EAA Checklist 2026
Since 28 June 2025, the European Accessibility Act applies. Who is affected, what must be implemented, what penalties apply for non-compliance?
On 28 June 2025, the European Accessibility Act (EAA) came into effect across the EU. In Germany this is implemented as BFSG, in Austria as the Barrierefreiheitsgesetz. Both oblige providers of certain products and services to ensure digital accessibility – with sanctions for breaches.
Who is affected?
Affected in practice are:
- Online shops (B2C) selling goods or services online
- Booking systems for hotels, restaurants, events, tickets, mobility
- Banking, insurance, utility apps and portals
- E-books, e-readers, app stores
- Passenger transport services
- Telephone services, smartphones, computer hardware
Important: Pure B2B services and pure content sites (visiting-card sites, blogs, associations) are not directly covered by EAA. But: as soon as you enable online purchases or bookings, you fall under the law.
Microenterprise exception
Microenterprises with fewer than 10 employees and annual turnover under € 2M are exempt for services (e.g. online shops). For products (e.g. e-reader hardware) theres no exemption.
What needs to be accessible?
The law refers to harmonised European standard EN 301 549, which builds on WCAG 2.1 Level AA – progressing to WCAG 2.2 since 2024. In practice this means:
1. Perceivability
- Alt text for all meaningful images
- Subtitles for videos, transcripts for audio
- Colour contrast: 4.5:1 minimum body text, 3:1 large text and UI
- Text scalable to 200 % without functional loss
- Information not conveyed by colour alone
2. Operability
- Keyboard operability for every function – no keyboard traps
- Visible focus on active elements
- Sufficient time, no auto-timeouts without extension option
- No epileptic triggers (no more than 3 flashes per second)
- Skip links at the start of each page
3. Understandability
- Declare language:
<html lang="en">mandatory - Consistent navigation across pages
- Clear, specific error messages
- Form labels for every input
4. Robustness
- Valid HTML, clean semantics
- ARIA only where needed; native HTML preferred
- Status messages for live regions (e.g. "added to cart")
Accessibility statement – mandatory document
Every affected website needs an accessibility statement (linked in the footer). Required content: conformity status, list of non-accessible content with reasoning, creation/update date, evaluation method, contact for feedback and conciliation body.
Penalties
- Fines up to € 100,000 per violation (DE) / € 80,000 (AT)
- Sales prohibition order from market surveillance authority
- Cease-and-desist letters from disability associations and consumer protection
- Reputational damage from public proceedings
Practical SMB checklist
- Audit current state with axe DevTools, WAVE, Lighthouse, Pa11y
- Prioritise critical violations (keyboard, contrast, alt text, form labels, error messages)
- Fix technical basics (semantics, lang, skip links, focus styles, form labels)
- Add accessibility helpers (font-size widget, contrast mode, reduced-motion mode)
- Test with screen reader (NVDA, VoiceOver) – at least checkout, contact form, product pages
- Publish accessibility statement, link in footer
- Train your team on alt text, headings, link naming
- Plan annual re-audits
What does compliance cost?
- Small business site: 8–20 hours, ~€ 800–€ 2,000
- Standard WordPress site: 20–60 hours, € 2,000–€ 6,000
- WooCommerce shop: 40–120 hours, € 4,000–€ 12,000
- B2B platform / custom app: 80–400 hours, € 8,000–€ 40,000
Bottom line
EAA isnt a bureaucratic monster but a relatively pragmatic compliance set. Most requirements are simply good web development. Sites built to good standards already meet 70 % of requirements automatically. The remaining 30 % are achievable – but wont happen by themselves.
Edgar Oganisjan is the founder of Skins4You – a web design and online marketing agency from Graz, Austria. More about the team →