EAA Enforcement Begins: June 28, 2025 - -200 days remaining
EU Web Accessibility Directive vs European Accessibility Act
The European Union has two major accessibility laws that businesses need to understand: the Web Accessibility Directive (WAD) for public sector websites, and the European Accessibility Act (EAA) for private sector products and services. This guide explains both laws, their requirements, and how they affect your organization.
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Both laws require WCAG 2.1 AA conformance. Scan your website to see where you stand.
Scan My Website →Quick Comparison: WAD vs EAA
| Aspect | Web Accessibility Directive | European Accessibility Act |
|---|---|---|
| Scope | Public sector only | Private sector (e-commerce, banking, etc.) |
| Effective Date | September 2020 | June 28, 2025 |
| Standard | WCAG 2.1 AA (EN 301 549) | WCAG 2.1 AA (EN 301 549) |
| Enforcement | Member state authorities | Market surveillance authorities |
| Penalties | Varies by country | Up to €100,000+ per violation |
| Geographic Scope | EU public bodies | Any business serving EU customers |
The Web Accessibility Directive (WAD)
What is the WAD?
Directive (EU) 2016/2102 on the accessibility of websites and mobile applications of public sector bodies was adopted in October 2016 and required transposition into national law by September 2018. It mandates that public sector websites and mobile apps be accessible to people with disabilities.
The directive applies to websites of government bodies, public hospitals, public universities, libraries, courts, and other public institutions across all EU member states. It references the European standard EN 301 549, which aligns with WCAG 2.1 Level AA.
Who Must Comply with WAD?
- • Central government websites and apps
- • Regional and local government bodies
- • Public law bodies (hospitals, universities)
- • Bodies governed by public law
- • Associations formed by public authorities
WAD Requirements
- • Conform to WCAG 2.1 Level AA (via EN 301 549)
- • Publish an accessibility statement
- • Provide a feedback mechanism for users
- • Conduct regular accessibility monitoring
- • Report compliance status to EU Commission
WAD Exemptions
Certain content is exempt from WAD requirements:
- • Office file formats published before September 23, 2018
- • Pre-recorded audio and video published before September 23, 2020
- • Live audio and video
- • Online maps (but accessible alternatives for essential info required)
- • Third-party content not under authority's control
- • Archived content not needed for ongoing administrative processes
- • Intranets/extranets published before September 23, 2019 (until redesigned)
- • Content of schools/kindergartens (except essential functions)
The European Accessibility Act (EAA)
What is the EAA?
Directive (EU) 2019/882 on the accessibility requirements for products and services was adopted in April 2019. Unlike the WAD which targets public sector, the EAA focuses on private sector products and services that are essential to daily life.
The EAA is a harmonization directive designed to create consistent accessibility requirements across EU member states, removing barriers to cross-border trade while improving accessibility for the 87 million people with disabilities in the EU.
Products Covered by EAA
- • Computers and operating systems
- • Self-service terminals (ATMs, ticketing machines, check-in kiosks)
- • Smartphones and tablets
- • TV equipment with computing capability
- • E-readers
- • Consumer terminal equipment for communication services
Services Covered by EAA
- • E-commerce websites and apps (online stores)
- • Electronic communications services
- • Banking services for consumers
- • E-books and dedicated software
- • Audio-visual media services (streaming platforms)
- • Air, bus, rail, and waterborne passenger transport services
EAA E-commerce Requirements
For e-commerce businesses, the EAA specifically requires:
- • Accessible product identification and selection
- • Accessible payment and checkout processes
- • Accessible customer support and feedback mechanisms
- • WCAG 2.1 AA conformance for all web content
- • Accessible mobile apps if offered
- • Accessible PDF documents (invoices, receipts)
EAA Exemptions
The EAA provides exemptions for:
- • Microenterprises (fewer than 10 employees AND annual turnover/balance sheet under €2 million)
- • Disproportionate burden - when compliance would fundamentally alter the service or impose excessive costs
- • Products/services placed on market before June 28, 2025 (grandfather clause - continues until June 28, 2030)
Note: Claiming disproportionate burden requires documented assessment and must be reassessed when service changes or every 5 years.
EAA Penalties and Enforcement
Potential Penalties
- • Fines up to €100,000 per violation (varies by country)
- • Orders to remove non-compliant products from market
- • Prohibition of placing products/services on market
- • Public notification of non-compliance
- • Potential private legal action from consumers
Enforcement Mechanism
- • Each member state designates market surveillance authorities
- • Authorities can request compliance documentation
- • Consumers can file complaints directly
- • Disability organizations can represent consumers
- • Cross-border enforcement cooperation between states
Key Dates and Timeline
WAD Adopted
Web Accessibility Directive becomes EU law
EAA Adopted
European Accessibility Act published in EU Official Journal
WAD Fully Enforced
All public sector websites and mobile apps must comply
EAA Transposition Deadline
Member states must incorporate EAA into national law by June 28, 2022
EAA Enforcement Begins
June 28, 2025: All covered products and services must comply
Grandfather Clause Expires
Products/services placed on market before 2025 must comply by June 28, 2030
How to Prepare for EAA Compliance
Audit Your Current Status
Run an accessibility scan to identify WCAG 2.1 AA violations across your website and apps.
Prioritize Critical Issues
Focus on checkout, payment, and essential functions that directly impact customer ability to complete purchases.
Create Remediation Roadmap
Plan fixes with clear timelines. Address Level A issues first, then AA requirements.
Document Everything
Keep records of accessibility efforts, audits, and fixes. You may need to demonstrate compliance to authorities.
Publish Accessibility Statement
Create a public statement describing your conformance level, known limitations, and contact for accessibility feedback.
Start Your EU Accessibility Compliance Today
Both WAD and EAA require WCAG 2.1 AA conformance. Our free scanner identifies violations and provides prioritized fix recommendations.
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