European Accessibility Act compliance checklist

The European Accessibility Act (EAA), Directive (EU) 2019/882, is the first EU-wide law that requires private-sector products and services to be accessible. It applies in EU member states from 28 June 2025. This checklist explains who is in scope, how the technical requirements map to WCAG, and what to actually do — without the fear-based framing competitors lean on.

Law versus standard: EAA and EN 301 549

Keep two things separate. The EAA is the law: it says certain products and services must be accessible. EN 301 549 is the European technical standard: it says how, by pointing at WCAG. Meeting the harmonised standard gives a presumption of conformity with the directive's technical requirements.

Who is in scope

• Products: computers and operating systems, smartphones, TVs with digital services, payment terminals, ATMs, ticketing and check-in machines, e-readers.
• Services: e-commerce, consumer banking, electronic communications, e-books, passenger transport information and ticketing services, and access to audiovisual media services.
• Microenterprises providing services (fewer than 10 staff and under EUR 2 million turnover) are largely exempt; manufacturers and most online shops are not.
• The EAA is separate from the Web Accessibility Directive (2016/2102), which covers public-sector websites and apps. Many organisations fall under both.

The practical checklist

1. Confirm scope: do you sell an in-scope product or service to EU consumers? If yes, the EAA applies regardless of where you are based.
2. Pick your conformance target: WCAG 2.2 AA (covers today's 2.1 requirements and future-proofs for the EN 301 549 update).
3. Run an automated scan to clear deterministic failures: contrast, names/roles/values, form labels, keyboard operability.
4. Do human review for judgement-based criteria: meaningful alt text, reading order, error recovery, authenticated flows.
5. Document conformance: keep technical evidence and, where required, an accessibility statement.
6. Set up monitoring: accessibility regresses with every release — re-scan on a schedule, not once.

National frameworks across the EEA build on the same core

If you operate across borders, you will meet national instruments with their own names, supervisory bodies, and reporting expectations. For the web, they are overwhelmingly WCAG / EN 301 549-shaped: meet WCAG 2.1 / 2.2 AA and you have done the technical heavy lifting. What differs is mostly jurisdiction, scope, and the wording of the accessibility statement.

• Germany — BITV 2.0: federal ordinance for accessible ICT, EN 301 549 / WCAG-aligned.
• France — RGAA: a public-sector referential with an explicit national test catalogue mapped to WCAG success criteria.
• Spain — UNE 139803: the UNE standard expressing ICT accessibility requirements, aligned with international practice.
• Italy — Legge Stanca (Law 4/2004) and AgID: WCAG-level requirements plus national monitoring and self-declaration.
• Ireland — NDA Code of Practice and the Irish statutory instrument transposing the Web Accessibility Directive (same WAD / EN 301 549 family).
• United Kingdom — PSBAR 2018 (the Public Sector Bodies Accessibility Regulations, sometimes written PSBR) plus the Equality Act 2010 duty. The UK is outside the EU/EEA but uses the same WCAG family.

A note for Norwegian organisations

Norway is in the EEA, not the EU. As of mid-2026 the EAA has not been incorporated into the EEA Agreement and is not yet Norwegian law — its national implementation is delayed. Norwegian businesses that only operate domestically continue to follow the existing ICT regulation (WCAG 2.1, the 48/35 split). But Norwegian businesses selling products or services into the EU must already comply with the EAA in those markets from 28 June 2025. See the dedicated Norwegian guide for the accessibility-statement workflow.