away from) and that the keyboard focus indicator (the outline that shows what link or button is currently selected) is visible.
Ensure your content is perceivable and easy to see/hear. This includes having sufficient color contrast between text and background so that people with low vision or color-blindness can read it. Don’t use color alone to convey important information. Use clear fonts and allow text to be resized. For audio or video content, aside from captions, consider audio descriptions for important visual details in videos. And avoid any content that flashes rapidly, as it could trigger seizures.
Provide clear navigation and orientation. Users should be able to easily navigate and understand where they are on your site. This means using proper headings and page titles, logical layouts, and features like “skip to main content” links for screen reader and keyboard users. Every link should make sense from its text alone. If your site has forms, each form field needs a label or instructions that screen readers can associate with the input.
Make sure assistive technologies can interact with your site. In practice, this means writing clean HTML code and using standard web components so that screen readers, screen magnifiers, voice control software, etc., can all parse and operate your site. Buttons should be actual <button> elements or have appropriate ARIA roles, images should use <img alt="...">, and so on. If you have dynamic content (like pop-ups or custom widgets), ensure that updates are announced to assistive tech. Essentially, adhere to best practices of semantic, well-structured HTML and ARIA roles when needed, so your site is robust across different devices and assistive tools.
These requirements are encapsulated in the technical standards (WCAG/EN 301 549), but you don’t need to read the entire spec to grasp the core idea: your website should be usable and understandable for people with a wide range of disabilities. That includes users who are blind or visually impaired, deaf or hard of hearing, motor impaired, cognitively impaired, or even just aging with reduced eyesight or dexterity. The EAA essentially demands that you follow inclusive design practices. For example, compatibility with screen readers and keyboard navigation is a must, as is using clear layouts and offering alternatives for media. It’s wise to familiarize yourself (and your web developer) with the WCAG 2.1 AA checklist – it’s the blueprint for what to implement. Key areas to double-check include text alternatives, color contrast, headings structure, form labels/error messages, keyboard access, time-out flexibility, and providing an accessibility statement on your site declaring your conformance (the EAA in fact requires an accessibility statement for many services).
Tip: Don’t be intimidated by the alphabet soup of acronyms. At the end of the day, complying with EAA/WCAG is about following sensible design rules. If you’re new to accessibility, start with the basics: add alt text to images, fix any low-contrast text, test if you can navigate without a mouse, and add captions to videos. Those steps alone address many common barriers. We’ll provide more guidance on how to audit and improve your site in the next section.
Risks and Penalties for Non-Compliance
The EAA isn’t just a friendly recommendation – it has real teeth. EU member states are empowered to enforce the rules, and businesses that ignore the accessibility requirements risk significant penalties. Broadly speaking, enforcement is handled by national authorities (for example, an equality commission or consumer protection agency in each country), and those regulators can investigate complaints or audit companies for EAA compliance. If your website or product is found non-compliant, you could face fines, sanctions, or even restrictions on selling your services in the EU.
What kind of penalties are we talking about? The exact fines and punishments can vary by country, since each EU nation sets its own penalty structure under the directive’s framework. However, the penalties are designed to be effective, proportionate, and dissuasive. Here are some general scenarios:
One-time fines per violation: Many countries plan to impose administrative fines that might range from a few thousand euros to tens of thousands of euros per accessibility violation. For instance, an audit might find that your e-commerce site lacks alt text on product images – that could incur a fine (one guide estimates something like an €5,000–€20,000 fine for a missing key feature, scaled by severity). More critical failures (say, an online banking portal that is unusable for keyboard-only users) would incur higher fines than minor slips.
Daily or ongoing fines: To encourage prompt fixes, regulators can also levy daily penalties for each day an issue remains unresolved. These might be on the order of up to ~€1,000 per day for serious issues, adding up quickly if a business refuses to make changes. The intent is clear – it’s cheaper to fix your site than to pay the fines.
