On June 28, 2025, the European Accessibility Act (EAA) became enforceable across all 27 EU member states. For the first time, a single set of accessibility requirements applies to a wide range of consumer products and digital services sold anywhere in the European Union — and the rules apply whether your business is based in Berlin, Boston, or Bangalore.
If you sell to EU consumers and your website, app, or ecommerce store does not meet the EAA's accessibility requirements — including providing alt text for every meaningful image — you are now exposed to fines, injunctions, and removal from EU markets. This guide explains who is covered, what is required, what enforcement looks like, and how to get compliant.
Summary
The European Accessibility Act (Directive (EU) 2019/882) is a binding EU law requiring digital products and services sold to EU consumers to meet harmonized accessibility requirements. It became enforceable on June 28, 2025. The Act covers ecommerce websites, mobile apps, e-readers, ATMs, banking services, and more. Compliance is measured against EN 301 549, which incorporates WCAG 2.1 Level AA. Missing alt text is the most commonly cited WCAG failure on the web. Penalties vary by member state — for example, Germany's BFSG allows fines of up to €100,000 per violation — and regulators can also order products withdrawn from the market and require services to be remediated. Non-EU businesses are covered if they place products or services on the EU market.
What is the European Accessibility Act?
The European Accessibility Act is Directive (EU) 2019/882, adopted by the European Parliament and Council in 2019. It is the EU's first comprehensive, market-wide accessibility law covering both physical products and digital services. Rather than leaving accessibility rules to each member state — which had created a fragmented and inconsistent compliance landscape — the EAA harmonizes requirements so a product or service that is accessible in one EU country is accessible in all of them.
Member states had until June 28, 2022 to transpose the directive into national law, and businesses had until June 28, 2025 to come into compliance (European Commission). Each country has now passed its own implementing legislation — for example, Germany's Barrierefreiheitsstärkungsgesetz (BFSG), Italy's Decreto Legislativo 82/2022, Spain's Ley 11/2023, and Ireland's European Union (Accessibility Requirements of Products and Services) Regulations 2023 (S.I. 636/2023) — but the underlying requirements all map back to the EAA.
The EAA is built around a simple premise: roughly 87 million people in the EU live with a disability (European Commission), and they should not be excluded from the goods and services available to everyone else.
Who must comply (including non-EU businesses)
The EAA applies to any economic operator — manufacturer, importer, distributor, or service provider — that places a covered product or service on the EU market. Critically, this is based on where you sell, not where you are based. A US ecommerce store that ships to customers in France is covered. A Canadian SaaS company with EU customers is covered. A UK bank serving EU residents is covered.
The "place on the market" rule
The EAA uses the EU's standard product-regulation language: if your product or service is made available to EU consumers in the course of commercial activity, it is considered "placed on the market" in the EU — regardless of your business's location. Targeting EU customers (EU language options, EUR pricing, shipping to EU addresses) is strong evidence that you are placing your service on the EU market.
Microenterprise exemption (services only)
There is a narrow exemption for microenterprises providing services — businesses with fewer than 10 employees and an annual turnover or balance sheet under €2 million. They are exempt from the service requirements but still encouraged to comply. The exemption does not apply to products: even a one-person company manufacturing a covered product must comply.
What products and services are covered
The EAA covers a defined list of products and services the EU determined to be most important for the daily lives of consumers with disabilities.
Products
- Consumer general-purpose computer hardware and operating systems
- Self-service terminals — payment terminals, ATMs, ticketing machines, check-in machines, interactive information kiosks
- Consumer terminal equipment used for electronic communications (smartphones, telephones)
- Consumer terminal equipment used for accessing audiovisual media services (smart TV equipment, set-top boxes)
- E-readers
Services
- Ecommerce — any website or app selling goods or services
- Banking services for consumers
- Electronic communications (phone, messaging)
- Audiovisual media services and access to them
- E-books and dedicated software
- Passenger transport services — websites, apps, ticketing, and information
Why ecommerce is the biggest impact area
The EAA's definition of "ecommerce services" is broad — it covers any commercial website or app where a consumer can conclude a contract with a business from a distance. That captures the vast majority of online stores, booking platforms, and subscription services. If you sell anything to consumers in the EU, your website is in scope.
