EAA Compliance Deadline: What Businesses Need to Know

The EAA Deadline Has Arrived

June 28, 2025, marked one of the most significant dates in European digital regulation: the main compliance deadline for the European Accessibility Act (EAA). From this date onward, all products placed on the market and services provided in the European Union must meet the accessibility requirements laid out in Directive (EU) 2019/882.

If your business offers digital services to EU customers and you have not yet achieved compliance, you are now operating outside the law. But it is not too late to act. This guide explains what the deadline means in practical terms and what you should do right now.

What Changed on June 28, 2025

The EAA required all EU member states to transpose the directive into national law by June 2022. From June 28, 2025, the actual accessibility requirements became enforceable. This means:

• New products: All new products placed on the EU market must meet accessibility requirements
• All services: All services provided to EU consumers must be accessible, including websites, mobile apps, e-commerce platforms, banking services, and transport services
• Enforcement begins: National market surveillance authorities can now take action against non-compliant businesses
• Consumer complaints: EU citizens can file formal complaints about inaccessible products and services

Who Must Comply

The EAA applies to a wide range of businesses. You must comply if you:

• Sell products or provide services to consumers in any EU member state
• Operate an e-commerce website or mobile app accessible to EU users
• Provide banking or financial services in the EU
• Offer electronic communications services
• Provide transport services (airlines, rail, bus, ferry) with digital booking systems
• Publish e-books or operate audio-visual media services

The Microenterprise Exemption

The only exemption for service providers is for microenterprises: businesses with fewer than 10 employees AND annual turnover or balance sheet under €2 million. If you exceed either threshold, you must comply. Note that this exemption does not apply to product manufacturers.

Penalties by Country

Each EU member state has established its own penalty regime. Here are examples from several countries:

• Germany: Fines up to €100,000 for violations, with the Federal Accessibility Agency overseeing enforcement
• France: Fines up to €50,000 per inaccessible service, doubling for repeat offenses
• Spain: Fines ranging from €301 to €1,000,000 depending on severity
• Italy: Fines of 5% of turnover, with AGID as the enforcement authority
• Netherlands: Administrative fines and orders to cease non-compliant services
• Portugal: Fines and mandatory compliance orders under the national transposition

What You Need to Do Right Now

If you have not yet started your accessibility compliance journey, here is your action plan:

Immediate Actions (This Week)

1. Audit your website: Use EAAPass to run a comprehensive WCAG 2.1 AA audit of your website. This will give you a clear picture of your current compliance level.
2. Assess your risk: Based on the audit results, assess the severity and volume of accessibility issues. This determines your risk level and should inform your prioritization.
3. Assign responsibility: Designate someone in your organization as the accessibility lead. This could be a product manager, a developer, or a dedicated accessibility specialist.

Short-Term Actions (This Month)

1. Fix critical issues: Address barriers that completely prevent access, such as inaccessible forms, missing keyboard navigation, and non-functional interactive elements.
2. Publish an accessibility statement: Even while you are working on full compliance, publish a statement describing your commitment, current status, and contact information for users who encounter barriers.
3. Document your efforts: Keep records of your accessibility improvement efforts. If enforcement action occurs, demonstrating active progress toward compliance can mitigate penalties.

Medium-Term Actions (Next 3 Months)

1. Fix all automated issues: Resolve all issues identified by automated testing tools.
2. Conduct manual testing: Test your site with keyboard navigation, screen readers, and other assistive technologies.
3. Train your team: Ensure developers, designers, and content creators understand accessibility requirements.

Long-Term Actions (Ongoing)

1. Integrate accessibility into your development process: Make accessibility part of your design system, code review process, and QA testing.
2. Monitor continuously: Use automated monitoring to catch new accessibility issues as they are introduced.
3. Regular audits: Conduct comprehensive audits at least annually, or after major redesigns.

The Transition Period for Existing Contracts

There is one important grace period: service contracts that were concluded before June 28, 2025, have until June 28, 2030, to meet the accessibility requirements. However, this only applies to contracts in place before the deadline — not to new contracts or services launched after June 28, 2025.

Can You Claim Disproportionate Burden?

The EAA allows businesses to claim exemption from specific requirements if compliance would impose a "disproportionate burden." However, this is a high bar:

• You must document and justify the claim
• You must still comply with all requirements that are not disproportionately burdensome
• You must reassess the claim at least every five years
• You must provide the assessment to authorities upon request
• Simply stating that compliance is expensive or inconvenient is not sufficient

The Business Case Beyond Compliance

While legal compliance is the immediate driver, accessibility improvements benefit your business in multiple ways:

• Market expansion: 87 million EU citizens have a disability. Accessible services reach this market.
• Aging population: Accessibility features help the growing older adult population use your services.
• SEO improvement: Many accessibility practices improve search engine rankings.
• Better UX: Accessible design improves usability for all users.
• Risk reduction: Proactive compliance reduces legal and financial risk.

Start Your Compliance Journey Today

The deadline has passed, but it is not too late to act. The sooner you begin, the sooner you reduce your risk and open your services to millions of additional users. EAAPass makes it easy to get started — run your first audit today and get a clear roadmap to WCAG 2.1 AA compliance. Start your free audit now.