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How the European Accessibility Act could shape digital accessibility

Have you ever seen company websites or apps that feel like time capsules from the 90s or the early 2000s? Maybe for some brands it’s a deliberate design choice, but there are some companies that have never updated their websites or digital devices after their first launch. On top of being a poor reflection of the company and potentially scaring away new customers, EU-based companies could risk facing significant fines if their digital products and services don’t comply with modern accessible guidelines.

In this article, we’re going to dive into the new European act that compels companies to make their digital products and services more accessible. We’ll also reflect on how this act could shape the future of Europe’s digital accessibility.

European Union Flags © Pixabay - Dusan Cvetanovic
European Union Flags © Pixabay - Dusan Cvetanovic

The European Accessibility Act (EAA)

In Europe, digital accessibility used to only be mandatory for products and services run by the public sector. However, since 2025, the European Accessibility Act (EAA) had been expanded . This act now pushes more types of digital products and services within the EU to comply with the Web Content Accessibility Guidelines (WCAG). Examples of products and services that have to follow these guidelines are:

  • E-commerce web shops
  • Websites for telecom providers
  • Computers and Computer Software
  • ATM-machines
  • Public ticket machines (for public transport)
  • Online banking
  • Loans and mortgages
  • Apps to watch movies and series
  • Electronic books (E-books)

For the full list of products and services, we advise everyone to read article 2 of the European Accessibility Act.

The intention of this act is to ensure technical standardization for these digital products and services within Europe. Additionally, it is meant to help close the gap between the digital world and people who could benefit from accessible design. On top of that, most of these guidelines also help optimize the SEO score of a company’s website, so following these guidelines also have marketing benefits.

What is Digital Accessibility?

To understand the impact this act could have on digital accessibility in Europe, we need to define what it exactly means. Digital Accessibility is the practice of making websites and digital services accessible to every user. This means that digital content needs to work on different devices, different environments, and it needs to work for all people with different abilities. Although the definition of digital accessibility is rather simple and direct, its practicality is often what makes it complex. There are many types of digital products and services, such as ticket machines, tv screens, websites, apps, and self-checkouts. Furthermore, there’s an important question to ask: who or what decides that your digital product or service is accessible (enough) for everyone?

Web Content Accessibility Guidelines (WCAG)

The EAA mainly uses the Web Content Accessibility Guidelines (WCAG) as a benchmark to check whether your digital products and/or services comply with digital accessibility standards. The WCAG are recommendations to make your web and digital content more accessible to a wider range of people with disabilities . The WCAG was published by the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C). While the first guidelines were written in 1995, W3C keeps publishing new versions of the WCAG, with the latest release being published in 2023, version 2.2 to be specific.

These guidelines contain highly detailed descriptions of how every component of your digital service should look like, with examples like:

  • Ideal color contrast
  • Visual rules for interactive buttons/elements
  • Alternative captions & descriptions for images
  • Keyboard accessibility
  • Resizable texts
  • Rules of navigation within the digital environment

With every rule and/or guidelines, there are levels of accessibility you can achieve, with level A being the lowest level of accessibility and level AAA being the highest.

The EAA has set WCAG 2.1 Level AA as the minimum requirement for accessibility for digital products and services. Some of the rules worth mentioning to achieve this level is:

  • The product/service needs to be compatible with screen readers, keyboard navigation, and other assistive technologies
  • The product/service should use accessible themes, good contrasting color combinations, and clear focus indicators to enhance readability and usability
  • The product/service should include captions into video content, as well as providing audio descriptions and transcripts

For the full list of all recommendations, we advise everyone to read the full WCAG guidelines and Section I of Annex I of the European Accessibility Act.

What happens when you don’t comply?

Expanding the types of services and products that need to comply with the WCAG guidelines immediately raises the fair question: is this applicable to the service or product that you provide? The first thing to check is whether your organization operates or trades in an EU member state, has more than 10 employees and has an annual turnover of at least €2 million. If so, your organization should comply with minimum required WCAG 2.1 Level AA.

Failure to comply with this act could result in fines as high as €200,000, depending on many factors. Companies can face daily penalties for non-compliance that could go up to €1000 per day. This could vary per country, so to look more into the legality of this act, we advise you to look for information at your own national government website within the EU.

While the expansion of this act was introduced on 28 June 2025, organizations that were established before that date have about 5 years to make sure their digital services and products comply with the WCAG guidelines. The deadline is set on 28 June 2030.

Woman Browsing Internet With Clevy Contrast Keyboard © Clevy
Woman Browsing Internet With Clevy Contrast Keyboard © Clevy

What does this act mean to the future of (digital) accessibility?

Although this act has only been expanded in 2025, we can already analyze what this could mean for many people with certain disabilities. By having this external motivation for companies to think about accessibility, new digital products and services could potentially be designed with a better understanding of inclusion. If the act were to be expanded further, which seems inevitable considering the fast growth of technology, it is crucial that accessibility is being considered when setting the base guidelines.

However, since we’re still in the early stage of this act, we lack the data to determine how effective and helpful these guidelines are to improve digital accessibility. How do we measure the impact of these minimum required guidelines? Will the minimum required level be adjusted in the future as we gain more data? The effectiveness of this directive also highly depends on how the guidelines are applied by the companies and regulated by its member states.

Without this certainty, you can only look at what is being covered by the directive already. This act has been so carefully written and defined, that it even includes the mandatory act to provide support services on the accessibility of the product and its compatibility with assistive technologies, in accessible modes of communication. This might give hope that companies are being motivated to think about inclusive design, rather than just following these guidelines out of necessity. Many companies are not even aware how many people usually are being excluded by poor accessible digital design.

In conclusion

Digital Accessibility comes in many different forms and is not something that can be solved with a general directive. If we consider a large group of users who rely on accessible design, it becomes clear that each individual may have very different needs and expectations. When implementing the regulations defined by the EAA, it is important to recognize that this act represents a step in the right direction, but not a complete solution. The solution also varies per company and digital product or service. It is neither the beginning of the conversation nor the final stage, but rather part of an ongoing effort to create a more inclusive digital environment.

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How the European Accessibility Act could shape digital accessibility