The European Accessibility Act has applied across the EU since 28 June 2025. Most teams know it exists. Fewer know whether it applies to them, and fewer still know what “compliant” looks like in practice.
This checklist covers both. First, who is in scope. Then, the steps to get there and stay there.
Who needs to be compliant?
The EAA is about consumers. It covers specific products and services sold to people in the EU, and it treats them the same in all 27 member states.
The quick test
☐ Do you sell to consumers in the EU?
☐ Does your product or service fall into one of the categories below?
☐ Do you have 10 or more employees, or more than €2 million in annual turnover or balance sheet?
If you ticked all three, you are in scope.
What’s covered
On the digital side, the act covers:
E-commerce services, from product pages to checkout
Consumer banking and payment services
E-books and e-reading software
Electronic communication services
Services that give access to audiovisual media
Ticketing, timetables and booking for passenger transport
It also covers hardware: computers, operating systems, smartphones, tablets, e-readers, ATMs, ticket machines and check-in kiosks.
In practice, if a consumer touches it through a screen, assume it’s in scope until you’ve checked otherwise.
Based outside the EU?
Where your company is registered doesn’t matter. What counts is where your product is sold. A SaaS company in Montréal, Austin or London selling a covered service to EU consumers must comply in the same way as a company in the European Union.
What about B2B SaaS?
Purely B2B offers sit outside the act’s direct scope. That doesn’t mean you can ignore it. There are three ways B2B teams end up affected:
Your customers are in scope. If your platform powers a bank, a web shop or a ticketing flow, your customer carries the legal duty. They will pass it to you through contracts and security reviews.
Public sector buyers require it. Procurement across Europe already writes EN 301 549 into tenders. No conformance, no shortlist.
National rules vary. Some countries expect you to state clearly that an offer is business-only. Check the rules in each market you sell to.
For many B2B teams, the first question about accessibility now comes from a buyer, not a regulator.
Exemptions and transition periods
Micro-enterprises providing services are exempt. That means fewer than 10 employees and no more than €2 million in annual turnover or balance sheet. Micro-enterprises selling covered products still have to comply, with lighter paperwork.
Services can keep using products they already used before 28 June 2025 until 28 June 2030.
Contracts agreed before the deadline can run unchanged until they expire, up to five years.
If compliance would fundamentally change your product, or would put a disproportionate burden on your business, you can claim an exception. You have to document the assessment and be ready to show it.
What happens if you don’t comply
Each member state sets its own penalties and runs its own market surveillance authority. The risks are:
Fines, set nationally
Products or services pulled from the market
Legal action from individuals or organisations
Lost deals, because buyers move on to vendors who can show evidence
How to become compliant
1. Map your products against the scope
List every product, flow and channel a consumer can reach. Mark what’s in scope, what’s exempt and why. Write the reasoning down. If you rely on an exemption, this document is your evidence.
2. Audit manually against the standard
The technical standard behind the EAA is EN 301 549, which is built on WCAG. Test against WCAG 2.2 AA. It covers everything in WCAG 2.1 AA, the version EN 301 549 currently points to, plus newer criteria.
Automated scanners catch roughly 30% of issues. The rest shows up only when a person tests your real flows with a keyboard and screen readers like NVDA and VoiceOver.
3. Prioritise by impact
Not every issue carries the same weight. Start with what blocks a user from finishing a task, like a form they can’t submit or a checkout they can’t reach. Cosmetic issues come later.
4. Fix at the component level
This is where most teams stall. Audits are easy to buy. Implementation is where products get stuck.
Fix the button, the input and the modal once, in your codebase, and the fix applies everywhere they’re used. Patching screen by screen means the same issue comes back with every new feature.
5. Don’t forget support
The EAA covers how customers get help, not just the product itself. Help centres, chat, contact forms and documentation all need to work with assistive technology. This is often the fastest win.
6. Publish accessibility information
Covered services must explain how they meet the requirements, in plain language, somewhere customers can find it. Keep it accurate and keep it current.
7. Re-test and validate
Re-test every fix. A backlog marked “done” isn’t evidence. A re-tested result is what you can show a buyer, a procurement team or a regulator.
8. Build it into how you ship
Compliance isn’t a one-off project. Put focus states, contrast and semantics inside your design system, so every new screen starts accessible. Add checks to your release process and test with real users with disabilities.
9. Make someone responsible
Leadership needs to understand both the legal risk and the commercial upside. One owner, clear timelines and a roadmap beat a shared good intention.
Why it’s worth doing properly
The World Health Organization estimates that more than 135 million people in Europe live with a disability. Accessible products reach more customers, hold up better in procurement and are easier for everyone to use.
The teams that treat the EAA as a design quality problem, instead of a legal one, are the teams that come out ahead. A few examples:
In a 2023 data snapshot, Forrester found that accessibility commitments aren’t purely about compliance. The top three drivers are winning new customers, creating better experiences for all customers, and attracting and retaining talent.
W3C Web Accessibility Initiative (WAI)
WAI's Business Case for Digital Accessibility describes how accessibility can drive innovation, enhance your brand, extend market reach and minimize legal risk.
Get help with your audit
EDL runs manual WCAG 2.2 AA audits for B2B SaaS teams selling into the EU. You get a prioritised, developer-ready backlog in three weeks, mapped to your components. Then we fix the issues in your codebase, at the component level, and re-test. Validation is included.
Audits start from €8,000, at a fixed price and scope.
See our accessibility services and book a free discovery call: edl.dk/accessibility-audit
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Jeanne Lacelle
Marketing & Communications
Jeanne makes sure the right people know what we do. She leads marketing and communications with a clear instinct for what deserves attention and how to give it the recognition it deserves.
