The EAA Turns One: What a Year of the European Accessibility Act Means for Your Website

On June 28, 2025, the European Accessibility Act stopped being a future deadline and became live law across the EU. That date came and went without the internet grinding to a halt, which led plenty of business owners to quietly conclude the whole thing was overblown.

One year on, that conclusion looks premature. The first year of any EU-wide consumer law follows a familiar pattern: a slow start while national authorities staff up, then complaints, then enforcement that compounds. The EAA is tracking that pattern. If you sell to consumers in the EU — even from outside the EU — the anniversary is a good moment to check where you actually stand, because the grace period of general confusion is ending.

This article is general information, not legal advice. For decisions about your specific situation, talk to a qualified attorney.

A 60-second refresher on what the EAA is

The European Accessibility Act (Directive (EU) 2019/882) requires a defined set of products and services to be accessible to people with disabilities. For website owners, the part that matters is the services list: e-commerce is on it, along with consumer banking, e-books, transport booking, and telecoms.

“E-commerce” is broader than most people assume. If consumers in the EU can buy something through your website or app — a product, a subscription, a course, a booking — you are providing an e-commerce service to them. It does not matter whether your business is based in Berlin, London, or Ohio. What matters is that you are selling to EU consumers.

Because the EAA is a directive rather than a regulation, each member state wrote it into its own national law, with its own enforcement body and its own penalties. That is why fines and procedures differ between, say, Ireland and Germany. The obligations themselves, though, are broadly the same everywhere: your service, including its website, has to meet the accessibility requirements — and in practice, conformance is measured against the European standard EN 301 549, which incorporates WCAG, the same Web Content Accessibility Guidelines used in US lawsuits.

What actually happened in year one

If you were expecting June 29, 2025 to bring a wave of fines, that is not how EU consumer law works — and not how it worked here. The first year looked like this:

National authorities got operational. Member states designated market surveillance authorities to handle EAA complaints. Some were ready on day one; others spent months clarifying who handles what. That ramp-up period is what made the first year feel quiet. It will not stay quiet: these authorities exist specifically to process complaints, and the complaint channel is open to any consumer and to disability organizations acting on their behalf.

Complaints became the engine. Unlike the American ADA system, which runs on private lawsuits and demand letters, the EAA runs on complaints to regulators. A frustrated customer who cannot complete your checkout does not need to hire a lawyer. They fill in a form with their national authority, and the authority is obligated to look into it. Disability advocacy groups across Europe spent years preparing for this law; testing services and filing complaints is precisely what many of them now do.

The compliance gap stayed enormous. Every major accessibility study of the past year tells the same story they told before the deadline: the overwhelming majority of websites — across studies, consistently more than nine in ten — have detectable WCAG failures on their home page alone. The EAA did not change that overnight. What it changed is the consequence of being in that majority while selling to EU consumers.

Accessibility statements became the visible tell. The EAA requires service providers to explain, in their terms and conditions or equivalent, how their service meets the accessibility requirements. A site with no accessibility statement at all is advertising that it has not engaged with the law — it is the first thing an authority or a complainant looks for, and it is the easiest gap to spot from the outside.

The misconceptions that survived the first year

A year in, the same handful of myths keep showing up in small-business forums. Worth killing them directly:

“I’m outside the EU, so it doesn’t apply to me.” It applies to services provided to consumers in the EU, wherever the provider sits. If you ship to France or sell subscriptions to customers in Spain, you are in scope. Non-EU businesses do not get a pass; they get the same obligations without the home-country familiarity.

“I’m a small business, so I’m exempt.” The exemption is for microenterprises providing services: fewer than 10 people and annual turnover or balance sheet under EUR 2 million. Both conditions, not either. A 12-person company is in scope. An 8-person company doing EUR 3 million is in scope. And even genuine microenterprises should be careful: the exemption covers the EAA’s service obligations, but it does not make accessibility complaints, bad press, or lost customers disappear.

“I bought an accessibility overlay, so I’m covered.” Year one confirmed what accessibility professionals said all along: overlay widgets do not make a site conform to WCAG, and European regulators evaluate the underlying service, not the presence of a widget. If anything, an overlay signals that you know accessibility is required and chose a shortcut. We’ve written before about why overlays don’t work; under the EAA the calculus is the same.

“Nothing happened in year one, so nothing will happen.” Regulatory enforcement compounds. Authorities prioritize large, visible services first, then work down. Complaints accumulate in queues. The businesses that get hurt by laws like this are rarely the ones caught in month one — they are the ones who used the quiet first year as a reason to do nothing and got caught in year three with no paper trail of effort.

The deadlines still ahead

The EAA did not finish arriving in 2025. Two dates still matter:

June 28, 2030 is the end of the main transition period for services. Service contracts agreed before June 28, 2025 can run unchanged until they expire, but no later than 2030. Self-service terminals (think ticket machines and payment kiosks) get longer — up to 20 years from when they were put into use — but that is hardware, not websites.

For a typical website, the transition arguments are thin. A site you redesigned, restyled, or substantially updated after mid-2025 is hard to characterize as a pre-existing, unchanged service. If you have shipped anything new since the deadline — a new checkout, a new booking flow, a new storefront — assume the requirements apply to it now.

There is also a disproportionate burden exception: a business can argue that full compliance would be disproportionately costly relative to its size and resources. But it is not a self-declared get-out-of-jail card. You have to actually perform and document the assessment, keep it, and be prepared to show it to an authority — and it does not exempt you from the parts that are reasonable to fix. For most websites, the biggest failures (missing form labels, broken contrast, keyboard traps) are cheap to fix, which makes a burden argument about them roughly impossible.

What to actually do at the one-year mark

If the anniversary prompts you to do anything, do these five things, roughly in order:

1. Settle whether you’re in scope. Selling products or services to EU consumers through your site? You are, unless you genuinely qualify as a microenterprise — count your heads and your turnover honestly.

2. Run a first-pass check yourself. You do not need a developer to find the worst problems. Free tools like WAVE and your own keyboard (can you Tab through your checkout and complete a purchase without a mouse?) surface the majority of high-impact failures in minutes. Our 15-minute EAA compliance check walks through it step by step.

3. Fix the conversion path first. Authorities and complainants care most about whether a disabled customer can actually use the service: find a product, understand the price, complete the purchase, contact support. Form labels, button names, contrast, keyboard operability, and error messages on that path deliver more legal and commercial value than anything else you can do.

4. Publish an accessibility statement. Describe honestly what standard you target, what you have done, what known gaps remain, and how users can report problems. An honest statement with known issues listed beats a perfect-sounding one you cannot back up — and a working feedback channel means frustrated users contact you instead of a regulator.

5. Keep evidence. Date your audits, keep your fix lists, record what you changed. If an authority ever asks, the difference between “we have been working on this since 2025, here is the trail” and a shrug is the difference between a cooperative correction and a penalty. Member-state fines vary widely — we’ve broken down the penalty ranges by country — and demonstrated effort is the cheapest insurance available.

The honest one-year verdict

The EAA’s first year was neither the apocalypse vendors sold nor the non-event skeptics declared. It was infrastructure being assembled: authorities staffed, complaint channels opened, the first cases working through queues, and a legal baseline quietly established that accessible-to-consumers now means accessible-to-all-consumers.

For a small business, the practical takeaway is unglamorous: the law is real, the standard is WCAG, the cheapest time to fix your site is still right now, and the most expensive time is after a complaint lands. Year two will have less patience than year one.

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