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

The Web Content Accessibility Guidelines (WCAG) have gone through several iterations. Each of them brings tighter definitions and broader requirements. 

WCAG 2.0 laid the foundation. WCAG 2.1 added enhancements for mobile interaction and improved support for users with low vision and cognitive disabilities. 

The current version, WCAG 2.2, brings 9 additional success criteria that close key gaps in navigation, mobile device interaction, and control visibility. These additions reflect feedback from real-world usage across multiple disability groups.

EN 301 549 takes these guidelines and defines how they should apply to real-world digital systems in the EU. It ensures consistency in public procurement and helps organizations interpret WCAG requirements within their industry or platform type.

Although WCAG 3.0 is still in development, it outlines a shift toward performance-based assessment. This future model will likely emphasize flexibility, with scoring methods that assess how well users can complete tasks rather than just verifying individual components. 

Understanding the changes in the guidelines supports smarter system design going 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 strict. 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 fixed 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 aimed at improving accessibility for users with cognitive and motor impairments, and 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, especially on mobile.

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

– Redundant Entry (3.3.7): Users don’t 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 perform better across assistive technologies and device types.

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

– Audit all digital interfaces: Identify where the current user experience falls short of WCAG 2.2 and EN 301 549.

– Fix critical issues first: Prioritize problems that impact navigation, content access, and assistive technology compatibility.

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

– Use the right tools: Automated testing solutions can speed up detection, but manual testing is still necessary, especially for evaluating interactions, content flow, and visual structure.

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

This approach creates a sustainable path to compliance while improving usability across your audience.

WCAG 3.0 is set to change how accessibility will be measured. 

Instead of 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 different types of disabilities.

Businesses can prepare by moving toward accessibility strategies that focus on the overall user experience. This includes testing for task completion, reducing reliance on one-size-fits-all components, and applying accessibility considerations across full user journeys.

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

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

But beyond compliance, accessible platforms work better for everyone. They offer smoother navigation, clearer communication, and better performance across devices.

An accessible product also reaches a wider audience. People using assistive tools, aging users, or customers in non-standard environments all benefit from thoughtful design. These improvements help businesses serve more users without changing their core offering.

Accessibility also builds credibility. When users see that a platform works for them, trust grows along with the company’s reputation for quality and responsibility.

The June 28, 2025, deadline places accessibility at the top of the agenda for any organization offering digital services in the EU. This is the time to audit platforms, update design processes, and build internal capabilities that support accessibility at every stage.