The EAA is here

What the directive says

The EAA doesn't set a technical standard. It sets a principle: digital products and services sold in the European Union must be accessible to people with disabilities. Each member state transposes this principle into national law and designates its own enforcement authorities.

Products covered

• Computers and operating systems
• Smartphones and tablets
• E-book readers
• Self-service terminals and ATMs
• Payment terminals

Services covered

• E-commerce: any website or application that sells products or services to consumers
• Banking: online banking, payment applications
• Transport: ticketing, real-time travel information (air, bus, rail, waterborne)
• Telecommunications: electronic communication services
• Audiovisual: on-demand video services
• E-books: formats and distribution platforms

In short: if a European consumer can buy, pay, book, or communicate through your digital product or service, the EAA applies.

Who is exempt

The EAA provides three exemptions:

Micro-enterprises providing services: if you employ fewer than 10 people and your annual turnover (or balance sheet) doesn't exceed €2 million, you're exempt. As long as you only provide services. A manufacturer of products covered by the directive must comply regardless of size.

Fundamental alteration: if an accessibility requirement would fundamentally alter the very nature of the product or service, that requirement doesn't apply. In practice, this clause is narrow. Making an e-commerce site usable for people with disabilities doesn't alter its nature.

Disproportionate burden: distinct from the previous one, it applies when compliance would impose an excessive burden, assessed against the criteria in Annex VI of the directive: compliance costs weighed against the organization's resources and the expected benefits for people with disabilities. The assessment must be documented, re-evaluated regularly, and kept available for enforcement authorities. It's not a checkbox, it's a case you have to defend.

The technical standard

The EAA sets goals, not technical specifications. To meet them, the European Union relies on a harmonized standard: EN 301 549.

EN 301 549: the reference standard

This is the European accessibility standard for information and communication technology. If your product or service conforms to EN 301 549, you're in a position to benefit from a presumption of conformity with the EAA. In plain terms: in the event of an audit or dispute, the other party must prove your product isn't accessible despite your compliance with the standard, not the other way around. One precision: the formal presumption requires the standard to be referenced in the Official Journal of the EU under the EAA, yet the revision of EN 301 549 to that end (incorporating WCAG 2.2) is still in progress. So it's not an absolute shield, but it's the most defensible position.

EN 301 549 covers more than the web:

• Chapter 9: web content (WCAG 2.1 Level AA)
• Chapter 10: non-web documents (PDF, office files)
• Chapter 11: software and mobile applications
• Chapters 5-8: generic requirements, two-way voice communication, video capabilities, hardware
• Chapter 12: documentation and support services

WCAG: the web baseline

For web content, EN 301 549 incorporates WCAG 2.1 Level AA in full, the international standard from the W3C. If you build for the web, this is your day-to-day reference: 4 principles (perceivable, operable, understandable, robust), 13 guidelines, 78 success criteria (all levels combined, of which 50 at levels A and AA as required by the EAA).

Where to start

You don't need to do everything at once. You need to start.

1. Scan your site yourself. Free tools like WAVE or the axe DevTools extension detect the most common errors in seconds. Images without alt text, insufficient contrast, forms without labels, broken heading structure. It's not an audit, it's a starting point. And it costs nothing.

2. Fix the blockers. Some issues prevent access entirely: no keyboard navigation, no image alternatives, forms unusable by a screen reader. These are your priorities, not because a standard says so, but because people can't use your product.

3. Train your teams. Accessibility isn't a patch you apply at the end. It's a skill that integrates into design, development, and content writing. A trained team doesn't repeat the same mistakes. That's the reason this blog exists, making accessibility concrete, free, and approachable.

4. Get audited when you're ready. A professional WCAG audit makes sense, but after you've fixed the obvious errors, not before. It's a snapshot in time. It's expensive and quickly outdated. Better to have it reflect real work than a starting state.

June 28, 2025 has passed, and for websites and applications there is no grace period: the deadline is already here. The transition until 2030 only concerns products and ongoing contracts. That's neither an excuse to wait nor a reason to panic. It's a schedule. Use it.