Key accessibility requirements
The EAA sets out functional accessibility requirements in Annex I of the directive. For digital services like ecommerce websites and mobile apps, the core obligations include:
- Perceivable content — information and user interface components must be presentable in ways users can perceive, including text alternatives for non-text content (the alt text requirement), captions for video, and sufficient color contrast.
- Operable interface — all functionality must be available from a keyboard, users must have enough time to read and use content, and content must not cause seizures.
- Understandable information — text must be readable, content must appear and operate predictably, and users must be helped to avoid and correct mistakes.
- Robust compatibility — content must be reliably interpreted by assistive technologies including screen readers.
- Accessibility statement — service providers must publish information explaining how their service meets the EAA's requirements.
These functional requirements map directly onto WCAG — the technical standard the EU uses to measure compliance — which we cover in the next section.
Selling to EU customers?
Run a free audit on any page of your site to see which images are missing alt text — the most commonly cited EAA violation and the easiest to fix.
Audit your site's alt textEN 301 549 and WCAG 2.1 AA
The EAA itself does not name a specific technical standard. Instead, it relies on harmonised European standards — and for ICT accessibility, that standard is EN 301 549. Conformance with EN 301 549 creates a presumption of conformity with the EAA. In other words: meet EN 301 549, and you are assumed compliant with the law until proven otherwise.
EN 301 549 incorporates the Web Content Accessibility Guidelines (WCAG) — for the current revision applicable to the EAA, that is WCAG 2.1 Level AA. The newer WCAG 2.2 is fully backwards compatible, so meeting WCAG 2.2 AA also satisfies the EAA. WCAG covers everything from text alternatives for images to keyboard navigation, color contrast, form labels, and time limits.
Why alt text shows up first
The very first WCAG success criterion — 1.1.1 (Non-text Content), at Level A — requires text alternatives for all non-text content. That makes missing alt text both the most basic and the most commonly cited accessibility failure. The WebAIM Million study consistently finds missing alt text on over one-third of all images across the top one million websites — the same picture in the EU as in the US. Under the EAA, those omissions now carry direct legal weight in every EU country.
Penalties and enforcement
Article 30 of the EAA leaves penalty levels and enforcement procedures to each member state, requiring only that penalties be "effective, proportionate and dissuasive." The result is a meaningfully different set of consequences depending on where your customers are located.
Two illustrative examples of the range:
- Germany — Under §37 of the Barrierefreiheitsstärkungsgesetz (BFSG), individual violations can be fined up to €100,000.
- Italy — Under Decreto Legislativo 82/2022, sanctions for non-compliant services are tied to a percentage of the turnover from the non-compliant service.
Other member states have set their own thresholds — some with fixed maximum fines, others with turnover-based sanctions. Before launching or continuing service in a specific EU country, check that country's national implementing act for its exact penalty rules.
Beyond monetary fines, market surveillance authorities across the EU have a common toolkit under the directive: they can order non-compliant products to be withdrawn from the market, prohibit further sales, and require remediation of services within a fixed deadline. Consumer associations and individual users can also bring complaints under each member state's procedures, which trigger investigations.
EAA vs ADA: how they compare
US businesses are familiar with the ADA accessibility lawsuit landscape. The EAA covers similar ground but works very differently in practice.
| EAA (EU) | ADA Title III (US) | |
|---|---|---|
| Standard cited | EN 301 549 (incorporates WCAG 2.1 AA) | WCAG 2.1 AA (de facto, via court rulings and DOJ guidance) |
| Who enforces | National market surveillance authorities + courts | Private plaintiffs (most common) + DOJ |
| Typical first contact | Warning letter + remediation deadline | Demand letter or filed lawsuit |
| Penalty type | Administrative fines + product withdrawal | Settlement payments + attorney's fees |
| Reach | Anyone selling to EU consumers | Anyone operating in the US |
| Microenterprise relief | Yes, for services (under 10 employees) | No formal exemption |
The good news: because both frameworks lean on WCAG 2.1 AA, a single accessibility program — proper alt text, keyboard navigation, color contrast, form labels — gets you most of the way to compliance with both at once.
How to comply — a practical roadmap
EAA compliance is achievable, even for small teams. The most efficient path is to focus on the highest-impact, most-cited issues first.
1. Determine your exposure
Confirm whether you place a covered product or service on the EU market. If you ship to EU customers, accept EUR payments, offer EU language versions, or have an EU presence in your marketing, assume you are in scope.
