EAA Deadline: What Happens After June 28, 2025
The European Accessibility Act is now enforceable. Market surveillance authorities are active. Here's the enforcement reality.
Enforcement Is Real — Not Theoretical
Unlike previous accessibility regulations that lacked teeth, the EAA gives each EU member state authority to impose penalties on non-compliant businesses. Germany's Federal Office for Accessibility has already issued formal notices. France's ARCOM has published its first batch of non-compliance reports.
The penalty structure varies by country but ranges from €5,000 to €500,000 per infringement, with repeat violations escalating. Some countries (Netherlands, Sweden) can order market withdrawal of non-compliant digital products.
Who's Affected — The Scope Is Broader Than You Think
The EAA applies to 'products and services placed on the market after June 28, 2025.' This includes: e-commerce websites, banking services, transport ticketing, e-books, telecom services, and any B2C digital product sold to EU consumers.
Key nuance: If your website serves EU customers — even from a US-based company — you're in scope. This isn't GDPR-style 'processing EU data.' It's 'selling to EU people.' The jurisdictional hook is the consumer's location, not yours.
Important for US companies
If you have EU customers, you're in scope. The EAA doesn't have a GDPR-style 'establishment in the EU' requirement. Market access = compliance obligation.
Technical Requirements Mapping
The EAA references EN 301 549 as the harmonized standard, which maps to WCAG 2.1 Level AA. However, the standard is being updated to reference WCAG 2.2, and market surveillance authorities are already using 2.2 criteria in their assessments.
Practically, this means you need: WCAG 2.1 AA compliance at minimum (mandatory), WCAG 2.2 AA compliance (strongly recommended and increasingly expected), accessibility statement published on your site, and a feedback mechanism for users to report barriers.
- WCAG 2.1 Level AA — mandatory baseline
- WCAG 2.2 Level AA — strongly recommended, increasingly tested
- Published accessibility statement — required by Article 14
- Feedback mechanism — users must be able to report barriers
- Disproportionate burden assessment — if claiming exemption, must be documented
90-Day Action Plan
If you haven't started EAA compliance work, here's a realistic timeline to reduce risk:
Week 1-2: Run a full-site automated scan (RegLayer covers this). Identify critical and serious violations. Prioritize by user impact, not just severity.
Week 3-6: Fix critical issues — color contrast, missing alt text, keyboard traps, form labels. These are the violations surveillance authorities look for first.
Week 7-8: Publish your accessibility statement. Document known issues and remediation timeline. This shows good faith.
Week 9-12: Address remaining serious issues. Set up monitoring for regressions. Train development team on accessible coding patterns.
Check your EAA compliance
RegLayer maps WCAG criteria to EAA requirements automatically. See your compliance status.
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