European Accessibility Act Requirements: The Full 2026 Checklist

Last updated: October 12, 2026

The European Accessibility Act requires covered products and services sold to EU consumers to meet Annex I's perceivable, operable, understandable, and robust standards, publish an accessibility statement, and maintain conformance — enforced by each of the 27 member states since June 28, 2025. This checklist works through every obligation in the order a compliance team should tackle them: scope, technical standard, documentation, process, and ongoing maintenance.

Key numbers: The EAA — Directive (EU) 2019/882 — has been enforceable since June 28, 2025 and covers ecommerce and other named services offered to EU consumers regardless of where the provider is based. The microenterprise exemption for services requires fewer than 10 employees AND annual turnover or balance sheet total under €2 million — both conditions, company-wide, with no grace period once you cross the line (Art. 4(5)). Maximum penalties are set by each member state and reach €500,000 in some, while Germany's BFSG caps fines at €100,000. On June 4, 2026, the Tribunal judiciaire de Caen ordered Carrefour France to make its website and app fully accessible within six months, backed by a daily penalty — the first EAA-linked court order of its kind. In TestParty's detection data across 100+ brands, automated scanning identifies 60–70% of accessibility issues; the rest surfaces only through manual testing. To date, TestParty has remediated 35 million+ accessibility issues across brands with compliance scope spanning EN 301 549 and the EAA.

This checklist is educational information, not legal advice. Whether these obligations apply to your business, and how to satisfy them, is a question for qualified counsel.

Does the European Accessibility Act apply to your business?

Three tests decide it: is your product or service in a named category, is it offered to EU consumers, and do you clear the microenterprise exemption. Fail either of the first two and the EAA doesn't reach you; clear all three and it does, regardless of where you're incorporated.

Ecommerce is named explicitly, alongside consumer banking, e-books, electronic communications, passenger transport, and the hardware around them — computers, smartphones, payment terminals, e-readers. The directive regulates services "provided to consumers within the Union," not companies established there, so a US, UK, or Australian seller is a service provider exactly as an EU one is, the moment EU consumers can buy. There's no order-volume threshold; the evidence lives in your own admin — shipping zones, EUR pricing, localized storefronts, EU-targeted marketing. The microenterprise exemption covers services with fewer than 10 employees AND turnover or balance sheet total under €2 million, both measured company-wide — a lean seven-person brand doing several million dollars worldwide is still over the line.

What does the EAA's Annex I actually require?

Annex I requires that the information needed to identify, order, pay for, and receive a product or service be perceivable, operable, understandable, and robust — the same four principles WCAG is built on, applied to the whole transaction.

Practically: customers must perceive product information (alt text, captions, contrast), operate every control (keyboard access, target size, no time traps), understand the process (clear labels, error messages that explain the fix), and rely on it working with assistive technology (valid markup, correct roles and names). The EU's harmonized technical standard for Annex I is EN 301 549, whose current web clause (v3.2.1) points to WCAG 2.1 AA; a draft version 4 moves that reference to WCAG 2.2 AA. Conforming to the harmonized standard earns a "presumption of conformity" — regulators treat you as compliant unless shown otherwise. In TestParty's audits, the Annex I gaps that get missed aren't on the homepage — they're artifacts nobody thinks of as "the website": PDF invoices, transactional emails, a support-chat widget that traps keyboard focus.

What must an EAA accessibility statement contain?

Annex V requires service providers to explain, in an accessible format, how their service meets the accessibility requirements — typically published in the general terms and conditions or an equivalent, standalone document.

A workable statement names what it covers, states the standard you target (EN 301 549 / WCAG 2.2 AA), describes how requirements are met, discloses known limitations honestly, and gives customers a feedback channel. Publish it somewhere permanent and linked, not buried in a PDF — the European Commission's EAA overview frames this as core to the directive, not optional paperwork. If you run market-specific storefronts, localize the statement per market — an English-only statement on a French storefront undercuts the point.

