Compliance
European Accessibility Act: what changed in 2025
The EAA came into force on 28 June 2025. This is what B2C digital product and service providers need to know, and what happens if they do not comply.
TL;DR
- The European Accessibility Act (EAA) applies from 28 June 2025. B2C digital products and services must meet WCAG 2.1 Level AA as a baseline.
- In Germany, the implementing law is the BFSG (Barrierefreiheitsstärkungsgesetz). Enforcement falls under the market surveillance authority of each federal state.
- Micro-enterprises (fewer than 10 employees and under €2 million annual turnover) are exempt from most obligations, but not from the requirement to handle complaints.
- Non-compliance risks fines, injunctions, and exclusion from public procurement. German consumer protection bodies can also bring enforcement actions.
- See how we run EAA and BITV accessibility audits for teams in Germany and across the EU.
Background
What the EAA actually <em>requires</em> and what it does not cover.
The European Accessibility Act (Directive 2019/882) is an EU directive that harmonises accessibility requirements for digital products and services sold to consumers across EU member states. It replaces a patchwork of national rules with a single standard, lowering the compliance overhead for businesses operating across borders while raising the floor for all markets.
**The EAA does not cover all websites.** It applies to B2C digital products and services in specific categories: e-commerce, banking and payment services, transport services, e-books and e-reading software, electronic communications, and audiovisual media services. B2B-only digital services are outside scope. Public-sector bodies already covered by the Web Accessibility Directive (2016/2102) are also out of scope for the EAA but remain subject to their existing obligations.
The technical standard the EAA references is EN 301 549, which in turn maps to WCAG 2.1 Level AA for web content. Meeting WCAG 2.1 AA is the practical baseline for compliance.
Who must comply
EAA scope by organisation and service type.
| Category | In scope | Notes |
|---|---|---|
| B2C e-commerce | Yes | Retail websites, checkout flows, product pages, mobile apps |
| Online banking and payments | Yes | Banking apps, payment services, account portals |
| Transport booking services | Yes | Ticket purchase, journey planning, passenger information |
| E-books and reading software | Yes | Including DRM-protected e-books and dedicated readers |
| Electronic communications | Yes | VoIP, messaging services, related customer-facing portals |
| B2B-only services | No | Services sold exclusively to businesses are exempt |
| Micro-enterprises | Partial | Fewer than 10 employees and under €2 million turnover: exempt from most obligations but must handle accessibility complaints |
| Public-sector bodies | No (separate rules) | Already covered by Web Accessibility Directive 2016/2102 |
Key obligations
What in-scope organisations must actually do.
01
Technical conformance
Digital products and services must conform to EN 301 549 / WCAG 2.1 Level AA. This covers perceivability (alt text, captions, contrast), operability (keyboard navigation, no seizure triggers), understandability (readable language, predictable behaviour), and robustness (compatible with assistive technologies). A technical audit is the standard way to verify and document conformance.
02
Accessibility statement
In-scope organisations must publish an accessibility statement that describes the conformance status of the product or service, lists known accessibility gaps with remediation timelines, and provides a contact mechanism for users to report issues. The statement must be kept up to date and reviewed whenever the product changes significantly.
03
Complaints procedure
All in-scope organisations (including micro-enterprises, which are otherwise exempt) must have a documented process for receiving and responding to accessibility complaints from users. The procedure must be publicly accessible and responses must be timely. In Germany, unresolved complaints can escalate to the market surveillance authority.
04
Ongoing monitoring and documentation
Compliance is not a point-in-time certificate. In-scope organisations must maintain evidence of conformance testing, track remediation progress, and update their accessibility statement when gaps are identified or fixed. Periodic re-testing is required when products change materially. In practice, this means integrating accessibility testing into the regular development and release process.
Common questions
What teams ask when they start an EAA compliance project.
We launched before June 2025. Are we still required to comply?
Yes. The EAA applies from 28 June 2025 regardless of when the product or service was launched. There is no grandfather clause for existing products. However, the disproportionate burden exemption allows organisations to phase in changes where full immediate compliance would require a fundamental redesign and the cost is genuinely disproportionate to the benefit. This exception must be documented and is not a blanket delay.
What are the penalties for non-compliance in Germany?
Under the BFSG, enforcement is handled by state-level market surveillance authorities. Penalties include fines, injunctions, and in serious cases product withdrawal orders. The BFSG also allows consumer protection associations to bring enforcement actions. Exact fine levels are set at member-state level; German enforcement practice is still developing, but the presence of an accessible complaints procedure is an early indicator that a company takes its obligations seriously.
Does the EAA apply to native mobile apps?
Yes. Mobile apps that fall within the in-scope service categories (banking, e-commerce, transport, etc.) must comply. The technical requirements are the same (EN 301 549), and platform-specific accessibility APIs (iOS VoiceOver, Android TalkBack) are part of conformance testing. App store submissions do not constitute EAA compliance checks.
How long does an accessibility remediation project take?
It depends on the current state of the product. A well-structured modern web application might reach WCAG 2.1 AA with three to six weeks of targeted remediation after an audit. A legacy product with significant structural barriers, deep third-party integrations, or a poor original implementation may take several months. An audit with a prioritised finding list is the starting point: without knowing the actual gap, any estimate is unreliable.
We are a B2B SaaS company. Does the EAA apply to us?
If your product is sold exclusively to business customers and is not used directly by end consumers, you are outside the scope of the EAA. However, if your platform is used by the customers of your business clients (for example, a payment widget embedded on a consumer-facing website), that part of the experience is in scope for your clients even if not directly for you. Many B2B SaaS providers are updating their products proactively to support their clients in meeting EAA obligations.
What is the difference between EAA, BITV, and WCAG?
WCAG (Web Content Accessibility Guidelines) is the international technical standard. BITV (Barrierefreie-Informationstechnik-Verordnung) is the German regulation that implements WCAG for public-sector digital services. The EAA is the EU directive that extends similar obligations to the private sector; its German implementing law is the BFSG. In practice, an EAA-compliant product meets WCAG 2.1 Level AA, which is the same technical target as BITV 2.0.
How we approach EAA compliance
Audit first, then a prioritised remediation plan with named deadlines.
We run structured EAA and BITV accessibility audits: a combination of automated tool scanning and manual expert review covering keyboard navigation, screen reader compatibility, colour contrast, form labelling, and document structure. The output is a finding list with severity scores (critical, high, medium, low), remediation guidance for each issue, and an estimated effort per finding. **See the EAA and BITV accessibility audit for scope and typical cost.**
For teams that need to remediate as well as audit, we can run the project end to end: audit, sprint-based remediation, regression testing, and publication of the accessibility statement. We do not treat conformance as the finish line. The goal is a product that genuinely works for users with disabilities, with documentation that stands up to regulatory scrutiny.
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