WCAG and the European Accessibility Act: what changed in 2025

The European Accessibility Act is now in force

On 28 June 2025, the European Accessibility Act (Directive 2019/882) became enforceable in every Member State of the European Union. This directive extends digital accessibility obligations far beyond the public sector.

In practice, all e-commerce websites, online banking services, transport platforms, telecom services and audiovisual media must now comply with accessibility requirements if they serve European consumers.

What changes for businesses

Before the EAA

Only public bodies and very large companies (more than 250 million euros in revenue, in some Member States) were concerned. In practice, penalties were rare and average compliance rates for public sites hovered around 47%.

After the EAA

Expanded scope: any business selling products or services online to European consumers
Stronger penalties: fines up to 50,000 euros per violation in most Member States, with the possibility of withdrawing the product/service from the market
Technical reference: WCAG 2.1 Level AA is the baseline across the EU (national frameworks such as the French RGAA 4.1.2 are fully aligned with it)
Active enforcement: national market-surveillance authorities are in charge of monitoring and sanctions

The WCAG 2.1 AA foundation

WCAG 2.1 at Level AA contains 50 Success Criteria grouped under four principles — Perceivable, Operable, Understandable, Robust — covering, among other areas:

Text alternatives: meaningful alt attributes, decorative images, captcha alternatives
Media: captions, audio descriptions, transcripts
Adaptable: information and structure preserved across presentations
Distinguishable: color contrast, text resizing, reflow at 320 px
Keyboard accessible: no keyboard traps, focus order, focus visible
Enough time: pausing, adjusting or extending time limits
Seizures and physical reactions: flashing thresholds
Navigable: skip links, page titles, headings, link purpose
Input modalities: gestures, motion actuation, target size
Readable: language of page, unusual words, abbreviations
Predictable: consistent navigation and identification
Input assistance: error identification, labels, suggestions
Compatible: parsing, name/role/value for assistive tech

How to become compliant

Step 1: Audit what you already have

The first step is to run a WCAG 2.1 AA audit of your site. Classic automated scanners only catch 20 to 30% of issues because they do not test dynamic interactions: keyboard navigation, keyboard traps, ARIA components, visible focus after tabbing.

Scrutia combines static analysis AND dynamic testing to automatically cover the WCAG 2.1 AA Success Criteria that can be checked programmatically.

Step 2: Prioritize fixes

Not all criteria are equal. A keyboard trap (WCAG 2.1.2) is blocking — a keyboard user literally cannot use your site. A missing heading level (WCAG 1.3.1) is minor — information is still accessible.

Prioritize:

Blocking: keyboard traps, components inaccessible by keyboard, screen-reader incompatibility
Major: images without alternatives, invisible focus, links without context, form fields without labels
Minor: heading hierarchy, text spacing, 200% zoom

Step 3: Train your teams

Accessibility is not a one-off project. Each new component, redesign or content update can introduce regressions. Train your developers on the basics (semantic HTML, ARIA, keyboard navigation) and integrate accessibility tests into your CI/CD pipeline.

Concrete sanctions

National enforcement bodies across the EU can typically:

Issue a formal notice with a compliance deadline (3 to 6 months)
Impose an administrative fine up to 50,000 euros per violation
Order a market withdrawal: a temporary ban on selling the non-compliant service
Publish the sanction: a reputational hit that can outweigh the fine itself

For public bodies, fines are often capped at lower annual limits, but public sanction notices on official registries carry significant reputational impact.

Estimate your exposure with our free fine calculator

Conclusion

The EAA is not optional. If your site sells products or services online to European consumers, you must be compliant. Auditing is the first step. Acting now means avoiding penalties and improving the experience for every visitor.