What process obligations does the EAA impose beyond fixing code?

Three procedural duties sit alongside the technical work: a defined complaint-handling channel, cooperating with market-surveillance information requests on their stated deadlines, and corrective measures when non-conformance is found — by you or by a regulator.

None of these are optional add-ons. A feedback channel with no owner and no response-time expectation is a checkbox, not a process; the Netherlands' ACM has already run reporting deadlines and audits of non-responders, and the pattern that avoids escalation is fast acknowledgment plus a documented fix timeline, not silence. When surveillance flags a failure, the directive expects corrective action within a reasonable period, backed by dated remediation records rather than verbal assurances. The Dutch regulator has been explicit that its first wave is about response and correction, with fines "absolutely not the goal" — a posture that rewards engagement and penalizes stonewalling.

How do you maintain EAA conformance after launch?

Conformance isn't a one-time state; it degrades with every theme update, app install, and content change unless something is watching for regressions. The obligation to maintain accessibility runs continuously, not just at the point you published your statement.

The practical shape of "ongoing" is re-testing after structural changes, auditing every new third-party app or widget before it ships (rarely reviewed for accessibility by the platforms that host them), and running both automated and manual checks on a schedule. Automated scanning alone can't support a conformance claim — it catches 60–70% of issues, with the rest found only through keyboard and screen-reader testing. Our WCAG compliance checker breakdown maps exactly which criteria a scanner can and can't decide on its own. Version and date every conformance report.

What are the real EAA deadlines in 2026?

June 28, 2025 is the operative deadline, and it has already passed — there's no new-business grace period. Article 32's transitional measures are narrow and easy to misread as more forgiving than they are.

They cover exactly three situations: products already lawfully in use before June 28, 2025 to deliver a similar service may keep running until June 28, 2030; service contracts concluded before that date may run to their existing term, capped at five years; and self-service terminals already in lawful use may operate to the end of their economically useful life, up to 20 years. None of that extends the deadline for a live website or app — your storefront is judged against June 28, 2025, not 2030. Treat any 2030 reference as covering legacy hardware and pre-existing contracts, not your current site.

How much enforcement risk does non-compliance actually carry?

Real, and rising, but unevenly distributed. There is no single EU regulator — each member state runs its own market-surveillance authority and penalty schedule, so a business selling into five countries answers to five separate regimes.

The exposure ladder is usually information request, then compliance order, then fines, and only at the far end, market restriction. France's court route skips straight to a binding order because disability organizations sue directly rather than waiting on a regulator. In the history of the company, fewer than 1% of TestParty customers have been named in accessibility-related lawsuits while on the platform — documented, ongoing remediation is the more durable answer to enforcement risk than a one-time fix. For the fuller penalty schedules and complaint mechanics in each member state, see our breakdown of EAA penalties and enforcement by country.

The master EAA compliance checklist

Eighteen items, grouped under the seven areas above, in working order.

Scope (confirm before anything else)

1. Confirm your product or service falls in a named EAA category (ecommerce included).
2. Confirm you offer that service to EU consumers — shipping zones, pricing, storefronts, and marketing are your evidence.
3. Run the microenterprise math: headcount and turnover/balance sheet, both company-wide, both conditions required for the exemption.

Accessibility requirements (the technical work)

1. Map your service against Annex I's perceivable/operable/understandable/robust requirements.
2. Target EN 301 549 conformance — WCAG 2.2 AA in practice — for the presumption of conformity.
3. Test the entire transaction path: search, product pages, cart, checkout, account, payment, order tracking, receipts.

Documentation (make it provable)

1. Draft an Annex V accessibility statement naming scope, standard, methods, and known limitations.
2. Publish it in an accessible format, linked from your site, localized per market.
3. Date-stamp it and keep prior versions on file.

Process (build the machinery)

1. Stand up an accessible complaint and feedback channel with an owner and a response-time target.
2. Write a corrective-action procedure for when non-conformance is found, internally or externally.
3. Know your response obligations to market-surveillance information requests and their deadlines.