High maximum fines and legal actions: Some countries have set pretty eye-watering maximum fines for EAA non-compliance, especially for repeated or willful violations. For example, France can impose fines up to €250,000 for failing to make a public-facing service accessible, and Spain can go even higher (up to €600,000 in the most serious cases). Germany has mentioned penalties up to €100,000, and Ireland even includes the possibility of criminal charges (e.g. imprisonment up to 18 months) for extreme cases of non-compliance. While small businesses might not immediately face the maximum fine, these figures show how serious the issue is taken. Consistently ignoring accessibility could literally put your business in legal jeopardy.
Market restrictions and orders: In addition to fines, authorities can potentially issue orders to stop the sale of non-compliant products or services. Under the EAA, if a product (which could include a software product or an e-commerce platform) doesn’t meet the requirements, regulators can force its withdrawal from the market until it’s fixed. This is akin to a recall in the product safety world. For a website or app, this might translate to being compelled to shut down access in that country until you address the accessibility gaps. Losing an entire market is a massive business risk.
Reputational damage: Even if you somehow avoid a big fine, being publicly called out for failing to accommodate users with disabilities can seriously damage your brand’s reputation. In today’s social media age, news travels fast. No modern business wants to be seen as excluding customers or ignoring inclusivity. Aside from official penalties, you also risk complaints on social platforms, bad reviews, or even lawsuits from advocacy groups or individuals if your site is not accessible. Many accessibility lawsuits have occurred in other jurisdictions (like the U.S. with the ADA); the EAA now provides a clear legal hook for similar actions in Europe.
It’s worth noting that regulators aren’t looking to punish everyone on day one – their goal is to achieve compliance. In many cases, if issues are found, you’ll be given a notice or opportunity to fix problems within a given timeframe before fines kick in. The EAA even has an “alternative dispute resolution” approach to encourage fixing issues outside of court. But this leniency applies only if you demonstrate a willingness to comply. A business that blatantly neglects the law or fails to make improvements after being warned will quickly find itself in hot water.
The takeaway: Non-compliance is risky and costly. You could face legal action, fines that impact your bottom line, and loss of access to the huge EU market. On the flip side, compliance not only avoids these negatives but actually can enhance your business – it shows social responsibility, improves your user experience for everyone, and broadens your reach. Why risk penalties and missed opportunities when investing in accessibility can drive growth? In the next section, we’ll focus on proactive steps to get your website in shape.
How to Audit and Improve Your Website’s Accessibility
By now you understand why accessibility compliance is important – now let’s talk about how to get it done. Making your website accessible might sound like a technical challenge, but it’s absolutely achievable, even for small teams. It’s often a series of incremental fixes and good practices that add up to a fully accessible site. Here’s a roadmap to get you started:
1. Perform an Accessibility Audit (Assess Your Starting Point). You can’t fix what you don’t know is broken, so the first step is to evaluate your website for accessibility issues. There are a few ways to do this:
Automated testing tools: Start with free online checkers or browser plugins that scan web pages for common problems. For example, tools like WAVE, AXE, or Lighthouse (built into Chrome) can quickly flag missing alt text, low contrast text, missing form labels, etc. Automated tools are a great first pass – they’ll catch many surface-level issues in minutes. (Note: automated checkers typically detect only 20–50% of possible issues, so don’t stop at this step.)
Manual testing: Plan to do some simple manual tests that no tool can fully replicate. Try navigating your site using only a keyboard – can you reach all
2. Prioritize Issues and Make a Plan. Once you have a list of problems (from your audit), organize and prioritize them. Not all issues are equal – some are critical barriers that might prevent a person with a disability from using your site at all, while others are minor annoyances. For example, a missing alt attribute on a decorative image is a smaller issue than missing alt text on a product image that conveys essential info. Similarly, an unlabeled form field in your checkout process is a high priority because it could stop sales. Focus on fixing high-impact, high-traffic parts of your site first. If you have a developer or tech team, discuss the findings with them and map out a timeline. It might help to break the work into phases (e.g., “easy fixes this week” and “larger template overhauls next month”). Ensure management/owners understand the importance so that proper time and budget can be allocated – treat it as a necessary upgrade to your website, not an optional tweak.
