Digital Accessibility Guide (European Accessibility Act): how to achieve compliance?

What is the European Accessibility Act?

The EAA is a directive that harmonises accessibility requirements for essential products and services in the EU, so that people with disabilities can access them on the same terms as everyone else.

Being a directive, it is transposed by each Member State. It marks a major extension of the accessibility obligation to the private sector, which had until now been focused on the public sector.

It does not define technical criteria in detail, but refers to recognised standards, in particular the European standard EN 301 549, which incorporates the WCAG (Web Content Accessibility Guidelines), the international reference framework for web accessibility.

Which products and services are affected?

The EAA's scope is broad and covers everyday services. Many private companies are now subject to it.

• E-commerce and transactional websites.
• Banking and payment services for consumers.
• Passenger transport (ticketing, information, applications).
• E-books and e-readers.
• Electronic communications services and audiovisual media.
• Certain equipment: ATMs, kiosks, payment terminals.

Technical standards: EN 301 549 and WCAG

Compliance is assessed against precise technical standards. The WCAG form the core framework for the web.

WCAG Level AA is the standard target for compliance of websites and applications.

EAA and RGAA: what is the relationship?

In France, digital accessibility in the public sector falls under the RGAA. The EAA extends the obligation to the private sector, with converging requirements.

• RGAA: the French framework, mandatory for the public sector and certain large companies.
• EAA: extends accessibility to many products and services in the private sector.
• Common foundation: both are based on WCAG, which allows efforts to be pooled.
• Declaration: in both cases, compliance must be documented and publicly displayed.

What penalties apply in the event of non-compliance?

As a directive, the EAA carries sanctions defined by each Member State, generally supplemented by compliance measures. Reputational risk and user exclusion are also significant concerns.

How to achieve compliance: the 5-step roadmap

Step 1 — Determine your applicability

Verify whether your products or services fall within the scope of the EAA (e-commerce, banking, transport, etc.) and whether you qualify for an exemption (service micro-enterprise).

Document this analysis: it defines the scope of your obligations.

• Identify your products and services that are in scope.
• Verify eligibility for exemptions.
• Define the perimeter to be made accessible.

Step 2 — Audit existing accessibility

Conduct an audit of your websites, applications and user journeys against the WCAG (Level AA) and EN 301 549. Identify gaps and prioritise remediation.

An audit combining automated testing and manual testing (including the use of assistive technologies) is the most reliable approach.

• Audit against WCAG Level AA.
• Combine automated and manual testing.
• Prioritise gaps by user impact.

Step 3 — Remediate and embed accessibility

Correct gaps (colour contrast, keyboard navigation, text alternatives, structure, forms) and integrate accessibility from the design phase of your future developments (accessibility by design).

Addressing accessibility upstream is far less costly than retrofitting after the fact.

• Remediate priority non-conformities.
• Embed accessibility into your design processes.
• Train designers and developers.

Step 4 — Publish the accessibility statement

Draft and publish an accessibility statement indicating the level of conformance, any applicable exceptions, and the means to report an issue.

This statement is an expected element of evidence and transparency.

• Indicate the level of conformance achieved.
• Mention exceptions and inaccessible content.
• Provide a contact method for reporting an issue.

Step 5 — Sustain accessibility over time

Monitor accessibility on a regular basis, particularly after each update, and correct regressions. Accessibility deteriorates quickly without ongoing oversight.

Integrate accessibility checks into your release cycle.

• Re-audit after each major update.
• Address regressions promptly.
• Incorporate accessibility into non-regression testing.

Common mistakes to avoid

• Believing that accessibility only concerns the public sector: the EAA now targets many private services.
• Relegating accessibility to the end of a project rather than integrating it from the design stage.
• Relying solely on automated tests, which are insufficient to cover WCAG requirements.
• Overlooking the accessibility statement, which is nevertheless expected.
• Forgetting to recheck after updates, leading to regressions.
• Underestimating the scale of remediation work when gaps are discovered too late.