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The European Accessibility Act for websites and apps

The European Accessibility Act (EAA) goes into effect on June 28, 2025 - just 5 months from now. From that point, websites and apps of companies operating in the EU must meet accessibility standards. Only microenterprises are exempt.

In this article, I'll dive into the requirements of the EAA for websites and apps, the timeline, and a plan to help you get started.

If you're new to accessibility, you might want to start with What is accessibility and who is it for. Otherwise, skip ahead to the EAA requirements.

What is accessibility and who is it for

Accessibility is about building websites and apps that are usable by as many people as possible, regardless of their abilities, devices or input methods.

Making sites and apps accessible is mainly done by ensuring content is easy to consume, interactive elements are easy to use, and navigation with a keyboard, screen reader, or voice commands is fully supported.

A common misconception is that accessibility only affects a small group of users, specifically people who are blind and only navigate using a screen reader. In reality, accessibility helps a wide range of users, including:

Users with reduced vision. Some use screen readers, but many just increase the font size or zoom in.
Users with dyslexia. They benefit from readable fonts, increased line spacing, and consistent layouts.
Users with color blindness. They might miss status indicators unless they're accompanied by labels.
Users with motor impairments. Small hit areas make navigation difficult for users with tremors or other motor challenges and they may rely on keyboard or voice commands.
Users with photo- or motion sensitivity. Subtle animation or flashing elements can trigger discomfort or more severe reactions.

Even users without disabilities benefit from accessibility improvements, as accessibility improves the user experience (UX) for everyone. A large part of accessibility is making your sites and apps easier to use, which allows anyone to speed up through familiar usability perks and reduces frustrations.

Businesses also gain from accessibility. Accessible websites and apps can reach more people and have SEO benefits, as search engines can understand your content better.

European Accessibility Act requirements

The main requirements under the EAA for sites and apps are:

Accessible UI and content
Accessibility statement

Here's a closer look at each.

Accessible UI and content

Your interface and content must be accessible according to the EAA's principles. The law requires that websites and apps are perceivable, operable, understandable, and robust, but it doesn't specify exactly how to achieve this.

In practice, the Web Content Accessibility Guidelines (WCAG) 2.1 level AA is widely considered the best way to meet these legal requirements. While WCAG isn't explicitly written into the law, it aligns closely with the EAA's principles and is referenced in EN 301 549, the European standard for ICT accessibility. This makes WCAG 2.1 the most reliable framework to ensure compliance.

Aside

EN 301 549 is currently being revised to align more closely with the EAA, with a new version expected in late 2025. Once published, it will serve as the official standard for EAA compliance. This update is expected to require WCAG 2.2 AA conformance, but until then, WCAG 2.1 AA remains the best way to ensure compliance.

WCAG 2.1 is built on four key principles, abbreviated as POUR:

1. Perceivable

Ensure all information is accessible through multiple means, such as text, visuals, or audio. The key requirements include:

Summary

Detailed overview

Text alternatives: Use alt attributes for images and provide captions for audio and video.
Semantic HTML: Use proper HTML elements for structure, such as headings, lists, and tables.
Color contrast: Ensure text and images of text have a contrast ratio of at least 4.5:1 (or 3:1 for large text).
Scalable text: Ensure your site or app works well with text sizes up to 200%.

2. Operable

Your site or app must be usable, regardless of input method. The key requirements include:

Keyboard accessibility: Make sure all functionality works well with a keyboard.
Visible focus: Include a clear focus indicator for keyboard navigation.
Avoid flashing content: Limit flashing elements to no more than three flashes per second.
Logical navigation: Ensure focus order is intuitive and links are descriptive.

3. Understandable

Create interfaces and content that are clear and predictable. The key requirements include:

Language declaration: Specify the page's language using the HTMLlang attribute.
Consistent navigation: Maintain consistent menus and naming (labels) across pages.
Error messages: Provide clear error messages and suggestions for correction.

4. Robust

Ensure compatibility with a wide range of devices, browsers, and assistive technologies. The key requirements include:

Valid HTML: Ensure code is well-structured and error-free.
ARIA roles: Use ARIA roles appropriately to convey the purpose and state of custom components.

For the full list of requirements, see the full WCAG 2.1 Guidelines.

Accessibility statement

The EAA also requires you to publish an accessibility statement. This should include:

Compliance level: State whether your site or app complies with WCAG 2.1 Level AA.
Known issues: List any known accessibility issues and how you plan to address them.
Feedback mechanism: Provide a way for users to report accessibility issues or request information in alternative formats.

The statement must be easy to find, clear and regularly updated. It demonstrates your commitment to accessibility and fosters transparency with your users.

For an example accessibility statement, see the EU accessibility statement.

Disproportionate burden

The EAA allows organizations to claim a disproportionate burden exemption if meeting certain requirements is unreasonably difficult or expensive. For instance, a small business might delay fixing a component if doing so requires a costly overhaul.

However, this isn't a free pass. You must justify the exemption in your accessibility statement and still take alternative steps to improve accessibility. The exemption is based on good faith; it's not an excuse to ignore accessibility altogether.

Timeline

As I mentioned earlier, the EAA takes effect in just five months. But that's only the first deadline; there are two key dates to keep in mind:

June 28, 2025: All new developments must comply.
June 28, 2027: Existing services must comply.

The first deadline applies to "all new developments". This includes any updated component and its immediate context. For example:

A small update (e.g. adding a favorites button) requires only that the component and related functionality comply.
A major update (e.g. redesigning a checkout flow) requires the entire section to comply.

By 2027, all applicable sites and apps must fully meet accessibility standards. These deadlines might seem far off, but they come with significant challenges, especially for large existing apps. Starting early will give you the time to assess, plan, and tackle accessibility issues incrementally.

Aside

Remember that in late 2025, a new version of EN 301 549 is expected that will closely align with the EAA. Once published, it will become the official technical standard for EAA compliance, and you'll need to ensure your sites and apps meet the updated requirements.

Next steps

The EAA introduces many new requirements, and its deadlines are fast approaching. Complying with these requirements may take significant time and effort, especially for large websites and apps with poor accessibility.

Here are a few things to start preparing:

Educate your dev team: Share resources like Accessibility essentials every front-end developer should know, and the WCAG 2.1 Guidelines to build awareness.
Perform an accessibility assessment: Test keyboard navigation, check Semantic HTML, evaluate color contrast, ensure elements scale with font size, and identify areas for improvement.
Test your app: Try navigating your app with a screen reader to uncover potential barriers and usability challenges.

Start early, involve your team, and don't wait until the last minute to comply with the EAA. Accessibility isn't just about compliance, accessibility is about making a better and more inclusive experience for everyone.

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