The European Accessibility Act (EAA) has been mandatory since June 2025. If your company sells digital products or services in the European Union, your website must comply with the WCAG 2.2 Level AA standard. Failure to comply carries fines of up to 100,000 euros per member state. And yet, 94.8% of websites still do not meet these requirements according to the WebAIM Million 2024 report.
This article explains what the regulation demands, how to audit your site, and what steps to follow to truly comply — without shortcuts that make things worse.
What Has Changed With the European Accessibility Act
The EAA (Directive 2019/882) harmonizes digital accessibility standards across the EU for the first time. Until its entry into force, each country had fragmented regulations. Now there is a single framework that applies to any company operating in the European market.
We are not just talking about public administrations. The EAA covers the private sector: e-commerce, electronic banking, transport services, telecommunications, e-books, and any digital service directed at consumers.
Microenterprises (fewer than 10 employees and under 2 million euros in revenue) are exempt. Everyone else is not. And the regulation applies to both European companies and any company offering services to consumers within the EU, regardless of where they are headquartered.
What the Regulation Specifically Requires
The EAA does not invent its own technical requirements. It refers to the harmonized standard EN 301 549, which in turn adopts the WCAG 2.2 Level AA guidelines as its technical reference. In practice, complying with the EAA means complying with WCAG 2.2 AA.
Deadlines and Penalties
- June 28, 2025: transposition deadline. Member states were required to incorporate the directive into their national legislation.
- June 28, 2030: end of the transitional period for products and services already on the market before 2025.
- Penalties: each member state defines its own, but the directive requires them to be "effective, proportionate, and dissuasive." Several countries have set fines of up to 100,000 euros per infringement. In cases of repeat offenses, figures can multiply.
Who Is Affected
The regulation is clear in its scope. It applies to e-commerce sites, banking and financial services platforms, websites of transport operators, electronic communications services, and audiovisual content platforms. If your company sells online to European consumers, you are within scope.
WCAG 2.2 AA: The Technical Standard Behind the Law
The Web Content Accessibility Guidelines (WCAG) have been evolving for over 25 years. Version 2.2, published in October 2023, adds 9 new success criteria compared to version 2.1. They are organized around four principles that all web content must meet.
The Four Principles (POUR)
Perceivable: information must be perceivable by at least one sense. This includes alternative text for images, captions for videos, sufficient contrast between text and background (minimum ratio 4.5:1 for normal text), and the ability to resize text up to 200% without losing functionality.
Operable: users must be able to interact with all interface elements. Full keyboard navigation, sufficient time to complete tasks, no content that causes seizures, and clear navigation mechanisms.
Understandable: content and the interface must be predictable. Language declared in the HTML, descriptive form labels, clear error messages, and consistent behavior of interactive elements.
Robust: content must work with current and future assistive technologies. Valid semantic HTML, correct ARIA roles, and compatibility with screen readers such as NVDA, JAWS, or VoiceOver.
What Is New in WCAG 2.2
Version 2.2 introduces criteria designed for users with cognitive and motor disabilities. The most relevant ones:
- Minimum target size: interactive elements must be at least 24x24 CSS pixels.
- Consistent help: if you offer help mechanisms (chat, phone, FAQ), they must be in the same relative location on all pages.
- Accessible authentication: you cannot require the user to memorize or transcribe complex information to log in. CAPTCHAs with cognitive tests are considered a barrier.
How to Audit Your Website's Accessibility
A serious accessibility audit combines automated analysis with manual review. Automated tools are a starting point, but they detect only 30% to 40% of the issues. Expert manual review achieves a 95% detection rate.
Automated Tools (First Filter)
These tools identify obvious errors: images without alt text, insufficient contrast, unlabeled forms, disordered headings.
- axe-core (Deque): browser extension and library integrable into CI/CD. It is the engine behind most testing tools.
- Pa11y: command-line tool ideal for integration into development pipelines. It enables recurring automated audits.
- Lighthouse (Google): includes an accessibility section in its report. Useful as a quick indicator, but not comprehensive.
Running these tools is the minimum step. If your website scores below 90 on Lighthouse's accessibility rating, you have structural problems to resolve before thinking about regulatory compliance.
Manual Review (Where the Real Value Lies)
The problems that automated tools miss are precisely the ones that most affect real users:
- Keyboard navigation: can you navigate the entire site without a mouse? Is focus visible on each element? Does the tab order make logical sense?
- Screen readers: does a NVDA or VoiceOver user understand the page structure? Do forms correctly announce their fields and errors?
- Context and comprehension: do links have descriptive text or do they say "click here"? Do data tables have row and column headers?
- Complete flows: can you complete a purchase, fill out a contact form, or book an appointment using only the keyboard and a screen reader?
If your website is built on WordPress, the audit must include active plugins. Many popular plugins generate inaccessible HTML that contaminates otherwise correct pages.
Why Accessibility Overlays Do Not Work
Facing regulatory pressure, many companies turn to "quick fixes": JavaScript widgets that overlay the website promising instant accessibility. These are called accessibility overlays.
They do not work. And we say this with data.
In 2024, the FTC fined accessiBe $1 million for deceptive advertising. The company claimed its widget made websites WCAG-compliant. The FTC determined those claims were false.
Overlays present documented problems:
- They do not fix the source code. They superimpose a layer that attempts to compensate for structural errors, but screen readers still encounter the original HTML.
- They interfere with assistive technologies. Real users with disabilities report that overlays worsen their experience, not improve it. The disability community has been particularly vocal against these products.
- They are not compliant. No standard (WCAG, EN 301 549, ADA) accepts an overlay as evidence of compliance. An overlay does not protect you against a claim or an inspection.
