FAQ for European Accessibility Act (EAA) enforced on 28th June 2025 and WCAG 2.1 Level AA

European Accessibility Act
  1. What is European Accessibility Act (EAA)?
    The European Accessibility Act (EAA) is a landmark EU directive (Directive (EU) 2019/882) aimed at harmonizing accessibility requirements for a range of products and services across the European Union. It enters into force for businesses on 28 June 2025, with enforcement by national authorities in each EU member state.

    Please note that many national laws already mandate WCAG 2.1 AA as the baseline standard for digital accessibility (e.g., Germany’s BITV, France’s RGAA, Italy’s Stanca Act)

    Learn more on European Accessibility Act

  2. What is WCAG 2.1 AA and how is it different to EAA?
    WCAG stands for Web Content Accessibility Guidelines and is a global standard published by the W3C (World Wide Web Consortium) for making web content more accessible to people with disabilities.

    WCAG 2.1 Levels:
    – A: Minimum compliance
    – AA: Industry-standard level (most legal frameworks, including the EAA, require this)
    – AAA: Very high accessibility (not commonly required)

    WCAG 2.1 AA Covers:
    – Perceivable: Can users see/hear the content? (e.g., alt text for images, captions for videos)
    – Operable: Can users interact with it using keyboard, mouse, voice, etc.?
    – Understandable: Is content clear and consistent?
    – Robust: Can it be reliably interpreted by assistive technologies (screen readers, etc.)?

    WCAG 2.1 AA is
    – Technical standard for how to make content accessible
    – Developed by W3C (independent standard)
    – Focuses on web/mobile content
    – Compliance with WCAG 2.1 AA is the main way to prove digital accessibility under the EAA
    – No legal force by itself

    where as EAA is
    – Legal requirement for which services/products must be accessible
    – Enforced by EU law (Directive 2019/882)
    – Covers web, mobile, physical terminals, services, customer support
    – Refers to WCAG 2.1 AA as a baseline for digital accessibility
    – Legally binding by member states

    Refer to the official WCAG 2.1 recommendations.

  3. Will compliance to WCAG 2.1 AA meet EAA?
    Partly yes, compliance with WCAG 2.1 Level AA will substantially meet the technical accessibility requirements of the European Accessibility Act (EAA) for websites, mobile apps, and digital services.

    EAA is principle-based, not technology-prescriptive. It outlines functional performance criteria like perceivability, operability, understandability, and robustness, all of which WCAG 2.1 AA covers.

    The European Commission and national accessibility bodies consistently reference WCAG 2.1 AA as the baseline standard for digital accessibility.

    Many national laws already mandate WCAG 2.1 AA (e.g., Germany’s BITV, France’s RGAA, Italy’s Stanca Act), and the EAA aims to harmonize these across the EU.

    WCAG 2.1 AA addresses (these align well with EAA’s “essential requirements”.):

    – Color contrast
    – Keyboard navigation
    – Screen reader compatibility
    – Responsive/mobile accessibility
    – Focus management
    – Captions and transcripts

    But EAA goes beyond just websites and apps as it includes services and user support (e.g., accessible help desks, documentation, kiosks).

    So, WCAG 2.1 AA is a critical foundation, but not the whole picture for compliance.

    – WCAG 2.1 AA covers Websites, and Mobile apps for EAA.
    – WCAG 2.1 AA partly covers PDFs and documents for EAA.
    – WCAG 2.1 AA does not cover Support channels, ATMs, kiosks, devices and accessibility statements for EAA.

  4. Are there any Exceptions?
    Micro-enterprises (fewer than 10 employees and annual turnover/balance sheet ≤ €2 million) are exempt entirely from EAA obligations — unless required by national law or clients.
    However, they still must not discriminate against disabled users under the Equal Treatment Directive.

  5. Is there any grace period?
    According to Article 32 of the EAA Directive (2019/882):
    “Products and services first placed on the market before 28 June 2025 may continue to be made available without modification until 28 June 2030.

    This creates a 5-year transitional period, but only under specific conditions”. However modifications made after June 2025 must comply immediately with EAA if changed and new new products or services after June 2025 must be fully EAA-compliant from day one.

    Caution on “Modifications”, If you update or modify a digital product/service after June 2025, it will lose the grace period status and must immediately comply with accessibility requirements.

    Examples:
    Hosting an old product without updates may qualify for grace period

    However the following 2 examples must comply with EAA and do not get grace period
    – Updating your website UX in July 2025
    – Adding new payment methods to an old e-shop in July 2025

  6. Conclusion
    Ensuring conformance to WCAG 2.1 AA across all your platforms will cover most EAA requirements. Just remember to additionally address:
    – Accessible client support
    – Document/PDF accessibility
    – Public accessibility statement

Note this is a general document for reference and we ask you to refer to your legal department for the correct scope and coverage of the law.