Demystifying common EAA misconceptions that are putting UK businesses at risk

Ensuring your website meets the European Accessibility Act (EAA) of 28 June 2025 is both a legal necessity and an opportunity to improve user experience for everyone. Even if website accessibility sometimes feels technical or daunting, the benefits for your organisation and your customers are significant. Let’s clear-up some myths holding UK organisations back – and reveal how accessibility elevates User Experience while mitigating legal risks.

Building inclusive websites fosters brand loyalty

In recent years, website accessibility has become recognised as an essential component of many organisation’s Corporate Social Responsibility policies. With the introduction of the European Accessibility Act (EAA), ensuring your site is accessible by everyone has risen in importance from a moral imperative, to one with serious legal implications.

From the end of June 2025, businesses that have products or services available to EU countries, and have 10 or more employees with an annual turnover or balance sheet exceeding €2 million (€1 million in Italy) became legally liable if they do not meet the criteria of the EAA. By embedding strong accessibility principles into their websites, organisations not only fulfil their legal obligations, but also demonstrate a commitment to social responsibility and equal participation in society.

Avoid common misunderstandings around EAA compliance

Attempting to ‘wait out’ the EAA, rely on quick-fixes, or claim exemptions without robust evidence can expose you to significant legal and reputational risk. The safest and most responsible approach is to aim for full compliance as soon as possible, and treat accessibility as an ongoing commitment rather than a one-off project. Let’s clear up some common misconceptions to ensure you are set for EAA compliance.

EAA misconception 1: It doesn’t apply to my business as I’m in the UK

Some believe the EAA only affects EU-based companies, but it applies to any organisation operating in EU markets, including non-EU businesses targeting European customers. Only micro-enterprises (fewer than 10 employees and less than €2 million turnover) are exempt, and even this threshold is lower in some countries (for example, Italy sets the threshold at €1 million).

EAA misconception 2: I have until 2030 to comply, so there’s no rush

The EAA’s phased approach is often misunderstood. From 28 June 2025, all new products, services, and any existing ones that undergo substantial modifications must comply. The 2030 deadline only applies to legacy products and services that remain completely unchanged after June 2025. Any updates, even very minor ones like platform updates, or even light amends can reset the compliance clock and trigger immediate adherence to the EAA.

EAA misconception 3: Minor updates don’t count as substantial modifications

The EAA does not clearly define what constitutes a ‘substantial modification’ leaving many legal teams baffled! Consider that even small changes, such as fixing a spelling mistake, updating background code infrastructure, or adding a minor new feature may trigger EAA compliance requirements. Relying on ambiguity here is highly risky and not advised, as enforcement is open to interpretation by each EU member state.

EAA misconception 4: We can claim a disproportionate burden and be exempt

This clause is absolutely not a free pass! To claim disproportionate burden, an organisation must provide significant evidence that compliance costs are excessive relative to the benefits for disabled users, or that compliance would fundamentally alter the nature of the product or service. This process is complex, requires thorough documentation, and must be submitted to individual EU member state authorities for review. We strongly suspect that most claims will be rejected, unless costs are truly prohibitive and the impact on users is minimal.

EAA misconception 5: My accessibility testing tool proves I pass the EAA 

It’s a fact that automated accessibility testing tools cannot guarantee EAA compliance, often missing critical issues, or require significant expertise to validate and interpret results. Recent detailed studies identify that automated accessibility audits only identify around 57% of issues¹, and historical studies quote this as low as 30%. They often fail to assess context-sensitive requirements or the complexities of modern websites. Only expert auditing and UX experience reveals common failures such as logical navigation flows, or identify false positives that can divert resources from genuine barriers. Relying solely on automated reports puts your business at risk, and should not be relied on.

EAA misconception 6: Adding accessibility overlays or plugins will make my website EAA compliant 

Despite aggressive marketing and huge promises from third-party companies that provide such technologies – accessibility overlays, automated plugins or functionality you add to any existing site that add accessibility features are never a substitute for genuine accessible code and technology. The wider web accessibility community and EU Commission does not endorse this technology; no tool can guarantee compliance with WCAG or EN 301 549. They often fail to address complex accessibility issues, provide a poor user experience, and do not fulfil the EAA’s requirement for functional accessibility and universal design. Accessibility needs to be supported at code level, and by your content creators from start to finish. The irony is that these tools can actually create more accessibility issues than they solve!

EAA misconception 7: The EAA only applies to my website, not the downloads or media embedded in the site

The EAA explicitly covers all electronic documents and media (like downloadable PDFs, Word, PowerPoint, and embedded video and audio files). All new or modified files after the deadline must be accessible. Legacy content is only exempt if it remains absolutely unchanged; so, any update, however minor, triggers EAA compliance requirements.

EAA misconception 8: Accessibility is only controlled by developers, not my internal content creators

Whilst your web development team can build a visually engaging, highly accessible website; it’s vital that anyone publishing content to the website (for instance, through any content management system like WordPress) understands accessibility fundamentals. Whilst your developers should provide broader accessible functionality, content creators also need to implement accessibility best practice when creating content, media and downloads to maintain compliance. This is a fantastic opportunity to collaborate with your developers to upskill your internal team and get everyone invested in accessibility.

An opportunity to lead in your market segment

The 2025 deadline isn’t a finish line, but a starting point for organisations ready to lead. UK businesses targeting EU markets face a clear choice; treat accessibility as a last-minute compliance burden, or embrace it as a catalyst for growth. With an estimated 100 million Europeans facing daily digital barriers due to accessibility challenges¹, this is an opportunity to reach untapped markets and build customer loyalty.

As the EAA implementation evolves, your compliance journey must remain agile. EN 301 549 v4.1.1 is expected in late 2025, and we suspect that this will incorporate an uplift to meet WCAG 2.2 criteria. Regular audits, and strong technical support will help you adapt to new criteria and interpretation changes.

Collaborate with experts

Partnering with a specialist agency like Jask for accessibility audits and User Experience direction ensures you not only comply with the EAA, but provide a better digital experience for all users. With a clear strategy, bespoke processes and user-centred reasoning, you’ll be ready to serve your customers no matter the challenges they face in their lives.

Article reference sources

1) Deque – Automated testing study
2) European Commission – Web accessibility policies