How EAA Enforcement Works Across the EU

If you’re hearing more about the European Accessibility Act (EAA) lately, you’re not alone—and you’re right to be paying attention. With the June 28, 2025 enforcement date around the corner, many U.S. businesses are starting to wonder: Does this apply to us? Are we at risk if we’re not in compliance?

The short answer? Not necessarily—but that doesn’t mean you should ignore it.

The EAA is a major development in digital accessibility law for the European Union, and while it’s not a global regulation, it can impact U.S.-based companies that offer products or services to EU customers. For others, it’s simply a signal of where global accessibility expectations are headed.

This article breaks down what the EAA actually is, who needs to comply, how enforcement works, and how to determine whether it applies to your business. No panic, no guesswork—just the facts and a clear path forward.

Setting the Stage: What Is the EAA?

The European Accessibility Act (EAA) is an EU directive focused on improving digital and product accessibility for people with disabilities across member states. It’s designed to standardize accessibility expectations throughout the EU, ensuring equal access to services like banking, transportation, e-commerce, and more.

The law goes into effect on June 28, 2025, and several EU countries are already working to align their national laws accordingly. For companies operating in the EU, this is a significant compliance milestone.

But here’s the key point: The EAA only applies to businesses that actively do business in the European Union.

Who the EAA Applies To—and Who It Doesn’t

The EAA’s core goal is to eliminate digital accessibility barriers. Whether someone is shopping online, checking into a flight, reading an eBook, or using a mobile banking app, the EAA ensures people with disabilities in the EU can participate fully in everyday digital life.

Does the EAA Apply to U.S. Businesses?

In short: Only if you’re engaging directly with EU customers.

The EAA is not a global requirement. It’s meant for companies that:

Operate physically or digitally within the EU,
Market or sell directly to consumers in EU countries, or
Offer digital services like online platforms or mobile apps in the EU marketplace.

So, if your business has no EU offices, no EU-based clientele, and no intention to serve EU consumers, the EAA doesn’t apply to you.

What About Small Businesses?

Even within the EU, microenterprises—those with fewer than 10 employees and less than €2 million in annual revenue—are exempt. That’s important for U.S. startups and solopreneurs wondering if having a website puts them on the hook. It doesn’t.

What the EAA Actually Requires

If your organization does conduct business in the EU, here’s what compliance looks like:

Covered Products and Services

The EAA applies to a wide range of digital goods and services, such as:

Online marketplaces and e-commerce platforms
Mobile apps and websites
Digital banking interfaces and ATMs
Public transport booking systems
eBooks and reading devices
Ticketing machines and self-service kiosks

Accessibility Standards

Compliance requires aligning with EN 301 549, which references WCAG 2.1 Level AA—a familiar standard in the U.S.

That means your content and digital tools should be:

Perceivable: Understandable with assistive technologies
Operable: Usable with various input methods like keyboards
Understandable: Clear, predictable layouts and instructions
Robust: Functional across devices and platforms

Accessibility Statements

EAA-compliant websites and apps must also include an accessibility statement that communicates the site’s current accessibility status, outlines any known limitations, and provides a channel for users to request support or report issues.

How EAA Enforcement Actually Works

EAA enforcement isn’t handled at the EU level. Instead, each member state enforces the EAA independently, with its own authority, procedures, and penalty structures. That means the experience—and consequences—can vary from country to country.

Here are a few notable examples:

France: Handled by Défenseur des droits, with fines up to €250,000
Germany: Managed by BFIT-Bund and regional bodies; penalties from €10,000 to €500,000
Ireland: Overseen by the National Disability Authority; up to €60,000 in fines or imprisonment in serious cases
Italy: Governed by AgID; fines can reach €25,000
Spain: Managed by OADIS and regional authorities; penalties as high as €600,000

A Word to Multinational Businesses

If your business spans multiple EU countries, EAA enforcement can get complex. Each jurisdiction may interpret the directive differently, making early planning essential for smooth, consistent compliance.

What U.S. Businesses Should Actually Do

Now that you have a clearer picture, here’s how to assess your next steps.

1. Evaluate Your Exposure

Ask yourself:

Do you sell to or serve customers in the EU?
Do you offer a localized site or support EU languages?
Are your apps available in EU-based app stores?

If the answer is yes, EAA compliance is likely necessary. If not, you’re likely outside its scope—but staying informed is still a wise move.

2. Take Practical (Not Panicked) Steps

If you do engage with the EU market, now is the time to:

Audit digital products for WCAG 2.1 Level AA alignment
Fix known accessibility issues (navigation, color contrast, labeling, etc.)
Publish an accessibility statement
Document your efforts for accountability

And if you’re unsure where to start, bring in accessibility experts. The right support can help you avoid missteps, reduce liability, and stay aligned with country-specific EAA enforcement requirements.

3. Remember: Accessibility Is a Business Advantage

Even if the EAA doesn’t apply to you now, accessibility is still a smart investment. It can:

Broaden your customer reach
Improve usability and search engine performance
Build long-term brand trust and loyalty
Help you stay ahead of evolving legal and market expectations

And in the U.S., digital accessibility remains a legal risk under the ADA. Proactive improvements made today could save you from future challenges—at home and abroad.

Looking Ahead: Stay Aware, Not Alarmed

The European Accessibility Act represents a shift in global digital accessibility expectations—but that doesn’t mean every U.S. business needs to overhaul its operations overnight. If your company doesn’t operate in the EU or serve EU-based customers, this law likely doesn’t apply to you.

Still, moments like this are valuable reminders. They give forward-thinking businesses a chance to pause, evaluate, and strengthen their digital experiences—not just for compliance but for the real people who rely on accessible technology every day.

Whether you need to take immediate steps or want to stay ahead of future regulations, the smartest move is to stay informed and be proactive. Accessibility isn’t about reacting to legal threats—it’s about building resilient, inclusive digital experiences that serve everyone, everywhere.

Need clarity on where you stand or how to move forward? Let 216digital help you navigate accessibility with confidence and purpose.