How to meet accessibility standards ahead of the EAA legislation

What is the EAA?    

The European Accessibility Act is a mandate that requires businesses operating in EU member states to meet digital accessibility standards. It's applicable to any business within the EU with at least 10 staff and a turnover above €2 million. It also applies to businesses that trade within the EU, even if the company is based outside of this jurisdiction. The goal of the act is to ensure that people with disabilities, as well as situational or temporary impairments, can access products and services online, without encountering barriers. The EAA covers a wide range of digital products and services, including:  

• Websites and apps 

• Computers and operating systems 

• Smartphones 

• E-books 

• Ecommerce 

• ATMs, ticketing and check-in machines 

• Television and audio equipment 

• Telephone, transport and banking services 

By June 2025, providers of products and services that operate within the EU must prove that they’re abiding by the legislation. Failure to comply with the EAA may result in penalties that include significant fines, restricted market access and – in some circumstances – CEOs facing jail time.  

What does this legislation mean for companies who operate solely in the UK?  

Although the UK was involved in the creation of the EAA, there are currently no plans to incorporate it into national law following Brexit. However, UK-based organisations will still need to comply with EAA requirements when operating in EU member states. To meet the UK’s accessibility legislation, organisations must take the necessary steps to make their websites and mobile applications accessible by adhering to the Web Content Accessibility Guidelines: perceivable, operable, understandable and robust. Additionally, public sector organisations are required to publish an accessibility statement, which is also considered best practice for private sector websites.

What will the impact be and why does it matter?  

While ensuring that your products and services are fully accessible is the right thing to do, you should also consider revenue as a driver to improve the accessibility of your products or services. As of 2024, WHO shared that an estimated 135 million people within Europe are living with a disability. And these figures do not account for minor disabilities, or impairments that may be temporary or situational. Therefore, if your digital products aren’t EAA-compliant, there are two financial risks:  

1. The risk of being hit with a fine and trading restrictions. 

2. The risk of losing customers who encounter accessibility barriers and abandon their purchase journey or choose an alternative service. 

What if “designing for all” feels too broad for your brand?  

Unless you’re operating a service that needs to be accessed by every person (e.g. gov.uk website), you’re likely to be very intentional about your target market. But even if you're only targeting a certain customer base, you need to be mindful of the fact that every group of humans will include a spectrum of abilities. Excluding users with additional access requirements – even unintentionally – is not only unethical, it’s also going to be illegal once the EAA is implemented.  

Accessibility standards are not about stifling creativity  

To product teams, 'creative' and 'legal' can seem at odds with each other, and some designers may feel stifled when applying accessibility restrictions to their work. However, when it comes to designing and building digital products, most user-experience practitioners are already used to operating within constraints, from brand and content guidelines to rigid design systems. Therefore, it’s a good idea to bake accessibility standards into design processes and governance systems that already exist. This will make them more familiar and achievable, and foster the mindset that accessibility standards are part of everything that product teams design, build and deploy.  

We recommend taking the following steps to get ahead of EAA legislation  

• Identify any accessibility issues in the digital experiences you offer by conducting an audit. Accessibility audits will determine the current level of compliance and highlight areas that need to improve. Once the audit is done, findings can be prioritised and recommendations made to meet accessibility standards. 

• Make necessary accommodations to run rounds of fully-inclusive user testing. This can be done as part of an audit to identify issues, or it can be used to validate any improvements you've made.  

• Implement a contact form that invites users to report any areas of your product or service where they encounter barriers. Log the submissions and prioritise fixes, if possible. Be sure to add the issues logged to your records along with efforts to meet accessibility standards, as you may be asked to provide evidence of this if your company is audited.

• Make sure that your designers are practicing accessible design and communicating accessibility requirements to developers, all of whom need to follow WCAG best practices for all user-interface code. In addition, every new feature should undergo accessibility testing during design and development, as well as following deployment.

• Publish accessibility statements for all products and services. Accessibility statements are a tangible way to explain how your product meets accessibility standards and thus complies with the EAA. It’s also an opportunity for you to call out any parts of the digital experience that are not yet fully accessible; it’s best to be upfront about this, rather than let users unknowingly encounter issues. 

Still not sure how to get ahead of EAA legislation? We’re here to help  

We believe that the time is now to make sure that your business is ready to comply with the EAA regulations. We can work with your teams to ensure that your products and services meet accessibility standards. It’s really a win-win situation: no users will feel excluded, plus your business will benefit from a larger user base, greater user satisfaction and a product team that’s energised by a commitment to inclusive design. 

Learn more about our accessibility services or get in touch.