Is your website compliant with the European Accessibility Act?

EAA requirements: EN 301 549 and WCAG 2.1 AA

The European Accessibility Act (Directive 2019/882) references the European standard EN 301 549 for technical accessibility requirements. For web content, EN 301 549 directly incorporates WCAG 2.1 Level AA success criteria. This means that meeting WCAG 2.1 AA is the path to EAA compliance for your website.

WCAG 2.1 AA defines 50 success criteria across 4 principles — Perceivable, Operable, Understandable, and Robust. Scrutia tests all of these criteria using a real browser and dynamic interaction testing, going beyond static HTML analysis.

Who must comply with the EAA

The EAA applies to a wide range of businesses that provide digital products or services in the EU:

• ✓E-commerce websites — any online store selling products or services to EU consumers
• ✓Banking and financial services — online banking, insurance platforms, payment services
• ✓Transport services — booking platforms, airline and rail websites, ride-sharing apps
• ✓Telecommunications — telecom operators, ISPs, messaging services
• ✓Digital media and publishing — e-books, streaming services, news platforms
• ✓SaaS and software products — any software sold or used within the EU

Exemption threshold:micro-enterprises with fewer than 10 employees AND less than €2 million annual turnover are exempt, unless they provide public services.

Penalties across EU member states

Each EU member state defines its own enforcement mechanisms and penalty levels. Here are examples from major markets:

• ✗France — up to €50,000 per violation, doubled for repeat offenses. Enforced by DGCCRF.
• ✗Germany — fines up to €100,000 under the BFSG (Barrierefreiheitsstärkungsgesetz).
• ✗Spain — fines from €301 to €1,000,000 depending on severity.
• ✗Italy — fines up to 5% of annual turnover. Enforced by AgID.
• ✗Netherlands — fines up to €900,000 enforced by the Authority for Consumers and Markets.

Beyond fines, authorities can order compliance injunctions with daily penalties, require product/service withdrawal from the market, and publish violation findings publicly.

How Scrutia audits against EAA requirements

Scrutia performs a comprehensive WCAG 2.1 AA audit that covers the web content requirements of EN 301 549. The audit uses a real browser to perform dynamic tests:

• ✓Keyboard navigation — Tab traversal, keyboard traps, visible focus indicators, skip links
• ✓ARIA components — menus, modals, tabs, accordions tested against APG patterns
• ✓Color and contrast — text and non-text contrast ratios per WCAG AA thresholds
• ✓Forms and error handling — labels, required fields, error messages, autocomplete
• ✓Structure and semantics — heading hierarchy, landmarks, document language, page title
• ✓Responsive design — reflow at 320px, zoom to 200%, orientation support

The full report includes HTML/CSS/JS fix code for every issue detected, an executive summary for management, and a prioritization guide — everything you need to achieve EAA compliance.