The European Accessibility Act (EAA) is creating significant concern and confusion, with a reported around 45% of organisations unsure if the EAA applies to them1. Many UK business owners are asking a crucial question: does this EU legislation actually apply to their websites post-Brexit? The answer might surprise you – and it could have substantial implications.
What is the EAA?
The European Accessibility Act (EAA) is an EU directive that came into force on the 28th of June 2025. It establishes legally binding accessibility requirements for products and services sold within the European Union, including websites, mobile apps, e-commerce platforms, banking services and digital content. It aims to harmonise inconsistent accessibility standards across all member states, reducing fragmentation and ensuring everyone can use digital platforms regardless of ability or technology.
While this article focuses on websites, the EAA also covers software applications, physical devices and customer-support channels such as live-chat or email systems that must accommodate assistive technologies. To comply, websites must meet the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA criteria, and adhere to the detailed technical specifications set out in EN 301 549.
It’s worth noting that we are advising clients to adhere to the more recent Web Content Accessibility Guidelines (WCAG) 2.2 Level AA criteria, as we feel the EAA is likely to be revised to include this.

Understanding the EAA’s reach beyond EU borders
Despite Brexit, UK companies that serve EU customers must comply with its requirements if they meet the operating criteria. If your products or services are available to, or sold to consumers within the EU, the EAA likely affects you; it doesn’t matter where your business is registered or located. When it comes to your website, if it processes transactions, provides digital services, or as is the case with most businesses – simply markets its products to EU residents; compliance became mandatory from 28th June 2025 if your business meets the following criteria:
- 10 or more employees AND
- annual turnover exceeding €2 million OR
- annual balance sheet total exceeding €2 million
Businesses classed as ‘Microenterprises’ (those with fewer than 10 employees AND less than €2 million turnover/balance sheet) can be exempt from service requirements. However, member countries of the EU are able to interpret the EAA individually, or vary compliance requirements; for instance Italy has reduced this threshold to €1 million.
We’ll be touching upon other tips and more subtle criteria in future content we publish, but you should be aware that there are broader compliance requirements that may affect not just your website, but the products you provide. For instance, the EAA also applies to downloadable documents, other supporting digital media like videos and audio downloads, and even software you’ve developed.
Navigating the EAA’s complexity
Each EU member state has the freedom to interpret and implement the EAA differently, creating a complex landscape of varying enforcement mechanisms and penalties. Individual countries maintain autonomy over penalty structures and enforcement approaches, making comprehensive compliance challenging without ongoing monitoring of legislative developments across the current 27 EU jurisdictions.
We’ve been monitoring this situation closely for many months, and suspect that in due time there will be a more unified, easier to understand approach to this. However, this complexity underscores the importance of staying informed about evolving requirements and seeking professional guidance for compliance strategies. We suspect that the main EAA technical criteria will mostly be consistently interpreted by all member states, and the main variance will be around implementation and penalties.

The business case for accessibility goes beyond compliance
The EAA represents both challenge and opportunity. Whilst compliance is non-negotiable for businesses serving EU markets who meet the criteria, the broader benefits of great accessibility are an expanded market reach, and improved brand reputation, making this investment worthwhile regardless of regulatory requirements.
The real opportunity lies in understanding the untapped market potential of great accessibility. According to research conducted by Scope, the total spending power of families with at least one disabled person is estimated at £274 billion a year3. Research also shows that 69% of disabled users with access needs click away from inaccessible websites2.
A strong approach to accessibility isn’t just about doing the right thing morally, or even mitigating legal risks; it’s about accessing a substantial customer base that many businesses are inadvertently excluding.
Accessibility enhances user experience for everyone
When websites meet accessibility standards, the benefits extend far beyond meeting the needs of users who face physical or mental challenges in their lives. User experience fundamentals like clear navigation, good colour contrast, and logical content structure improve usability for all visitors. Screen reader compatibility requires well-structured HTML, which can also benefit search engine optimisation. Even things like captions and transcriptions can help those in noisy environments or with limited internet access.
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Article reference sources
1) AbilityNet – Attitudes to Digital Accessibility 2024
2) Scope – Disability facts and figures
3) Freeney Williams Ltd – The Click-Away Pound Report 2019