- They create a false sense of security. The company believes it "already complies" and stops investing in real accessibility.
Accessibility is built from the code and design, not patched afterward. Any solution that promises compliance without touching your HTML, your CSS, or your user flow is selling you something that does not exist.
Step by Step: How to Make Your Website Truly Accessible
Complying with WCAG 2.2 AA is not a weekend project, but it does not require rebuilding your site from scratch either. It is an iterative process that, well planned, integrates into the normal development cycle.
1. Complete Initial Audit
Combine automated tools (axe-core, Pa11y) with an expert manual audit. The result should be a report that classifies each issue by severity (critical, high, medium, low) and by WCAG criterion violated.
2. Prioritization by Impact
Not all failures carry the same weight. Prioritize in this order:
- Blockers: elements that prevent completing critical tasks (purchase, registration, contact).
- Severe: information inaccessible to assistive technology users.
- Moderate: navigation or comprehension issues that hinder but do not prevent use.
- Minor: contrast details, target sizes, or non-critical ARIA attribute omissions.
3. Code Remediation
The most common changes include: adding descriptive alternative text, fixing heading hierarchy, properly labeling forms, ensuring keyboard navigation, implementing visible focus states, and improving color contrast.
A relevant data point: according to a Nucleus Research study, websites with good accessibility see a 12% improvement in organic traffic. The semantic HTML that WCAG requires is exactly what Google values for ranking. If you invest in accessibility, you are simultaneously investing in SEO and conversion optimization.
4. Testing With Real Users
Before declaring the project complete, test with people who use assistive technologies daily. Their findings always reveal problems that neither tools nor auditors detected. Including users with different types of disabilities (visual, motor, cognitive) provides complementary perspectives.
5. Accessibility Statement
The EAA requires publishing an accessibility statement on your website. It must indicate the conformance level achieved, known exceptions, the date of the last review, and a contact mechanism for reporting accessibility issues. It is not a decorative document — it is a legal requirement.
6. Ongoing Maintenance
Accessibility is not a project with an end date. Every new feature, every design change, and every content update can introduce barriers. Integrate accessibility checks into your development pipeline (axe-core in CI/CD) and plan periodic audits at least once a year.
Accessibility and SEO: An Alliance That Multiplies Results
The connection between accessibility and organic ranking is not coincidental. Google has been rewarding exactly the same practices that WCAG requires for years.
Semantic HTML: hierarchical headings (H1-H6), correctly marked lists, and tables with headers do not just help screen readers. They help Google understand your content structure.
Image alt text: a basic accessibility requirement that also feeds Google Images and improves the page's semantic relevance.
Contrast and readability: a readable website retains users longer, reduces bounce rate, and sends positive engagement signals.
Performance: many accessibility improvements (reducing unnecessary JavaScript, simplifying the DOM, optimizing load order) coincide with optimizations that improve Core Web Vitals.
Accessible websites conforming to WCAG AA register an average +12% in organic traffic compared to their previous non-accessible versions. It is not a side effect — it is the direct result of doing things right for all users, including Googlebot.
The digital accessibility market is valued at a projected $3.24 billion by 2034. Companies that invest now are not just avoiding penalties — they are capturing a user segment that the competition ignores.
Frequently Asked Questions About Web Accessibility and the EAA
When Did the European Accessibility Act Become Mandatory?
The EAA came into force on June 28, 2025. EU member states were required to have transposed the directive into national legislation by that date. Products and services already on the market have a transitional period until June 2030.
What Technical Standard Must I Comply With?
The European harmonized standard is EN 301 549, which adopts the WCAG 2.2 Level AA guidelines as its technical reference. Complying with WCAG 2.2 AA is the most direct way to demonstrate conformance with the regulation.
Does My Small Website Also Have to Comply?
If your company has fewer than 10 employees and annual revenue under 2 million euros, you are exempt. In any other case, if you offer digital products or services to consumers in the EU, the regulation applies to you.
Can I Use an Accessibility Overlay or Widget to Comply?
No. Overlays do not guarantee WCAG conformance and can worsen the experience for users with disabilities. The FTC fined accessiBe $1 million for claiming otherwise. Accessibility requires changes to the source code, not superficial patches.
How Much Does It Cost to Make a Website Accessible?
It depends on the site's size, the complexity of interactions, and the current state of the code. An initial audit identifies the real scope of work. In general, it is significantly cheaper to integrate accessibility from design than to remediate afterward. What is not optional is the cost of not doing it: fines of up to 100,000 euros and exclusion from a growing user segment.
Are Automated Tools Sufficient for an Audit?
No. Tools like axe-core, Pa11y, or Lighthouse detect between 30% and 40% of accessibility issues. Expert manual review, including screen reader tests and keyboard navigation, detects up to 95%. Combining both methods is essential.
Does Accessibility Affect SEO?
Yes, positively. The semantic HTML, alternative text, heading structure, and performance that WCAG requires coincide with the factors Google rewards. Accessible websites register an average +12% in organic traffic.
How Often Should I Review My Website's Accessibility?
At a minimum, once a year with a complete audit. Additionally, every new feature or significant design change should undergo an accessibility review before publication. Integrating automated checks in the development pipeline (CI/CD) catches regressions continuously.
The Time to Act Is Now
Web accessibility has moved from a recommendation to a legal obligation with real economic consequences. But beyond the regulation, making your website accessible is a smart business decision: you expand your audience, improve your SEO, reduce legal risk, and demonstrate a genuine commitment to inclusion.
The first step is knowing where you stand. A professional accessibility audit identifies the problems, prioritizes them, and defines a concrete action plan. It is the difference between truly complying and crossing your fingers.
