The EAA: where the obligation stands

The European Accessibility Act (EAA) is the EU directive behind digital accessibility, implemented through national laws such as Germany's BFSG. It requires that digital products and services be usable by people with disabilities. The technical benchmark is EN 301 549, which for websites and apps points to WCAG. The harmonized version EN 301 549 V3.2.1 references WCAG 2.1 AA, and V4.1.1, expected in 2026, moves to WCAG 2.2. Because WCAG 2.2 fully includes 2.1, building to WCAG 2.2 AA now is the safe choice.

For new products and services the obligation has applied since 28 June 2025. For existing services a transition period runs until 2030. That sounds like plenty of time, but it is not: retrofitting accessibility is far more expensive than building it in from the start, and new projects have to be compliant right away.

The focus is on consumer-facing services: online stores, banking, booking and ticketing, telecommunications, audiovisual services and e-books. The rule of thumb: once a site does more than provide information, allowing a form, a booking, a purchase or a download, it very likely falls under the EAA. Microenterprises providing services may be exempt; products are treated differently. The act also follows the customer, so providers outside the EU can be in scope when they sell to EU consumers.

Enforcement sits with national authorities, and penalties vary by member state. As in the US, accessibility overlays are not a reliable defense; they rarely create genuine conformance. A site built to WCAG 2.2 AA is the better protection because it is both compliant and demonstrable.

A calm three-step approach works: first check whether and how strongly you are affected, for example with a self-check or an audit. Second, fix the barriers in the code rather than with an overlay. Third, publish an accessibility statement and keep the site tested over time, including after each release. Acting early avoids the expensive scramble later.