The European Accessibility Act: What the June 2025 Deadline Means Going Into 2026
The European Accessibility Act’s compliance deadline — 28 June 2025 — has already passed. For the many companies still not fully compliant, the question now isn’t “when do we need to act” but “how exposed are we right now.”
By VVnT SeQuor Team··3 min read
In this article
01
What’s actually in scope
The EAA covers specific products and services sold to consumers across the EU, concentrated in a…
02
What non-compliance actually costs
The EAA is an EU Directive, which means each member state transposes it into national law with its…
03
Where companies catching up should start
Confirm which of your products/services actually fall in scope — many companies overestimate…
What’s actually in scope
The EAA covers specific products and services sold to consumers across the EU, concentrated in a few sectors: retail, financial services, communications, travel and technology. In scope: computer hardware and operating systems, payment terminals, self-service kiosks (ATMs, ticketing, check-in), e-readers and telecom devices, electronic communications services, audiovisual media access, websites and mobile apps (including e-tickets and transport information), consumer banking, e-books, and e-commerce. If your product or service touches any of these categories and reaches EU consumers, the EAA likely applies regardless of where your company is headquartered.
What non-compliance actually costs
The EAA is an EU Directive, which means each member state transposes it into national law with its own enforcement mechanism and penalty structure — so the specifics vary by country, but common elements across member states include administrative fines, orders to withdraw non-compliant products or services from the market, and in some jurisdictions personal liability for responsible company officers. Private enforcement is also a feature in several member states, meaning individual consumers (sometimes supported by advocacy organizations) can bring claims directly, not only regulators.
Scope confirmation comes first because the EAA’s coverage is broader, and its exemptions narrower, than most teams initially assume.
Where companies catching up should start
Confirm which of your products/services actually fall in scope — many companies overestimate or underestimate their exposure without checking the specific category list.
Run a WCAG 2.1 AA conformance audit against your in-scope websites and apps — the EAA’s accessibility requirements for digital products closely track WCAG.
Prioritize remediation by which member states you have the most exposure in and which products carry the highest consumer volume, rather than trying to fix everything simultaneously.
Prepare (or update) your VPAT® / Accessibility Conformance Report — increasingly requested by EU B2B customers and procurement teams even outside direct regulatory enforcement.
The compounding risk: EAA exposure and WCAG-driven litigation risk (ADA-style, in markets like the US) increasingly overlap for companies selling internationally. A single, well-executed WCAG 2.2 AA remediation programme addresses both exposures at once rather than running separate compliance tracks.
This isn’t just a legal exercise
Companies that treat EAA compliance purely as risk mitigation miss the other half of the argument: EU accessibility compliance work, done properly, expands your addressable market in exactly the region you’re trying to sell into. The business case and the compliance case point the same direction.
Frequently asked questions
Does the EAA apply to companies outside the EU?
Yes, if you sell in-scope products or services to EU consumers — the Act applies based on where your customers are, not where your company is headquartered.
Is WCAG 2.1 AA sufficient for EAA compliance?
WCAG conformance is a strong foundation and closely aligned with the EAA’s digital accessibility expectations, but the EAA also covers non-digital requirements (hardware, kiosks, payment terminals) that WCAG doesn’t address. Full compliance requires looking at the specific harmonized standards referenced for your product category.
What’s the realistic timeline to go from non-compliant to compliant?
It depends heavily on how many products/services are in scope and how far from WCAG AA your current state is, but a focused remediation program for a single website or app typically runs two to four months from audit to verified fix, longer for a full product portfolio.
This is general guidance, not a scoped engagement plan. If you want one for your specific environment, talk to our Accessibility & Inclusive Product Engineering practice.