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The European Accessibility Act became enforceable on 28 June 2025, and the first six months produced sanction files in Spain, Germany and the Netherlands along with several forced mass-remediation projects. Directive 2019/882 covers consumer-facing products and services, and the technical bar regulators apply is EN 301 549, which takes WCAG 2.1 level AA as its baseline.
Accessibility overlays were sold as a magic fix for WCAG and the European EAA directive in one step. In 2025 lawsuits against them have grown and disabled users are speaking out more critically than ever. A look at why they fail and what to do instead.
WCAG 2.2 (W3C, October 5, 2023) adds 9 criteria to WCAG 2.1: Target Size requires clickable targets of at least 24 by 24 pixels, and Accessible Authentication bans logins that require memorising complex passwords without an alternative. Upgrading from 2.1 AA typically takes 1 to 2 sprints for a medium-size product.
The European Accessibility Act takes effect in June 2025 and covers more products than most teams expect. What actually changes, who is legally obliged to comply, what WCAG 2.1 asks for in practice, and how to plan the work with enough margin to arrive ready.
