Audit checklist
- Confirm whether the service is in an EAA-covered sector.
- Check micro-enterprise and product/service distinctions carefully.
- Run WCAG 2.2 AA testing on public conversion flows.
- Map exposure by target EU country and enforcement authority.
- Create a remediation plan for blockers, templates and content gaps.
- Publish an accessibility statement in the relevant language.
EAA scope is sector-based
The EAA does not make every website illegal overnight. It covers defined categories such as e-commerce, consumer banking, e-books, electronic communications, audiovisual media, passenger transport and self-service terminals. A purely informational website may be outside the core scope; an online shop or digital service flow is much more likely to be covered.
National implementation matters. Each EU country transposes the directive into local law, names its own authorities and sets its own enforcement model. That is why country-specific landing pages and statements are useful.
What regulators and claimants look for
Accessibility enforcement usually starts with a practical failure: a user cannot buy, register, read, pay or contact support. Audit evidence should therefore focus on user journeys, not only isolated pages. Checkout, account creation, search, navigation and customer-service pages deserve special attention.
- Can a keyboard-only user complete the key task?
- Are forms, validation errors and payment steps announced correctly?
- Is the accessibility statement accurate and easy to find?
- Are repeated component defects being fixed systematically?
Accessibility statements are part of the process
A statement should not be marketing fluff. It should describe the standard used, known limitations, how the assessment was prepared, feedback contacts and the review date. Updating it after remediation shows a living process, which is more credible than a static claim of perfect compliance.
FAQ
Does the EAA apply outside the EU?
If you offer covered products or services to EU consumers, the EAA can matter even if your company is headquartered elsewhere. Scope depends on the service and target market.
Are micro-enterprises exempt?
There is a micro-enterprise exemption for certain service providers, generally fewer than 10 employees and no more than €2m turnover/balance sheet. Product obligations are different, so do not apply the exemption blindly.
What should an EAA audit deliver?
A useful audit delivers technical findings, risk priorities, remediation guidance, country context, and statement-ready documentation. It should not pretend that automation alone guarantees legal compliance.