3. Fix the Issues (Implement Accessible Design and Code). Now roll up your sleeves and start making improvements:
Add missing text equivalents: Go through all images and media. Write clear alt text for images that are informative. (If an image is purely decorative, you can mark it as such with an empty alt attribute, so screen readers skip it.) Provide captions for videos and transcripts for audio content. If you have PDFs or downloadable documents, ensure they’re accessible or provide the content as HTML as well.
Improve site navigation and structure: Use proper HTML heading tags (<h1>, <h2>, <h3> etc.) to structure pages logically – this not only helps assistive tech users understand the page outline, but also improves SEO. Make sure every form field has a label (either explicitly linked to the input or via placeholder with aria-label if needed). Add a “Skip to Content” link at the top of your pages so keyboard users can bypass repetitive menus. Ensure your site search or sitemap is easily reachable as alternate ways to find info (WCAG actually recommends multiple ways to navigate).
Enhance keyboard accessibility: Fix any components that don’t work with keyboard alone. Common culprits are custom dropdown menus, modals, image galleries, or interactive widgets that were designed only for mouse use. You may need to add JavaScript handlers for keyboard events or restructure certain elements. Every interactive element (links, buttons, controls) should be reachable by pressing Tab, and activatable by Enter/Space. Also, implement visible focus styling (CSS outline or highlight) so it’s always clear which element is focused. If your website currently “hides” the focus outline, re-enable it or design a custom focus indicator that matches your branding but stands out clearly.
Check color and contrast: Use a color contrast checker to verify your text meets at least the WCAG AA contrast ratio (4.5:1 for normal text). Adjust colors or font sizes as needed. Ensure that information isn’t conveyed by color alone – if something is in red text to indicate an error, also include an icon or text label (“Error: …”) so color-blind users know. Allow users to zoom text easily; ideally nothing should break when zoomed up to 200% size (test this using your browser’s zoom function).
Make interactive elements self-explanatory: Links and buttons should have discernible text (no empty links or buttons with only icons unless the icon has an accessible name). For example, if you have a social media icon link, provide an aria-label="Follow us on Facebook" or similar. If you use icons for a phone number or email, ensure there’s text or alt text. Error messages on forms should be clearly associated with the form field (using aria-describedby or inline text) and in a simple language. Include helpful instructions for any complex form fields. Basically, communicate clearly through multiple senses.
Test as you go: After you fix a batch of issues, re-test those pages. Use the automated tools again to see if errors are resolved. Try the keyboard and screen reader tests again on key user flows (like a purchase or sign-up). This iterative approach helps ensure that the changes you made actually work as intended for users.
4. Integrate Accessibility into Ongoing Practice. Making your current website compliant isn’t a one-and-done task – you’ll want to keep it accessible going forward:
Train your team (even if that’s just you!). Make sure anyone who creates content or updates the website knows
Use accessible templates and tools. If your website runs on a CMS like WordPress or Shopify, choose themes and plugins that are labeled as accessible or have good reviews for accessibility. Many modern templates note if they follow WCAG guidelines. Still, always test them, but starting with a well-designed template saves a lot of retrofitting. Similarly, when adding third-party widgets (chat bots, video players, etc.), check if they are accessible or offer an accessible mode.
Maintain an Accessibility Statement. It’s a good practice (and for many, a requirement) to publish an Accessibility Statement on your site that outlines your commitment to accessibility, the standards you aim to meet (e.g. “WCAG 2.1 AA”), and contact information for users to report any issues. Not only is this transparent, it can also provide some legal protection by demonstrating your proactive stance. The EAA mandates accessibility statements for certain services, so it’s wise to have one ready. There are generators and templates available to help write this.
