The European Accessibility Act: Steps to achieve compliance

We have been busy helping our clients prepare for the upcoming European Accessibility Act (EAA) and it has been a pleasure to see the significant improvements that have been made and planned into future roadmaps. As strong advocates of accessibility, we are fortunate that many of our clients consider making their services accessible as a matter of course, however, the impact that legislation like the EAA has, in terms of helping to gain more momentum and engagement, is undeniable.

As the date for the EAA becoming law across the EU comes closer, we thought it would be helpful to summarise some key points that may be relevant to service providers.

What is the European Accessibility Act (EAA), and what is the cost of failing to meet it?

The EAA (Directive (EU) 2019/882) requires products and services to be designed so they can be used to a full and equal extent by people with accessibility needs. The directive becomes law across the European Union (EU) on June 28, 2025.

The EAA applies to both private and public sector companies, that want to sell, produce, or distribute products within the EU. This includes big players like Microsoft and Eurostar, down to small service providers that have at least 10 employees and a turnover of €2 million or more. It covers products and services including:

• consumer facing websites and apps,
• physical devices, from computers and smartphones to Wi-Fi routers, as well as their packaging and instructions too,
• banking services, including access to customer support,
• self-service terminals, such as ATMs, ticketing machines or check-in kiosks, and
• transportation services, including real-time travel information.

The impact of not meeting the EAA can affect businesses both financially and operationally. For instance non-compliance can result in:

• significant fines, which vary between EU member states – for example, it can be between €5,000 and €250,000 in France and up to 5% of the business turnover in Italy,
• criminal penalties for businesses and staff members – for example, in Ireland it could lead to imprisonment and/or a fine on conviction,
• civil action from advocacy organisations or individuals, and
• reputational damage along with withdrawal/launch delays to services that are not compliant.

Making an impact through compliance

However, the EAA becoming law isn’t the only reason to comply! While the EU is home to over 87 million disabled people, fifteen times this number have a disability worldwide, including 24% of the UK population. This number is increasing due to an ageing population and rise in diseases caused by unhealthy behaviours, meaning more and more are relying on products and services being accessible.

Inclusive, accessible design can also benefit all of us by offering alternative ways of using a product or service. Whether you’ve broken your wrist, forgotten your headphones, or are sat in bright sunlight that causes glare on your devices, everyone experiences situational disabilities throughout their life.

By adhering to the EAA, UK businesses can ensure they are prioritising accessibility to the same extent as competitors, supporting innovation, a positive reputation, and a large customer base. It will also make it easier for companies to expand internationally in the future, increasing market opportunities.

Steps to adhere to the EAA

The EAA requires services to be accessible, but it does not prescribe how to achieve this. Below we have summarised our suggested approach to adhere to the EAA:

1. Identify non-conformance

You firstly need to identify where your product or service is falling short. System Concepts offer digital and physical accessibility audits that do just this, by assessing your product or service against key regulations such as the latest Web Content Accessibility Guidelines (WCAG), that outline how to make content accessible (while the EAA only outlines what). Using manual expert checks rather than automated tools will ensure that you get reliable and descriptive results, with practical recommendations of how to fix any issues. This will give you a clear view of how your product or service is performing and how to move forwards.

2. Develop an accessibility policy

Outline the steps you need to take to comply with new rules, reaching out to accessibility experts if you need help. Having a formal policy in place will help you organise your internal approach to accessibility, while holding all areas of the business accountable. You may want to include content such as:

•  a declaration of commitment, with the laws and standards you adhere to,
• the scope of the policy (i.e. what products, services or assets it covers),
• activities that should be undertaken to optimise accessibility (e.g. audits, testing with users with accessibility needs, employee training), and
• roles, responsibilities and timescales for each initiative.

3. Update your accessibility statement

The EAA requires service providers to publish a publicly available, accessible document explaining how you meet the relevant standards. This could form part of your accessibility statement, which it is best practice to have available on your website and/or app. In addition to showing your commitment to accessibility, we recommend being transparent about any areas you are still working on within the statement, with a roadmap of how you will achieve compliance. This will increase trust and reduce the risk of legal action from your customers. System Concepts can help you write an accessibility statement if this is something you need support with.

4. Implement ongoing improvements

While some things may have quick fixes like updating code, making other aspects of your product or service accessible may require significant changes, such as to a physical design or your business operations for example. Make sure you are confident that improvements meet the needs of customers by running accessibility research to inform decisions and continue to do this regularly, following implementation. Customer expectations, assistive technology and accessibility regulations are constantly evolving, so implementing an ongoing improvement strategy will help you stay ahead of the curve.

5. Train and motivate staff

Use the EAA as a chance to advocate for accessibility within your business, shifting focus from the legalities to the customer. Involve stakeholders in the research and design process by running empathy workshops, inviting them to observe testing, and showcasing best practice. Relevant accessibility training should also be given to employees who interact directly or indirectly with customers, including designers, developers and customer service agents. Accessibility shouldn’t be daunting, and encouraging everyone to take small steps will support your success.

6. Finally, stay updated

Proactively put measures in place to ensure you stay informed about changing regulations, including the EAA. You may want to subscribe to newsletters, follow industry experts, join accessibility communities, or attend conferences, for example. Not only will you learn about what you must do, but you’re likely to pick up best practice tips to help you optimise accessibility in other ways too!