Your EAA Compliance Roadmap

The European Accessibility Act (EAA), effective 28th June 2025, mandates enhanced accessibility for individuals with disabilities across the EU, imposing new obligations on businesses within and outside the EU. If your organisation offers digital services or products covered by the EAA, now is the time to act. 

Beyond compliance, it's about creating a more inclusive, user-friendly experience for all customers, including the 101 million people in the EU with disabilities(this will open in a new window). For a comprehensive understanding of the legislation and its requirements, read The EAA definitive guide.

Where do you begin? This roadmap outlines the essential steps—Assess, Address, and Embed—to help your business comply with EAA requirements ahead of the deadline and maintain compliance beyond it. 

Assess

Understanding the EAA scope

The EAA primarily focuses on transactions and sales of any product or service to customers in the European Union. This includes all steps leading to the conclusion of a transaction with a consumer, not just the final purchase. 

This legislation applies regardless of whether a company is based within or outside the EU, if it provides products or services to EU customers.

The EAA applies to a wide range of industries, particularly those providing:

• E-commerce platforms and online services
• Banking and financial services (including ATMs and payment terminals)
• Transport services (ticketing and check-in)
• Telecommunications
• E-books and related services
• Retailers selling digital products

Conduct an Accessibility Audit

The current version of the EN 301 549 standard serves as the baseline for meeting accessibility requirements under the European Accessibility Act (EAA). It references the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, which remain the established benchmark for digital accessibility.

Although EN 301 549 is still based on WCAG 2.1, work is underway to update it to reflect WCAG 2.2. We recommend adopting WCAG 2.2 AA now, as this proactive step not only prepares organisations for future compliance but also signals a strong commitment to accessibility and helps mitigate potential legal risks.

Conducting a thorough accessibility audit will help identify any non-compliant areas and prioritise fixes.

An audit typically includes:

• Reviewing websites, mobile apps, and digital interfaces
• Conducting automated and manual testing of key user journeys
• Assessing compatibility with the most used assistive technologies, including the following: - JAWS (desktop screen reader) - NVDA (desktop screen reader) - VoiceOver on iOS (mobile screen reader) - TalkBack (mobile screen reader) - Windows Magnifier or Apple Zoom (screen magnifiers) - Dragon (speech recognition)

Evaluate Capabilities

Before tackling EAA compliance, evaluate your internal accessibility capabilities and identify any gaps. This assessment ensures you choose the most effective approach—whether in-house or external support—for meeting compliance requirements.

• Start by assessing internal expertise - Does your team have the skills needed in areas like accessibility testing, inclusive design strategy, assistive technology testing, usability testing, and training delivery? - Can they confidently carry out WCAG audits or deliver specialist training sessions?
• Conduct a gap analysis - This will help determine whether to proceed with an in-house approach or seek external support. If your team lacks the expertise or capacity, partnering with accessibility specialists can provide you with expert audits, guidance, and training. If you already have skilled professionals in place, focus on enhancing their capabilities through training and hands-on experience.

Address

Prioritising Findings

Once an accessibility audit is complete, the next step is to address the identified issues. With a potentially large number of issues, this process can feel overwhelming, so prioritisation is key to tackling them effectively. A good approach to use is to prioritise issues by severity (high, medium, low) is essential. High-impact issues completely block user access, while medium and low issues, though problematic, present less significant accessibility barriers.

This prioritisation helps in:

• Addressing the most impactful accessibility barriers first
• Efficiently allocating resources
• Tracking progress over time
• Clearly communicating accessibility status and plans to stakeholders

Work closely with developers, designers, and content teams to streamline the process. Develop a clear remediation plan that outlines timelines, responsibilities, and specific actions for each issue.

Once fixes are in place, conduct spot checks to verify they’ve been implemented correctly—and to catch any new accessibility barriers that may have been introduced. This step is essential for maintaining the quality and accuracy of your accessibility improvements.

Accessibility Statement

Creating an Accessibility Statement is a key requirement under the EAA, which mandates businesses to prepare and maintain accessibility information as outlined in Annex VI, for as long as the service is available.

An accessibility statement is a public declaration that communicates the accessibility status, policies, and practices of a website or application.

The statement conveys:

• Accessibility Status
• Known Issues
• Planned Improvements
• User Guidance 

An accessibility statement is important, its more than just a compliance tool—it builds trust and demonstrates inclusivity by showing that your organisation values all users and is actively working to make its digital content accessible to everyone.