Monitor and update regularly. Set up a schedule (say, quarterly or biannually) to re-run automated scans on your site and review any new content for accessibility. Laws and standards can evolve – for example, WCAG 2.2 and 3.0 are on the horizon – so keep an ear out for updates. Also, pay attention to user feedback: if someone emails that they had trouble using your site with a screen reader, treat it as valuable data and fix the issue. This continuous improvement mindset will keep you in good shape. It’s much easier to maintain accessibility than to remediate a huge backlog of issues after years of neglect.
5. Consider Expert Support When Needed. If all of this feels overwhelming, remember that you don’t have to do it alone. There’s a growing industry of accessibility consultants and services that specialize in helping businesses comply with laws like the EAA. Whether it’s a one-time audit, implementing fixes, or providing an accessible website redesign, professional help is available (often scaled to the size of your business). Hint: one such service is LumenForges, which we’ll talk about in the FAQ. The key is to show that you’re making a sincere effort. The EAA even contains a “disproportionate burden” clause – if making something accessible truly bankrupts you or is technically impossible, you might get some leeway, but you must document your reasoning and still improve whatever you can. Simply ignoring accessibility won’t fly. Fortunately, many accessibility fixes are not outrageously expensive – in fact, many are straightforward once you know what to do. The ROI can be seen not only in avoiding penalties but in positively reaching more customers and improving overall user experience (accessible websites often have better usability for everyone).
By following these steps, you’ll be well on your way to an inclusive and compliant website. It may take some effort, but consider it an investment in your business’s future. You’re not just complying with the law; you’re building a better website for all your users. Next, let’s address some common questions and how our team at LumenForges can assist in this journey.
FAQ: EAA Compliance for Small Businesses (and How LumenForges Can Help)
Q: Does the EAA really apply to my small business?
Q: My website was created before June 2025 – do I need to comply immediately or do I have extra time?
Q: What are the biggest accessibility issues I should look out for on my website?
<h1> to an <h4>).In essence, think of accessibility compliance as both a shield and a sword: a shield from legal trouble, and a sword to cut through to new market opportunities and improved user satisfaction. It’s a win-win for your business and your customers.
Compliance can seem daunting, but you’re not alone and it’s definitely not too late to get on track. The European Accessibility Act has raised the bar, but with the right guidance and a step-by-step approach, even small businesses can meet the challenge. By understanding who it applies to, what is required (remember: WCAG 2.1 AA is your go-to guide), the consequences of ignoring it, and the practical steps to achieve accessibility, you’ve taken the first big step just by educating yourself with this article.
If you have more questions or need a hand with making your website EAA-compliant, LumenForges is here to help – feel free to contact us for expert support. Here’s to building a more inclusive web for everyone, and to future-proofing your business in the process. Now’s the time to comply – and we’re confident that with the tips and insights from this guide, you’re well equipped to make it happen.
Let’s forge a brighter, more accessible digital future together!
Disclaimer: This article is for general information only and does not constitute legal advice. For guidance on your specific situation, consult qualified legal counsel or your national authority.
Sources:
European Accessibility Act official summary – European Commission
commission.europa.eu
WebYes Accessibility Blog: “European Accessibility Act 2025 – Everything You Need to Know” (Melwyn Joseph, Sept 17, 2025)
webyes.com
WebYes: EAA compliance standards (EN 301 549 referencing WCAG 2.1 AA)
AEL Data Blog: “Business Guide to the EAA 2025” (Sept 18, 2025) – on EAA requirements & who must comply
aeldata.com
Applause Blog: “European Accessibility Act and EN 301 549 Explained” (2023) – effect date and scope
applause.com
ITRex Blog: “Navigating the EAA 2025: strategic guide for businesses” (June 10, 2025)
itrexgroup.com
Accessible.org: “European Accessibility Act Summary” (Nov 16, 2024) – small business exemptions and benefits
accessible.org
WebYes Blog: “EAA Fines and Penalties (And How to Avoid Them)” (May 19, 2025)