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What is the European Accessibility Act (EAA)?

The European Accessibility Act comes into force on 28th June 2025 and aims to enhance the quality of life for individuals with disabilities and older adults across the EU by ensuring access to digital products and services. This act applies to any business operating within the EU, including those with at least 10 employees and a turnover exceeding €2 million, companies conducting business in the EU, and non-EU companies selling relevant goods or services to EU customers.

 

Scope of the EAA

Products

  • Computers and operating systems
  • Smartphones and other communication devices
  • TV equipment related to digital television services
  • ATMs and payment terminals (e.g., card payment machines in supermarkets)
  • E-readers
  • Ticketing and check-in machines

Services

  • Phone services
  • Banking services
  • E-commerce
  • Websites, mobile services, electronic tickets and all sources of information for air, bus, rail and waterborne transport services
  • E-books
  • Access to Audio-visual media services (AVMS)
  • Calls to the European emergency number 112
Obligations for website accessibility

If your business has a digital presence, your website must comply with the Web Content Accessibility Guidelines (WCAG). You will need to ensure that it is available and accessible to all.

For example the Act requires websites to display information about the accessibility features of services. Users must be able to consult a website’s content and structure and to navigate through webpages, also when using assistive devices.

By focusing on these aspects, you can leverage the power of digital communication to build stronger relationships with your stakeholders in a genuine and impactful way.


What is the standard for compliance with the European Accessibility Act?

While the EAA focuses on functionally meeting the needs of people with disabilities and does not itself provide specific technical standards for accessibility. The presumptive standard of conformity in the EU is EN301549. This defines the requirements and is currently aligned to WCAG 2.1, however it is due to be updated to WCAG 2.2. Given that WCAG is the framework used to assess digital accessibility in the EU then conforming to the ‘AA’ level is the best way to ensure you comply to the EAA.

Ensuring Compliance

As with any new regulations compliance can seem daunting at first, particularly if you do not have experts inhouse to help you navigate the legislation. Here are some practical steps you can take to help you on your journey towards compliance:

 

  1. Understand the Requirements

Familiarize yourself with the EAA and its specific requirements. Determine which of your products and services fall under the scope of the EAA. This includes understanding the four main principles of the Web Content Accessibility Guidelines (WCAG 2.1 Level AA): Perceivable, Operable, Understandable, and Robust

2. Conduct an Accessibility Audit

Perform a comprehensive audit to identify areas where your website or services may not meet the EAA standards. Focus on elements such as compatibility with assistive technologies, text alternatives for non-text content, and accessible navigation structures.

3. Develop a Compliance Plan

Create a plan outlining when and how you will achieve compliance. Prioritize the most critical compliance gaps and set milestones. This plan should include software updates, hardware modifications, service redesigns, and integrating accessibility into the design process of future products and services

4. Implement Accessibility Features

There are some important elements you must implement to ensure you website is accessible.

Read our article on how to create an accessibly website >

BUT remember that this is only the beginning. To be accessible a website must be continuously monitored as new content is published and as the standard evolves. This is a major reason we advise implementing an accessibility monitoring tool – as outlined in this article.

5. Prepare Documentation and Declarations

Prepare documentation detailing how your products and services comply with the EAA. Ensure you have a declaration of conformity or certification from recognized bodies where applicable. This documentation should be easily accessible and understandable.

6. Train Employees

Provide employees with training on the best practices for maintaining compliance. Keep them informed of any changes in standards or regulations. This includes training on how to design and maintain accessible content and services

7. Monitor and Implement Feedback Mechanisms

Regularly monitor the accessibility of your products and services through audits and involve people with disabilities in your testing process. Implement customer feedback mechanisms to continuously improve accessibility

8. Public Accessibility Statement

Create and publish a public accessibility statement that outlines how your service meets the relevant accessibility standards. This statement should include a general description of the service, explanations needed to understand the service, and relevant contact information for users who encounter issues.

By focusing on these aspects, you can leverage the power of digital communication to build stronger relationships with your stakeholders in a genuine and impactful way.


Monitoring and Enforcement

National authorities in EU member states are responsible for enforcing the EAA. Non-compliance can result in fines, legal action, and the prohibition or restriction of non-compliant products and services from the market. For example, in Germany, fines can go up to €100,000 for violations.

Companies following these steps will be well on their way to complying with the EAA and ensuring a more user friendly and accessible website for all of their key stakeholders. If you need help getting started, in conducting an accessibility audit, or redesigning your site to make it fit for the future, please do get in touch.

Talk to us

If you’re unsure of how to implement an accessible website why not get in touch with us. We can help.

 


About Black Sun

Black Sun Global is a stakeholder advisory and engagement agency that's been driving transformation and positive change for ambitious brands for more than 30 years. With deep expertise in disclosure and reporting, ESG, sustainability, and digital engagement, we reshape how organisations connect with customers, investors, employees, and the wider world.

We are trusted partners to some of the most influential global organisations, sparking innovation and sustainable performance through our strategic insights, partnerships, and proprietary technologies.

As founders of the Positive Change Group, we are on a mission to create a new kind of stakeholder relations partner. Our world-class specialists work closely with executive leadership teams to protect reputations, inspire trust, and promote responsible business practices - building resilience and long-term value in a rapidly changing world.

For more information, please visit: www.blacksun-global.com





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