European Accessibility Act: Preparing for June 2025
Actualizado: 2026-05-03
The European Accessibility Act[1] (EAA, Directive 2019/882) enters force on 28 June 2025. Approved in 2019 and transposed by member states over recent years, it’s an imminent reality. Many companies have it on the radar but haven’t acted. Others don’t know it applies to them. This article is a practical summary: who’s obligated, what it requires technically, and how to plan with enough margin.
What the EAA Is
The EAA harmonises accessibility requirements for products and services across the EU. The goal: people with disabilities can access digital and physical products and services without disproportionate barriers.
It’s not new in spirit — regulation on the public sector (WAD, Directive 2016/2102) already existed. The EAA extends those obligations to the private sector with binding deadlines. In Spain, Royal Decree 193/2023 articulates the transposition.
Which Products and Services It Covers
The list is extensive and sometimes surprising:
Products: Computers, smartphones, tablets and their operating systems; self-service terminals (ATMs, ticket machines, check-in kiosks); routers, set-top boxes, smart TVs; e-book readers.
Services: E-commerce; electronic banking; telecoms (calls, messaging, 112 emergency access); transport (online booking, info displays, e-tickets); e-books and reading software; audiovisual-media services — Netflix, Prime Video interfaces, similar platforms.
If your company has consumer e-commerce in Europe, the EAA affects you. If you have a banking app, it affects you. If you sell a SaaS consumers use in browsers, probably too.
Important Exceptions
- Micro-enterprises (fewer than 10 employees, below €2M turnover) are exempt in services — not in products.
- Disproportionate burden: unjustifiably costly adjustments vs benefit can be excepted, but with documented analysis. “Disproportionate” isn’t “I don’t want to do it”.
- Legacy infrastructure with limited scope may be partially excepted with solid justification.
Technical Requirements
Specific technical requirements are in EN 301 549, the European standard incorporating WCAG 2.1 AA[2] as base reference. Four pillars:
- Perceivable: content accessible across senses — alt text, captions, minimum contrast.
- Operable: keyboard navigation, no forced timing, no seizure-inducing content.
- Understandable: clear language, predictable behaviour, error assistance.
- Robust: compatible with present and future assistive technologies.
For most digital products this means: semantic HTML, correct ARIA roles, minimum 4.5:1 contrast for normal text, visible keyboard focus, video captions, and forms with clear labels and error messages.
Penalties in Spain
In Spain, Royal Decree 193/2023:
- Minor infractions: up to €50,000.
- Serious: €50,001 to €400,000.
- Very serious: €400,001 to €1,000,000.
Plus reputational risk from public audits. Consumer-association complaints over accessibility are already happening — volume will grow after June 2025.
The Most Common Mistake: Starting Late
Fixing deep accessibility issues takes months, not weeks:
- Full audit: 2-4 weeks for a mid-size product.
- Refactoring non-accessible components: 2-6 months.
- Re-testing and compliance documentation: 2-4 weeks.
Anyone starting in May 2025 won’t make it. The only viable strategy is starting now and prioritising by severity.
A Structured Phase Plan
Audit phase (first month): Automated tools — axe DevTools, WAVE, Lighthouse, pa11y — plus manual review of critical flows with real assistive tech: NVDA + Firefox on Windows, VoiceOver + Safari on Mac/iOS, TalkBack on Android. Output: prioritised issue list with real effort estimate. Automated audit covers 30-40% of issues; the rest needs human review. Budget both from the start.
Critical issues phase (months 2-5): Custom components without correct ARIA support; keyboard navigation across the full application; text and UI contrast; forms with labels, errors, and clear helpers.
Secondary flows and content (months 6-8): Images, videos, and PDFs; documentation and help centre; accessible transactional emails.
Final phase (month 9 onward): Full re-audit; testing with real users with disabilities — the most underrated and most useful step; formal compliance documentation.
Typical Mistakes
- Adding
aria-labeleverywhere without understanding it: bad ARIA is worse than no ARIA. - Depending only on automated tools: they cover a third of the problem.
- Ignoring PDFs: if you distribute commercial PDFs, they’re in scope too.
- Not training the team: without awareness, new development re-introduces the same problems.
- “Accessibility button” as solution: overlay widgets don’t meet the EAA and are being sued in the US and Europe.
Impact Beyond Compliance
Accessibility done well delivers: better SEO through semantic structure; better general UX for all users; larger addressable market (approximately 15% of users have some relevant disability); and technical resilience through enforced semantic HTML discipline.
Accessibility is an investment with return, not just a compliance cost.
Conclusion
The European Accessibility Act enters force in June 2025 and affects more companies than realise it. Preparation cost is manageable with enough margin; non-preparation cost scales exponentially near the date. The right approach: audit early, prioritise by real severity, train the team so accessibility is part of how they build — not a final layer. Companies that do this well will have a better product in all senses, not just law-compliant ones.
