EAA Compliance Guide — What the Law Requires in 2025

The legal framework for digital accessibility in Europe

The obligation for digital accessibility in Europe is built on several legislative texts. The foundational regulation is the European Accessibility Act (Directive 2019/882), adopted in April 2019 and enforceable since June 28, 2025. This directive harmonizes accessibility requirements across all EU member states, covering digital products and services sold in the European market.

The EAA has radically changed the regulatory landscape by extending accessibility obligations to the private sector. This multiplied tenfold the number of businesses that must comply. Each member state has transposed the directive into national law, with enforcement beginning in June 2025.

Who must comply?

The EAA compliance obligations now cover a very broad range of actors. Public services have been required to comply since the earlier Web Accessibility Directive (2016/2102). For private businesses, the EAA applies to companies with more than 10 employees or turnover exceeding €2 million that sell products or services online in the EU.

This covers e-commerce sites, online banking services, transport platforms, telecommunications services, and more broadly any digital service sold or provided in the European Union. Micro-enterprises (fewer than 10 employees and less than €2 million turnover) are exempt, unless they provide public services.

Large companies (over 250 employees) have additional obligations: they must publish a multi-year accessibility plan, an accessibility statement on each site, and an annual action plan.

WCAG vs EAA: what are the differences?

WCAG (Web Content Accessibility Guidelines) are the international recommendations published by the W3C. They define four principles — Perceivable, Operable, Understandable, Robust — and three conformance levels (A, AA, AAA). Most legislation worldwide requires Level AA. The EAA is the European directive that creates the legal obligation to comply.

In practice, meeting WCAG 2.1 Level AA is the way to satisfy EAA technical requirements. The European standard EN 301 549 references WCAG 2.1 as its technical foundation. In France, the RGAA framework operationalizes these same WCAG criteria into 106 testable requirements.

Penalties for non-compliance

Penalties vary by member state and actor type. In France, enforcement is handled by the DGCCRF (competition and consumer protection authority). Fines can reach €50,000 per violation detected, doubled for repeat offenses. Compliance injunctions with daily penalties and product/service withdrawal from the market are also possible. Active enforcement has been underway since June 2025 across the EU.

Steps to achieve compliance

Compliance is a structured process in several steps. The first step is to audit your site to know your current compliance rate. This is exactly what Scrutia offers: an automated audit of WCAG 2.1 AA criteria in 5 minutes, validated against 9 official audits.

The second step is to fix the identified issues. Scrutia's full report provides ready-to-paste HTML/CSS/JS fix code for each issue. Prioritize fixes by severity: start with blocking issues (keyboard navigation, focus traps), then major issues (images without alternatives, forms without labels), then minor ones.

The third step is to publish an accessibility statement on your site, mentioning your compliance rate, non-accessible content, and measures taken. This statement is mandatory for all covered actors under the EAA.