The European Accessibility Act, one year on: what enforcement actually looks like

What year one of enforcement looked like

The EAA is a directive, so enforcement runs through each member state's own market surveillance authorities - and year one confirmed how that works in practice: complaint-driven, uneven across countries, and accelerating. Consumers and disability organizations file complaints; authorities open inquiries; companies get formal requests to demonstrate conformance. Several member states, with Germany, France, Italy and the Nordics among the more active, moved from information campaigns to actual case handling during the year.

Two realities surprised companies most. First, the burden of proof sits with the seller - an authority's letter asks you to show conformance, not the other way around. Second, national transpositions differ in penalties (fines in some states scale into six figures or attach per violation), so identical websites face different downside depending on where the complaint lands.

Who is covered - including outside the EU

The EAA covers the services most digital businesses run: e-commerce, banking and financial services, transport booking, e-books, telecoms and media platforms - for services provided to EU consumers. The seller's location is irrelevant: a US or Israeli company selling to consumers in the EU is in scope.

The main relief valve is the microenterprise exemption for services - under 10 employees and under EUR 2 million turnover - plus a documented "disproportionate burden" claim for specific requirements. Neither is a get-out-of-jail card: the microenterprise test is strict, and a burden claim must be assessed, written down and refreshed, not asserted after a complaint arrives.

The technical bar: EN 301 549, and what changes in October

Conformance is presumed when you meet EN 301 549, the harmonized European standard - which for web content applies the success criteria of WCAG 2.1 Level AA, and in Chapter 10 extends them to documents, PDFs included (see WCAG for PDFs).

The next revision of EN 301 549 is expected to be cited in the EU Official Journal around October 2026, aligning the standard's baseline more closely with newer WCAG work. The practical hedge is the same one we recommend everywhere: build and test to WCAG 2.2 AA - it satisfies the current citation and absorbs the update, instead of scheduling a re-audit around it.

If Europe is part of your revenue: the short list

1. Scope honestly. Which properties serve EU consumers - storefronts, checkout, apps, support flows, statements and invoices as PDFs?
2. Baseline and fix. Automated full-site scanning plus expert audit of the purchase journey; remediate code first, documents in parallel.
3. Prepare the accessibility statement and conformance file. Under the EAA you declare how the service meets the requirements - that document, plus your audit and remediation evidence, is exactly what an authority requests first.
4. Monitor. Complaint-driven enforcement means any visitor is a potential trigger; continuous monitoring keeps the state you declared true.

Keep reading

• ADA Website Compliance: the full guide
• Web Accessibility: the complete guide
• The WCAG library

Last updated 12 August 2026. Reviewed by the EqualWeb accessibility team.