European Accessibility Act 2025 Deadline: Your EAA Compliance Checklist

The June 28, 2025 Deadline Is Now in Effect

The European Accessibility Act — Directive EU 2019/882 — required EU member states to transpose its requirements into national law by June 28, 2022, and set June 28, 2025 as the date by which covered products and services must conform. For US companies, selling into the EU without an accessibility compliance posture is now an active legal risk.

What Products and Services Are Covered by the EAA?

• Consumer computers and operating systems (laptops, desktops, tablets, smartphones)
• Self-service terminals: ATMs, ticketing machines, check-in kiosks, payment terminals
• E-commerce websites and apps selling goods or services to EU consumers
• Electronic communications services and associated consumer equipment
• Audiovisual media services and associated consumer electronics
• Banking and financial services provided to consumers
• E-books and dedicated reading software
• Passenger transport services — ticketing and real-time information systems

Who Is Exempt? Understanding Microenterprise Exclusions

• Fewer than 10 employees AND annual revenue under EUR 2 million = service exemption applies
• Product manufacturers and importers: no microenterprise exemption regardless of size
• Disproportionate burden exception (Article 14): available if compliance costs are excessive relative to benefits, requires documented assessment
• Fundamental alteration exception: if compliance would fundamentally change the nature of the service
• Exemptions must be re-evaluated if business size changes above thresholds

Your Step-by-Step EAA Compliance Action Plan

• Phase 1 (Immediate): Determine which products and services fall within EAA scope
• Phase 1 (Immediate): Confirm whether microenterprise or disproportionate burden exemptions apply
• Phase 1 (Immediate): Run automated WCAG 2.1 AA scans on all EU-facing web properties
• Phase 2 (30 days): Commission a full EN 301 549 gap audit covering web, mobile, and documents
• Phase 2 (30 days): Draft an EU Declaration of Conformity template
• Phase 2 (30 days): Publish an EAA-compliant accessibility statement with a feedback mechanism
• Phase 3 (60-90 days): Remediate critical barriers blocking access to core user journeys
• Phase 3 (60-90 days): Integrate EN 301 549 acceptance criteria into your CI/CD pipeline
• Phase 4 (Ongoing): Conduct annual full conformance audits and update EU Declarations
• Phase 4 (Ongoing): Train product, design, and engineering teams on EN 301 549 requirements