Update Procurement Processes

Many organisations rely on third-party platforms, software, and tools but not all are accessible. The EAA requires businesses to ensure that any externally purchased digital service is compliant. That means accessibility can’t be an afterthought – it needs to be embedded at every stage of the procurement process. This should include the following:

Before purchase:

• Define accessibility requirements early, using WCAG 2.2 AA or EN 301 549 as benchmarks. Be specific so suppliers understand the standards they must meet.
• Evaluate suppliers’ accessibility track record through case studies or examples of past work to assess expertise and commitment.
• Request VPATs (Voluntary Product Accessibility Templates) or ACRs (Accessibility Conformance Reports) to verify compliance.
• Test or demo products with assistive technologies like screen readers to ensure usability in real-world scenarios.

During the contract:

• Include clear accessibility expectations in contracts and Service Level Agreements (SLA), detailing responsibilities, issue resolution processes, and consequences for non-compliance.
• Add remediation plans outlining steps and timelines for addressing post-launch accessibility issues.
• Ensure contract terms align with your internal accessibility policy for consistency across your digital estate.
• Establish ongoing monitoring processes to regularly review accessibility performance and reassess services over time.

Learn more on how VPATs and ACRs play a crucial role in inclusive digital procurement here. 

Embed

Embedding accessibility into processes is essential for achieving EAA compliance, which involves incorporating accessibility best practices to make it a standard part of business operations for all products and services.

Policy

• Processes and documentation - Maintain up-to-date documentation detailing how products and services meet accessibility standards. Regular updates ensure compliance, especially after modifications or updates.
• Integrating accessibility into development - Embed accessibility into product lifecycles by prioritising it from the start. Use WCAG requirements in designs, ensure collaboration between design and development teams, and integrate accessibility into design systems. This proactive approach aligns with the EAA’s requirement to consider accessibility before market release, ultimately saving time and resources in the long term.

Training 

Accessibility is not just a one-time fix; it requires ongoing awareness and knowledge across your organisation. Training ensures all employees understand their responsibilities in making services accessible and meet EAA compliance requirements. 

Training helps teams responsible for digital products understand:

• The importance of accessibility 
• How to design and create accessible content 
• How to test and maintain accessibility over time
• How to manage accessibility in an organisation 
• How to respond to customer accessibility requests

Our accessibility training suite is designed to upskill and support teams. 

To put continuous learning into practice, you should consider:

• Regular workshops and training sessions

Host accessibility workshops to keep teams updated on evolving standards like WCAG 2.2 and EAA requirements. Provide role-specific training for developers, designers, and support teams to integrate accessibility into daily workflows. Use audit findings as case studies and conduct empathy workshops and create accessible personas to raise awareness and promote inclusive design.

• Accessibility champions to promote best practices

Create a network of accessibility champions within different departments to advocate for inclusivity and share their expertise. These champions can offer guidance, troubleshoot issues, and ensure that accessibility is prioritised from the outset of projects.

Ongoing Monitoring and Growth 

The June 2025 deadline is just the starting point for a continuous process of monitoring, adapting, and improving to meet evolving standards and user needs.

Here are actionable steps to maintain compliance and a culture of accessibility:

• Monitor and audit regularly Conduct regular audits and spot checks after major updates to identify non-compliant areas. Use insights from monitoring to refine processes, ensuring future changes align with standards. 
• Document and report Keep detailed records of testing, audits, remediation, and user feedback. Publish and update an accessibility statement outlining goals, barriers, and improvements as required by the EAA.
• Conduct usability testing with disabled people Involve people with disabilities in usability testing to identify barriers and enhance accessibility. Use their feedback to inform compliance documentation and strategies for practical improvements.
• Enable feedback channels Provide accessible ways for users to report issues, such as email or contact forms. Address complaints efficiently and use feedback to refine user experiences.
• Celebrate success Share case studies of accessible outcomes to motivate teams and showcase the benefits of inclusivity for users and businesses.

Key Takeaways on EAA Compliance

Start with a clear roadmap and use the Assess, Address, Embed framework to guide your accessibility journey:

1. Assess: Understand the EAA scope, audit your digital estate, and evaluate internal capabilities.
2. Address: Prioritise and fix accessibility issues, publish an Accessibility Statement, and embed accessibility into procurement practices.
3. Embed: Make accessibility part of your policy, development lifecycle, training programs, and culture.

Remember, EAA compliance isn’t a one-off task—it’s a long-term commitment that requires continuous improvement. Regular audits, inclusive usability testing, and maintaining accurate documentation are all essential to staying compliant and delivering better experiences for everyone.

If you need support at any stage, get in touch today. From audits and usability testing with disabled users to creating compliance documentation, we offer practical, tailored solutions that support both compliance and inclusive design.