What the European Accessibility Act Means for Your Digital Platforms in 2025

The Web Content Accessibility Guidelines (WCAG) have undergone several iterations. Each iteration introduces more stringent definitions and broader requirements. 

WCAG 2.0 established the groundwork. WCAG 2.1 incorporated enhancements for mobile interaction and improved support for users with impaired vision and cognitive disabilities. 

The current version, WCAG 2.2, introduces 9 additional success criteria that address key shortcomings in navigation, mobile device interaction, and control visibility. These additions are informed by feedback from practical application across various disability groups.

EN 301 549 adopts these guidelines and specifies how they should be applied to real-world digital systems within the EU. It ensures uniformity in public procurement and assists organisations in interpreting WCAG requirements within their specific industry or platform type.

Although WCAG 3.0 is still under development, it indicates a move towards performance-based assessment. This future model will likely prioritise flexibility, with scoring methodologies that evaluate how effectively users can complete tasks, rather than simply verifying individual components. 

A thorough understanding of the changes in the guidelines facilitates more informed system design moving forward.

The European Accessibility Act (EAA) sets legally binding standards for a wide range of products and services, including:

• E-commerce platforms and mobile apps
• Digital banking tools and ATMs
• Websites and booking systems for transportation services
• Computers, smartphones, and their operating systems
• E-book readers and streaming service platforms

If you offer any of these services within the EU, your platform needs to meet the technical standard EN 301 549, which is built on WCAG 2.2 Level AA.

There are a few exemptions. The most straightforward is for micro-enterprises, defined as service providers with fewer than 10 employees and an annual turnover or balance sheet below €2 million. 

Additionally, a business may claim that meeting a particular requirement creates a disproportionate burden, though this requires a formal, documented assessment and does not grant a blanket waiver from all other accessibility obligations. 

Another limited exemption exists for cases where accessibility changes would fundamentally change what the product or service does.

For most businesses, however, these narrow exceptions don’t apply, so they require immediate action to meet the EAA criteria.

Enforcement of the EAA is handled by designated authorities within each EU member state. This means penalties for non-compliance vary by country and are determined by national law. As a result, there is a varied list of penalties across the Union.

The financial repercussions for failing to comply can be severe. For example, authorities in Germany can issue penalties of up to €100,000 for significant violations. 

In other jurisdictions, the consequences can be even more stringent. In Ireland, failure to meet the requirements can result in criminal charges. This could lead to substantial fines for the company and potential imprisonment for directors and other liable officers.

Beyond monetary fines, national authorities can take direct market action to protect consumers. They can demand that a non-compliant service be rectified within a reasonable timeframe. 

If a business fails to implement the necessary measures, authorities can order the withdrawal of a product from the market or prohibit a digital service from operating, effectively halting business activities.

Moreover, the EAA helps consumers and advocacy groups to become active participants in its enforcement. The directive ensures that users can report non-compliance to the relevant national authorities. 

A reported issue can trigger official investigations and subsequent legal action. This adds a layer of public accountability and increases the risk for businesses that neglect their accessibility obligations.

WCAG 2.2 introduces nine additional success criteria designed to improve accessibility for users with cognitive and motor impairments, as well as users on mobile devices.

Some of the most significant changes include:

– Focus Appearance (2.4.11): Focus indicators must be clearly visible for users relying on keyboard navigation.

– Dragging Movements (2.5.7): Interfaces must offer alternatives to dragging for users with limited motor control.

– Target Size (2.5.8): Interactive elements need to meet a minimum size to reduce misclicks, particularly on mobile devices.

– Consistent Help (3.2.6): Help options must be available in a predictable manner across different pages.

– Redundant Entry (3.3.7): Users should not have to re-enter the same information multiple times during a single process.

These additions align with current interaction patterns and address usability gaps that affect a wide range of users. Ensuring support for these criteria helps systems to perform better across assistive technologies and device types.

To align with current accessibility standards, businesses should adopt a focused approach:

– Audit all digital interfaces: Identify areas where the current user experience does not meet WCAG 2.2 and EN 301 549 standards.

– Address critical issues first: Prioritise problems that affect navigation, content access, and compatibility with assistive technology.

– Integrate accessibility into your workflow: Ensure designers, developers, and QA teams incorporate accessibility checks at every stage.

– Employ appropriate tools: Automated testing solutions can expedite detection, but manual testing remains necessary, particularly for evaluating interactions, content flow, and visual structure.

– Test across real devices: Screen readers, keyboard-only navigation, and mobile devices should all be included in your evaluation process.

This approach establishes a sustainable route to compliance while enhancing usability for your entire audience.

WCAG 3.0 is poised to change how accessibility is measured. 

Rather than assessing compliance at the level of individual elements, the new model introduces broader scoring and outcome-based evaluations. This approach focuses on how content performs in practice for users with differing disabilities.

Organisations can prepare by transitioning towards accessibility strategies that focus on the overall user experience. This includes testing for task completion, reducing reliance on standardised components, and applying accessibility considerations across complete user journeys.

An early adoption of these practices will reduce future rework and establish stronger foundations for long-term accessibility governance.

Investing in accessibility supports long-term business value. It reduces the risk of fines or commercial limitations under the European Accessibility Act.

Beyond compliance, however, accessible platforms function more effectively for all users. They provide smoother navigation, clearer communication, and improved performance across devices.

An accessible product also reaches a broader audience. Individuals utilising assistive technologies, older users, or customers in non-standard environments all benefit from considered design. These enhancements enable businesses to serve a greater number of users without altering their core offering.

Accessibility also enhances credibility. When users observe that a platform functions effectively for them, trust increases, along with the company’s reputation for quality and responsibility.

The deadline of 28th June 2025 places accessibility at the forefront for any organisation offering digital services within the EU. Now is the time to audit platforms, update design processes, and develop internal capabilities that support accessibility at every stage.