The European Accessibility Act (Directive (EU) 2019/882) isn't a future deadline anymore. Member states had until 28 June 2022 to transpose it into national law, and the compliance obligations themselves became enforceable on 28 June 2025. If your business sells digital products or services to consumers in the EU, and you haven't run an accessibility check against it, this is the checklist to work through this quarter, not next year.
We've covered how enforcement is actually playing out country by country in our roundup of EAA enforcement in 2026. This piece is the other half: the practical, in-scope checklist to work through before enforcement finds you.
1. Confirm whether you're actually in scope
The EAA applies to specific categories of products and services sold to consumers in the EU, regardless of where the company itself is based. The categories most relevant to a typical website or app include:
- E-commerce (any site selling goods or services to EU consumers)
- Banking and consumer financial services
- E-books and dedicated e-reader software
- Telecommunications services, including messaging and video calling apps
- Passenger transport services: ticketing, check-in, and journey information
Small businesses (under 10 employees and under €2 million in annual turnover) have a "microenterprise" exception for some obligations, but this exception is narrower than most companies assume, and it doesn't apply to every category. If any meaningful share of your revenue comes from EU consumers, don't assume you're exempt without checking.
2. Treat WCAG 2.1 AA as your technical baseline
The EAA doesn't invent a new technical standard. In practice, conformance is measured against EN 301 549, the EU's accessibility standard for ICT, which for web content maps directly onto WCAG 2.1 Level AA. If your site already meets WCAG 2.1 AA (or better yet, WCAG 2.2 AA), you're covering the vast majority of the technical requirement.
3. Audit the purchase and account flows first
Regulators and plaintiffs alike focus on the transactional path, not the blog. Prioritize:
- Product browsing and search
- Cart and checkout, including payment fields
- Account creation and login
- Order confirmation and support contact
A beautifully accessible homepage sitting in front of an inaccessible checkout form is still a real compliance gap, and it's the one most likely to generate a complaint.
4. Make customer service and support channels accessible too
The EAA explicitly covers the information and support that accompanies a product or service, not just the storefront. That means your accessibility statement, help center, and any chat or contact form need to be usable with a keyboard and a screen reader, not just your product pages.
5. Publish (or update) your accessibility statement
A public accessibility statement describing your conformance status, known limitations, and a contact method for accessibility complaints is expected practice under the EAA, mirroring the approach already required under the EU Web Accessibility Directive for public sector sites. If yours is more than a year old or was written before your last redesign, it's due for a rewrite.
6. Get a documented conformance record (VPAT/ACR)
Enterprise EU customers and procurement teams increasingly ask for a documented conformance report before signing a contract. A VPAT/ACR gives you a standard format to state exactly what you conform to and where the gaps are, which is far stronger evidence of good faith than a verbal claim.
7. Build in regression testing, not a one-time fix
Accessibility conformance degrades the moment a new feature ships without a check. Bake automated scanning into your CI pipeline and schedule a periodic manual review, especially after redesigns, new checkout providers, or third-party embeds.
8. Know your national enforcement body
Each EU member state designates its own market surveillance authority for EAA enforcement, and the penalties and process differ by country, as we cover in the enforcement roundup. If a meaningful share of your customers are concentrated in one or two EU countries, know which authority handles complaints there before you need to.
What actually happens if you ignore it
The EAA doesn't set one EU-wide fine schedule; instead, each member state writes its own penalties into its national transposition law, which is part of why the practical risk varies so much by country and why we track it separately in the enforcement roundup. What's consistent across the EU, though, is the enforcement mechanism itself: a market surveillance authority can investigate a complaint, request evidence of conformance, and require corrective action within a set timeframe. A documented VPAT/ACR and a recent audit are exactly the evidence that authority will ask for first, and having neither is what turns a routine complaint into a drawn-out one.
A common misconception worth clearing up
Plenty of US-based companies read "European Accessibility Act" and assume it only applies to businesses with a European legal entity or an EU-hosted website. It doesn't. The EAA applies based on where your consumers are, not where your company is incorporated or your servers sit. A US ecommerce brand shipping to customers in Germany or France is in scope in the same way a Berlin-based retailer is. If your analytics show meaningful EU consumer traffic or transactions, scope is a question of "which categories," not "whether."
Where to start this week
If you sell into the EU and haven't checked your site against this list, start with the checkout flow and your accessibility statement, the two most commonly missing pieces. For companies specifically working through EU-facing compliance, our EAA compliance solutions page walks through the full remediation path.
The fastest way to know exactly where you stand is a real audit. Get a free accessibility audit and get a clear, prioritized gap list against WCAG 2.1 AA and the EAA, not a guess.