1. What is the European Accessibility Act (EAA)?

2. EAA checklist

3. When does the European Accessibility Act take effect?

4. Which organizations are subject to the EAA directive?

5. Directive priority levels

What is the European Accessibility Act (EAA)?

The European Accessibility Act (EAA) is a legislative framework of the European Union established to ensure that products and services are accessible to people with disabilities. The goal of this act is to remove barriers that prevent full participation of people with various types of disabilities in social and economic life.

The EAA sets accessibility standards for various digital products and services, including websites, mobile apps, e-commerce, banking services, payment terminals, e-books, and many others.

EAA checklist

To make a website, webshop, or digital service compliant with the EAA directive, attention must be paid to the following key aspects:

• Keyboard accessibility – All elements must be accessible and functional without using a mouse.

• Alternative text for images – All images must have descriptions (alt text) that allow visually impaired users to understand their content.

• Contrast and readability – Text and visual elements must have sufficient contrast to be easily readable.

• Navigation and structure – Content should be logically structured with a proper heading hierarchy.

• Forms and inputs – All fields must be clearly labeled and easily filled out by users relying on assistive technologies.

• Video and audio content – Should include subtitles or transcripts.

• Notifications and errors – Information about errors or successful form submissions must be accessible and clearly communicated.

The practical implementation of these guidelines is based on WCAG (Web Content Accessibility Guidelines) standards, specifically level AA.

When does the European Accessibility Act take effect?

The EAA directive was adopted in 2019, and EU member states had until June 28, 2022, to transpose its provisions into national law. The requirements of the EAA will apply from June 28, 2025. From that date onward, all covered products and services must comply with the prescribed accessibility standards.

Which organizations are subject to the EAA directive?

The EAA applies to a wide range of organizations and businesses that offer products and services in the European Union market. Obligated entities include:

• Retailers, especially those with e-commerce stores.

• Financial institutions, including banks and insurance companies.

• Transport companies (air, rail, bus, and maritime transport).

• Digital service providers, including online shopping and multimedia platforms.

• Manufacturers and distributors of digital products such as ATMs, payment terminals, smartphones, e-books, software, etc.

Small businesses with fewer than 10 employees and an annual turnover below 2 million euros may be exempt from certain obligations, but it is still recommended that they implement basic accessibility measures to increase user reach and competitiveness.

Directive priority levels

EAA/WCAG priorities are divided into three levels:

• A (basic requirements) – Minimum level, critical for functionality.

• AA (recommended standard) – The standard typically required for compliance (and the primary reference in the EAA).

• AAA (highest standard) – For maximum accessibility, often not mandatory.

When looking at the A priority list (level A), these are the most essential elements without which users with disabilities cannot perform basic actions.

⚠️ Which webshop sections are most critical for A priority?

For a webshop, level A means that a user must be able to at least:

1. Find a product → Search the catalog using a keyboard, understand descriptions.

2. Add to cart → Button works, confirmation is clear, action is visible.

3. Complete checkout → Fill out the payment form, see errors, confirm order.

4. Log in or register → Form must be functional and understandable.

5. Understand key information → Product descriptions, prices, and errors must all be available in text form.

If any of these points fail, users with disabilities cannot complete a purchase, meaning the webshop is not accessible and not EAA compliant.

🚨 The most common “A” issues in webshops

• The “Add to cart” button has no text or lacks focus.

• The order confirmation pop-up has no focus and cannot be closed via keyboard.

• The credit card form fields are unlabeled (e.g., CVV, Expiry Date – only placeholders).

• Product images lack descriptions (e.g., “product123.jpg” instead of “Blue Adidas sneakers”).

• Checkout error messages are only color-based without text (e.g., red outline without explanation).

If you are just starting compliance efforts, start with the A list. Then move on to AA level, as it is the standard required by the EAA.

Here is the complete AA checklist that complements the A level and aligns with what is most commonly required for EAA compliance (according to WCAG 2.1 AA). This is the level most EU laws (including the EAA) consider the accessibility standard.

⚠️ AA – Especially critical for webshops

Checkout and payment:

• Allow users to review their order summary before confirmation.

• Error messages must clearly indicate what needs to be corrected (not just “invalid input”).

• Payment data must be structured so that a screen reader reads in order, e.g., “Card number, input field; expiry date, input field; CVV, input field.”

Products and descriptions:

• Contrast for prices and discounts – AA compliance often fails here due to gray-on-white or red text with insufficient contrast.

• Specifications and sizes must be readable as text (not only as an image of a table).

📝 How to approach AA implementation in a webshop

• ✅ Start with checkout and cart – these areas contain the most common issues and highest risk.

• ✅ Test mobile + text zoom (200%) – webshops often fail here.

• ✅ Contrast and fonts – products, prices, and discounts must be clear and legible.

• ✅ Keyboard flow throughout – from product search to adding to cart and completing payment.