2. Run an accessibility audit
Scan your most important pages — home, product listings, checkout, account, and contact — with automated tools like WAVE, Lighthouse, or our free alt text audit. Automated scans catch only a portion of WCAG issues — for full coverage, supplement with manual testing using a screen reader.
3. Fix alt text first
Missing alt text is the most-cited WCAG failure and the easiest to fix systematically. Every informative image needs descriptive alt text; decorative images need alt="". See our complete guide to alt text for the rules.
4. Address the rest of the WCAG basics
After alt text, work through color contrast (WCAG 1.4.3), form labels (1.3.1), keyboard operability (2.1.1), focus visibility (2.4.7), and document language (3.1.1). These five issues account for the bulk of detectable WCAG failures across the web.
5. Publish an accessibility statement
The EAA explicitly requires service providers to publish a statement explaining how their service meets the accessibility requirements, what exceptions apply, and how users can report barriers. Most member states provide template language.
6. Build accessibility into your workflow
One-time fixes do not stay fixed. Make alt text a required field at upload time, add an automated accessibility check to your CI pipeline, and review new pages before publishing.
Multilingual alt text at scale
Selling into the EU means selling in many languages. The EU has 24 official languages, and accessibility statements and screen-reader output are expected to match the language of the page. For a store with thousands of product images localized into French, German, Spanish, Italian, Polish, and Dutch, that is a tremendous amount of text to produce by hand.
AI-generated alt text is the only realistic way to ship accessible content at this scale across this many markets. Modern vision models can describe an image and translate the description in seconds — keeping pace with product launches, seasonal updates, and content velocity that manual writing simply cannot match.
Generate descriptive alt text in 194 languages
Alt Text Studio uses leading AI vision models to generate descriptive alt text in any of 194 languages, including all 24 official EU languages. Add product context and SEO keywords, and export in CSV, JSON, HTML, or plain text.
Frequently asked questions
Does the EAA apply to my US-based business?
Yes, if you place a covered product or service on the EU market — for example, by selling to EU consumers through your website, shipping to EU addresses, or providing a digital service to EU users. Your business location is irrelevant; the location of your customers is what matters.
When did the EAA become enforceable?
June 28, 2025. Member states had to transpose the directive into national law by June 28, 2022, and businesses had a three-year window to come into compliance.
What standard do I have to meet?
Compliance is measured against EN 301 549, the harmonised European standard for ICT accessibility. EN 301 549 incorporates WCAG 2.1 Level AA. Meeting WCAG 2.1 AA — or the newer WCAG 2.2 AA — gives you a presumption of conformity with the EAA.
What are the penalties for non-compliance?
Penalties vary by member state — Article 30 of the directive only requires that they be "effective, proportionate and dissuasive." Germany's BFSG sets a maximum fine of €100,000 per violation. Italy's transposition ties sanctions to a percentage of turnover from the non-compliant service. Beyond fines, regulators can order products withdrawn from the market and require services to be remediated within a fixed deadline. Check the implementing act of each country you serve for its specific rules.
Are small businesses exempt?
Microenterprises providing services — fewer than 10 employees and under €2 million in turnover or balance sheet — are exempt from the EAA's service obligations. The exemption does not apply to products. Even tiny manufacturers must comply if they place a covered product on the EU market.
Does my accessibility statement need to be in every EU language?
The EAA requires that information about accessibility be available in the language of the country where the service is offered. In practice, that means publishing your accessibility statement in each language version of your site.
If I am already ADA compliant, am I EAA compliant?
Mostly. Both frameworks use WCAG 2.1 AA as the technical baseline, so the same accessible website satisfies the bulk of the requirements under both. The EAA adds a few EU-specific obligations — most notably, publishing an accessibility statement in the local language and meeting product-specific requirements where applicable.
Get ahead of EU enforcement
The EAA is now in force, the penalty frameworks are in place, and complaints are starting to flow through national market surveillance authorities. For any business selling into the EU, accessibility is no longer a "nice to have" — it is a market access requirement.
The fastest, highest-leverage starting point is fixing alt text across your image library. It is the most-cited WCAG failure, the easiest to verify, and the one that has the biggest immediate impact on screen-reader users across the EU's 24 languages.