European Accessibility Act: Website Compliance Requirements

EAA requirements for website accessibility in EU. Legal deadline, compliance timeline, WCAG 2.1 AA standard, and penalties.

9 min read

Overview

The European Accessibility Act (EAA) requires websites and digital services of public and private organizations to be accessible. Compliance deadline is June 28, 2025 with limited exceptions. EAA is more prescriptive than ADA.

Jurisdiction

European Union (27 member states) and EEA countries (Iceland, Liechtenstein, Norway)

Who must comply

All websites of public authorities (government, education). All websites of private enterprises with 10+ employees. Essential services must comply. Some small businesses have exemptions (under 10 employees).

Penalties

Administrative fines up to €10,000 per violation (varies by member state) – Up to €500,000 or 2-4% of annual revenue (varies by member state); mandatory site closure/remediation orders

Key Requirements

WCAG 2.1 Level AA Conformance

All websites must achieve WCAG 2.1 Level AA. Non-negotiable requirement. No exceptions for 'technical difficulty'.

Accessibility Statement

Every website must have an accessibility statement detailing conformance level, known limitations, contact for accessibility issues. Statement must be easy to find (usually in footer).

Feedback Mechanism

Website must have clear mechanism for users to report accessibility issues and request assistance. Organizations must respond within 30 days.

Disproportionality Assessment

Organizations can claim 'disproportionate burden' only if full compliance costs exceed 25% of annual revenue. Burden must be documented and published.

Monitoring and Enforcement

Designated accessibility bodies in each EU state monitor compliance. Organizations can be ordered to remediate or face fines.

Compliance Checklist

WCAG 2.1 Level AA audit completed with formal report

All 50 success criteria tested and documented

Accessibility statement created and published

Contact form for accessibility feedback established

Response process for accessibility issues documented (30-day SLA)

Third-party content and plugins tested

Accessibility conformance claim document prepared

Known limitations documented (if any)

Disproportionality assessment completed (if claiming burden)

Staff trained on accessibility requirements

Ongoing monitoring process established

Annual compliance audit scheduled

Documentation of compliance efforts maintained

Penalties & Enforcement

Penalty range: Administrative fines up to €10,000 per violation (varies by member state) to Up to €500,000 or 2-4% of annual revenue (varies by member state); mandatory site closure/remediation orders
EAA enforcement is government-led, not lawsuit-based like ADA. Penalties are administrative and can be more severe (up to 4% revenue). Combined with reputational damage and business disruption.

Timeline

2019

EAA Directive 2019/882 published; sets accessibility requirements for digital services

2021

June 28, 2021: EAA deadline for implementation into national laws (3 years)

2025

June 28, 2025: Primary compliance deadline. Organizations must be WCAG 2.1 AA compliant

2025

After June 28, 2025: Non-compliant sites subject to enforcement action, fines, forced closure

2026

Monitoring bodies actively enforcing; fines and remediation orders issued for non-compliance

Frequently Asked Questions

When do websites need to comply with EAA?

June 28, 2025 is the primary deadline. After that, non-compliant sites risk regulatory action and fines. Grace periods may exist in some member states, but compliance is expected by mid-2025.

Do I need an accessibility statement?

Yes. Required by EAA. Must explain conformance level (WCAG 2.1 AA), known limitations, feedback process, and contact information. Must be easy to find and in clear language.

What if I have legitimate disproportionality concerns?

You can document 'disproportionate burden' if compliance would cost more than 25% of annual revenue. But burden must be formally assessed, documented, and published. Claiming burden doesn't exempt from compliance; it requires alternative solutions.

Are PDFs covered by EAA?

Yes. PDFs published after June 28, 2025 must be accessible. PDFs published before are exempt unless they document legally important procedures (contracts, terms). Remediate strategically.

What's different between EAA and ADA?

EAA is government-led regulation; ADA is lawsuit-based. EAA mandates accessibility proactively; ADA requires response to lawsuits. EAA has compliance deadline; ADA has no deadline (ongoing). EAA requires accessibility statement; ADA doesn't. Both require WCAG 2.1 AA.

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