The European Accessibility Act, explained for tech teams

The European Accessibility Act (EAA, Directive 2019/882) applies from 28 June 2025. This post breaks down what it requires, who it applies to and what the enforcement landscape looks like across the EU countries that have transposed it into national law. The EAA covers products and services sold to EU consumers, e-commerce platforms, banking apps, e-books, transport booking, streaming. The technical baseline is the harmonised standard EN 301 549, whose current version references WCAG 2.1 levels A and AA (a WCAG 2.2 update is in preparation); Axively tests against WCAG 2.2 AA, beyond it. The service exemption applies only to micro-businesses, fewer than 10 employees AND no more than €2M annual turnover; products covered by the EAA must comply regardless of company size. Penalties vary wildly by country. Hungary tops out at 5% of turnover. Germany's BFSG caps at €100k per violation. Ireland is the only EU country with criminal sanctions, fines up to €60,000 and, in serious cases, up to 18 months in prison. In July 2025, French associations (ApiDV and Droit Pluriel) formally put four major retail chains on notice to meet their accessibility obligations and then took them to court, the first court action against the private sector over digital accessibility in the EU. The enforcement authority is the DGCCRF; penalties in France reach up to €7,500 per breach (€15,000 for a repeat offence). Know where you operate, and price your risk accordingly.