The EAA has been enforceable across the EU for a year — and the first lawsuits and regulator inspections have landed. If your site takes orders from EU customers, this law reaches you too, no matter where you're based. Here's what changed and what to do.
The European Accessibility Act has now been enforceable for a full year. When the deadline passed on 28 June 2025, a lot of US businesses filed it under "European problem" and moved on. That was a mistake — and the first year of enforcement is starting to prove it.
The EAA doesn't care where your company is headquartered. It cares whether people in the EU can use your digital service. If your website takes an order from a customer in Paris, Berlin, or Madrid, you're inside its scope. Here's what the law actually requires, what enforcement has looked like in year one, and why — for most US teams already working toward ADA compliance — the gap is smaller than it sounds.
What the EAA actually is
The European Accessibility Act (Directive (EU) 2019/882) is an EU-wide law requiring a broad set of consumer products and services to be accessible to people with disabilities. It covers e-commerce, banking, telecommunications, transport ticketing, e-books, and hardware with digital interfaces such as ATMs and payment terminals.
Unlike a regulation that applies uniformly, the EAA is a directive: each of the 27 member states wrote it into its own national law, and each runs its own enforcement. Enforcement began on 28 June 2025 for new products and services. Services already on the market before that date have until 28 June 2030 to comply.
For web content, the practical standard is WCAG 2.1 Level AA, incorporated through the harmonized European standard EN 301 549. That's the key detail for US readers: WCAG 2.1 AA is the same web baseline US courts apply in ADA Title III cases and the same standard the DOJ's Title II rule names. A site built to that standard is doing the core work for both legal systems at once.
Why this reaches US businesses
This is the part most American companies miss. The EAA applies to any business placing covered products or services on the EU market, regardless of where that business is based. A US company with an e-commerce site that accepts orders from any EU member state falls under its jurisdiction.
The liability can also attach at multiple points in the supply chain — manufacturers, importers, distributors, and service providers can all be covered. And the obligation isn't limited to consumer sales: the EAA reaches some business-to-business contexts too, where digital services are provided to other businesses.
There's a narrow microenterprise carve-out — businesses with fewer than 10 employees and under €2 million in annual turnover may be exempt from the service requirements. But it's limited, it doesn't cover product requirements, and the exemption that EU member states grant their own smallest firms does not extend to non-EU businesses serving the EU market. In other words: don't assume it covers you, and don't rely on it without legal advice.
When does it not apply? Broadly, if you only serve US customers with no EU presence, if your site doesn't ship to or offer services in the EU, or if you genuinely fall under the microenterprise threshold. If your checkout accepts EU addresses, though, you should assume you're in scope.
Year one: enforcement is real, if uneven
For the first few months, enforcement was quiet enough that some businesses wondered whether it would happen at all. The answer, a year in, is clearly yes — it's just arriving the way major EU regulation usually does: procedural, country-by-country, and easy to underestimate.
A few concrete markers from the first year:
- In France, disability organizations issued formal legal notices to four major grocery retailers in mid-2025. When the responses fell short, they filed emergency injunctions in the French Commercial Court in November 2025 — the first EAA-related lawsuits in Europe.
- Sweden's Post and Telecom Authority began inspecting devices and opened its first regulatory cases focused specifically on e-commerce, with that review continuing into 2026.
- Authorities in the Netherlands and Germany have confirmed enforcement activity is underway and signaled plans to expand auditing through 2026.
The pattern is that enforcement won't be evenly paced across all 27 states — it depends on each national authority's readiness and priorities. But the direction is one-way. The quiet phase is ending, not continuing.
Penalties are set by each member state and vary widely — broadly in the range of roughly €5,000 to €500,000 depending on the country and the severity of the violation, with some countries adding daily fines for ongoing non-compliance and the power to order a service withdrawn from the market. A few jurisdictions allow criminal penalties. The financial exposure is real, but the market-access risk — being ordered to stop serving EU customers — is often the bigger threat for a growing business.
What the EAA shares with US law — and where it goes further
For a US team, the encouraging news is the overlap. EN 301 549 incorporates the full text of WCAG 2.1 Level AA for web content. So a website built and verified to WCAG 2.1 AA — the work you'd already be doing for ADA and Section 508 — satisfies the core web requirements of the EAA at the same time.
Where the EAA goes further is beyond the web page itself. EN 301 549 adds requirements for mobile apps, non-web software, documents, and hardware interfaces that go past what WCAG alone covers. If your service includes a mobile app, PDF documents, or self-service hardware, those need their own attention. And one point worth noting for anyone tempted by a shortcut: the European Commission does not accept overlay widgets as a path to EN 301 549 conformance — the same conclusion US regulators and courts have reached.
It's also worth knowing the standard is moving. EN 301 549 is being updated to incorporate WCAG 2.2; the current operative version still references WCAG 2.1 AA, but teams building now should aim at 2.2 to stay ahead of the update.
What to do now
If you sell to EU customers, treat the EAA the same way a serious US business already treats the ADA — as an ongoing obligation, not a one-time checkbox.
- Confirm your scope. Does your site accept EU orders, ship to the EU, or offer services to EU consumers? If yes, assume you're covered and don't lean on the microenterprise exemption without legal advice.
- Audit against WCAG 2.1 AA — aim for 2.2. Test every key flow, especially checkout, account creation, and any booking or payment step. Automated scans catch only a portion of issues; the rest need a human reviewer with assistive technology.
- Don't forget the non-web pieces. Mobile apps, PDFs, and any hardware interface have requirements under EN 301 549 beyond the website.
- Publish an accessibility statement. Several member states specifically penalize missing or inadequate statements.
- Monitor continuously. Compliance isn't a single audit — sites change, and a passing score in June doesn't hold in September without ongoing checks.
The throughline is the same one we keep coming back to: real accessibility is a moving target that demands genuine remediation and ongoing verification, not a script or a one-time scan. The upside for US businesses is that the work isn't duplicative. A site engineered and monitored to WCAG 2.1 AA — moving toward 2.2 — is meeting the ADA, Section 508, and the EAA's core web requirements with one body of work.
That's exactly how Accessive approaches it: every audit combines automated scanning with expert review against WCAG 2.2 AA, ADA Title III, and Section 508, delivers concrete code-level fixes for each finding, and uses continuous monitoring to catch new regressions as your site changes — so a site you've made compliant for US law is already most of the way to compliance for the EU market too.
This article is for general information and is not legal advice. The European Accessibility Act is implemented and enforced separately by each EU member state; for guidance on your specific situation and the rules in the countries you serve, consult a qualified attorney.