Accessibility & the EAA

Accessibility refers to how people with disabilities can “access” the world around them. The European Accessibility Act (EAA) aims to improve digital access for people with disabilities in Europe & Ireland.

To enforce this, the EAA will require accessibility standards to be in place for digital products from 28th June 2025. If firms do not meet those standards, then significant legal penalties can apply.

Digital products include: 

• Websites 
• Mobile Apps
• Communication devices 
• E-readers
• Financial ATM’s
• Point-of-sale devices & self-service shop checkouts
• Information kiosks / boards
• Electronic ticketing & check-in terminals

The goal of the EAA is to promote equal access to digital products for the 27% of people in the EU — equating to over 87 million people as of Oct. 2024 — living with some form of disability. 

Why the EAA matters

To illustrate why the EAA matters, consider the following two scenarios:

1. If a person has a serious vision impairment, how would they use an electronic ticket machine? 
2. How would a person shop online without the necessary hand mobility required to use a computer mouse?

In a nutshell, the EAA can provide effective solutions to people with disabilities trying to access what many of us take for granted. In fact, the National Disability Authority of Ireland states that there are over 640,000 people with disabilities in Ireland alone.

With that in mind, the EAA is also an opportunity for businesses to grow their markets & improve sales with an audience that is largely underrepresented in the digital space.

What is affected by the EAA

Firms with 10 or more employees, operating in the following sectors* of the European market are required to be compliant in 2025.

• E-commerce
• Banking
• Telecoms
• Transport (air, bus, rail & waterborne passenger transport services)
• Technology products (computers, mobile phones, e-readers, ticketing & check-in machines, point-of-sale devices, ATM’s, information kiosks)

*Sectors mentioned also include firms that are not based in Europe, but who have dealings with Europe (e.g. air transport firms that are registered outside of the EU, but who fly into the EU). 

What is exempt from the EAA

The EAA does not apply to the following:

• Firms with less than 10 employees & with annual turnover not exceeding 2 million Euro

The EAA also does not apply to the following content of websites & mobile applications:

• Pre-recorded time-based media published before 28th June 2025
• Office file formats (e.g. PDF documents) published before 28th June 2025
• Online maps & services, if essential information is provided in an accessible digital manner for maps intended for navigational use
• Third party content that is neither funded by, developed by, or under the control of the economic operator concerned
• Content of Websites & Mobile Apps qualifying as archives, meaning that they only contain content that is not updated or edited after 28th June 2025

Penalties for non-compliance with the EAA

While the EAA itself is the same across Europe, the penalties for non-compliance are decided and enforced by each individual EU member state.

Penalties are also to be accompanied by effective remedial action where non-compliance is established. If no remedial actions are implemented, then the ability to trade might be questioned.

In Ireland, firms who are subject to the EAA & are not digitally accessible after 28th June 2025, risk the following penalties for non-compliance: 

• On summary conviction, a class A fine of €5,000 and/or imprisonment up to 6 months
• On indictment, fines up to €60,000 and/or imprisonment up to 18 months (applicable to Directors, Managers, Secretaries and other Officers).

Assigned compliance authorities are empowered to direct businesses to comply with requirements. The EAA Regulations appear to also allow for private individuals, with the option to be supported by interest groups, to enact court proceedings directly.

Other important laws within Ireland, such as the Disability Act (2005) & the Equal Status Acts (2000-2018), potentially may also have a bearing on litigation relating to digital accessibility.

The UK is not directly affected by the EAA, however UK based firms offering products or services into the EU, will need to comply with the regulations. The same applies to firms based in the United States offering products or services into the EU.

Standards used to determine EAA compliance

In general, digital products are checked for accessibility using the European Standard referred to as EN 301 549 “Accessibility requirements for ICT products and services”.

Websites & Mobile Apps are further checked for accessibility using Web Content Accessibility Guidelines (WCAG) 2.2 AA criteria. This is the global standard used to determine if website / mobile app content is accessible or not.

Firms must also publish a formal Accessibility Statement indicating how they meet the Act’s requirements at the time of publication.

Unsure if your digital content is compliant?

Implementing digital accessibility is more of a marathon than a quick fix, so it’s better to evaluate your current status as soon as possible with remediation prior to 28th June 2025.

There are a number of options to help determine compliance with the upcoming EAA Regulations. If you’re unsure where to start, we can help you plan your next steps starting with a thorough web accessibility audit.

For expert advice & compliance evaluation, contact us today.

Note: this article is provided for information purposes only & does not constitute legal advice.

About the Author

This article was written by our trusted Accessibility Partner, Brian Matthews. Brian is a Web Accessibility Consultant based in the Rep. of Ireland. He has an I.T. background, but his real passion is trying to improve digital access to websites & apps for people with disabilities. Plus, digital accessibility is also good for helping businesses to grow. Apart from being a self-confessed nerd, Brian has also be known to ponder if geeks have it better.

by :

Eamonn O'Raghallaigh, PhD