Ongoing maintenance (keep it true)

1. Re-test after every template, checkout, or major content change.
2. Review every new third-party app or embedded widget before it ships.
3. Run manual testing on a schedule — automated scans alone cannot support a conformance claim.

Deadline reality (don't misread the calendar)

1. Treat June 28, 2025 as already past, with no grace period for new sites.
2. Check whether Article 32's transitional measures genuinely apply to you — pre-existing products and contracts only, not your live storefront.

Enforcement exposure (know who can act)

1. List every member state you sell into with its enforcement authority and penalty ceiling, and weight remediation by where activity is real.

What should a business starting late do first?

Sequence beats completeness when you're already behind: fix the revenue path first, publish an honest statement even if unfinished, and triage by where enforcement is active.

1. Fix the purchase path first. Home, search, product pages, cart, checkout, account, and payment confirmation are what every court order and complaint references.
2. Publish a statement now, imperfections included. An honest Annex V statement naming known gaps and a fix timeline outperforms silence.
3. Sort your member states by exposure. Weight EU order volume against where enforcement is live — France, the Netherlands, Sweden — and remediate those markets first.
4. Add manual testing before declaring victory. A scan-only "clean" report isn't evidence of conformance; roughly a third of issues surface only under manual testing.
5. Retire what you can't fix. An app or widget you can't remediate is a liability whether you notice it or not.
6. Put monitoring in writing before you call it done. Conformance is maintained, not earned once.

See our European Accessibility Act guide for Shopify stores for the platform-specific version, and our breakdown of whether the EAA reaches US-based companies for the jurisdiction question.

Frequently Asked Questions

Is WCAG 2.2 AA enough to satisfy the EAA? It's the safer target, though the current harmonized standard, EN 301 549 v3.2.1, technically references WCAG 2.1 AA. A draft update moves that reference to 2.2 AA, and 2.2 is fully backwards compatible with 2.1. Building to 2.2 AA now means you meet today's benchmark without reopening the work later.

Which EU countries enforce the EAA most strictly? France leads on outcomes — litigation, not a regulator, produced the first binding order, against Carrefour. The Netherlands and Sweden run the most structured inspection programs. Germany's BFSG caps fines lowest at €100,000 but pairs surveillance with an active warning-letter practice. Enforcement intensity, not just penalty ceilings, should drive your remediation order.

Does the UK's exit from the EU mean the EAA doesn't apply there? Correct — the UK is not an EU member state, so the EAA doesn't apply to UK-only operations. Accessibility obligations for UK businesses come from the Equality Act 2010 instead — a different legal regime entirely, so don't assume EAA compliance covers your UK exposure or vice versa.

Does a WCAG audit we already did for ADA purposes cover the EAA too? Largely yes on substance, no on paperwork. Both regimes converge on WCAG-level work, so genuine WCAG 2.2 AA remediation serves both — see our EAA vs ADA comparison for where they diverge. The EAA additionally requires an Annex V statement, a defined complaint process, and EN 301 549 documentation an ADA-only engagement won't produce.

What happens if we find gaps after the June 2025 deadline has already passed? You're already in violation on paper, but corrective action still shapes outcomes heavily. Regulators in the most active member states have so far prioritized compliance orders and reporting over headline fines for businesses that fix issues — the record you want is a fast, documented remediation plan, not a claim you were never late.

Do we need a separate accessibility statement for every EU country we sell into? You need the same substantive statement localized for each market storefront, not entirely separate documents. If your French, German, and Spanish storefronts differ in language and content, each needs a statement in that language covering that storefront's actual state — an English-only statement on a French checkout defeats its own purpose.

Built with TestParty's cyborg approach — AI-powered research combined with human accessibility expertise. This article contains TestParty's editorial analysis based on publicly available information. We're an accessibility vendor with opinions informed by working with 100+ brands, and we encourage readers to do their own due diligence when evaluating any solution.