✅ EAA Compliance 📅 March 25, 2026 ⏱ 8 min read

EAA Compliance Checklist 2026: Is Your Website Ready for the European Accessibility Act?

The European Accessibility Act (EAA) has been enforceable since June 28, 2025. If your website serves customers in the EU, you're legally required to meet WCAG 2.1 Level AA standards — or face fines up to €250,000. Use this checklist to find out exactly where you stand and what to fix first.

⚠️ Important disclaimer: This checklist covers the most impactful EAA requirements. Automated tools (including AccessPatch) detect approximately 40–60% of WCAG issues. Full compliance requires a manual audit by an accessibility specialist. This checklist is a strong starting point, not a legal guarantee of compliance.

Who Does the EAA Apply To?

The EAA applies to businesses that provide products or services to EU customers — regardless of where the business is located. This includes e-commerce stores, SaaS platforms, booking systems, online banking, and any digital service used by EU residents.

The only exemption is for micro-enterprises: businesses with fewer than 10 employees and annual turnover below €2 million. If your business exceeds either threshold, you must comply.

Business Type	EAA Coverage	Risk Level
E-commerce (EU consumers)	✅ Fully covered	🔴 Very High
SaaS / Software (EU B2B)	✅ Fully covered	🔴 High
Online banking / FinTech	✅ Explicitly named	🔴 Very High
Travel / booking platforms	✅ Explicitly named	🟠 High
Information/blog websites	⚠️ Partially covered	🟡 Medium
Micro-enterprises (<10 staff, <€2M)	🟢 Exemption possible	🟢 Low

The Complete EAA Compliance Checklist

This checklist is organized into four categories. Work through each one systematically. Critical issues are the highest priority — these are most likely to trigger complaints.

Category 1 — Perceivable Content (Can users perceive all information?)

All images have descriptive alt text Critical

Every <img> element must have an alt attribute. Decorative images use alt="". Screen reader users cannot perceive images without alt text.

Videos have captions and audio descriptions Critical

All pre-recorded video content must include synchronized captions. Live video streams must have live captions. Audio descriptions required for video-only content.

Color is not the only means of conveying information Serious

Error messages, status indicators, and charts must not rely on color alone. Add icons, patterns, or text labels alongside color coding.

Text has sufficient color contrast (4.5:1 ratio minimum) Serious

Normal text requires a contrast ratio of at least 4.5:1 against its background. Large text (18px+ bold or 24px+ regular) requires 3:1. Use a contrast checker tool to verify.

✓

Text can be resized to 200% without loss of functionality Moderate

Users who increase browser text size to 200% should still be able to use all features and read all content without horizontal scrolling.

✓

Page language is declared in the HTML <html lang="..."> Serious

The lang attribute on the <html> element must correctly identify the page language. Screen readers use this to select the correct pronunciation engine.

Category 2 — Operable Interface (Can users operate all controls?)

All functionality is accessible by keyboard only Critical

Every interactive element — buttons, links, forms, modals, dropdowns — must be reachable and usable with Tab, Enter, Space, and arrow keys. No mouse required.

Visible keyboard focus indicator on all interactive elements Critical

When a user tabs to a button or link, there must be a clearly visible focus outline. Do not use CSS "outline: none" without providing an alternative focus style.

Skip navigation link at top of every page Serious

A "Skip to main content" link must appear as the first focusable element on every page. This lets keyboard users bypass repeated navigation menus.

✓

No content flashes more than 3 times per second Critical

Flashing content can trigger seizures in users with photosensitive epilepsy. Avoid flashing animations or provide a way to pause/stop them immediately.

✓

Users can pause, stop, or hide moving/auto-updating content Moderate

Carousels, auto-playing videos, and live-updating feeds must have a pause/stop mechanism. Content that moves for more than 5 seconds must be controllable.

✓

Session timeouts provide sufficient warning and a way to extend Moderate

If your site times out logged-in sessions, users must be warned before the timeout and given at least 20 seconds to extend the session.

Category 3 — Understandable Structure (Is the content clear and predictable?)

All form inputs have programmatic labels Critical

Every form field must have an associated <label> element, or an aria-label / aria-labelledby attribute. Placeholder text alone is not sufficient as a label.

Form errors are clearly identified and described in text Critical

When a form submission fails, the error must be described in text (not just color) and associated with the specific field that caused the error.

✓

Page titles are descriptive and unique for each page Serious

Each page's <title> tag must describe the page's topic or purpose. "Home" or "Page 1" are not compliant. Screen reader users hear the title when a page loads.

✓

Headings are used in logical order (H1 → H2 → H3)

One <h1> per page. Subheadings use H2, H3 in nested order. Do not skip heading levels (e.g., H1 directly to H4). Headings create document structure for screen readers.

✓

Navigation is consistent across pages Moderate

Menu items should appear in the same order and location on every page of the website. Unpredictable navigation is disorienting for cognitive and motor-impaired users.

✓

Links have descriptive text — no "click here" or "read more" Serious

Link text must describe the destination or purpose. Screen reader users often navigate by listing all links on a page — "click here" × 10 is completely useless to them.

Category 4 — Robust Technical & Legal Requirements (EAA-specific)

Accessibility Statement published on your website Critical

The EAA explicitly requires a published Accessibility Statement. It must describe your compliance level, known limitations, contact details for accessibility feedback, and your enforcement body. This is the single most important legal document.

User feedback mechanism for accessibility issues Critical

Users must have a way to report accessibility barriers — typically a contact form or email address linked from your Accessibility Statement. The EAA requires you to respond to these requests.

HTML is valid and parseable by assistive technologies Serious

Elements must have complete start and end tags. IDs must be unique. ARIA attributes must be used correctly. Broken or malformed HTML causes assistive technologies to fail unpredictably.

ARIA roles and attributes are used correctly Serious

aria-label, role, aria-expanded, and similar attributes help screen readers understand custom UI components. Incorrect use of ARIA is worse than no ARIA — test with actual screen readers.

Automated accessibility scan completed and results tracked Moderate

Run a WCAG scanner (such as AccessPatch, axe, or WAVE) on all key pages. Document findings and maintain a remediation log showing ongoing improvement efforts.

✅ Do Items 1–16 Automatically

AccessPatch scans your website, auto-fixes the most common WCAG violations, and generates your legal Accessibility Statement — all with one line of JavaScript.

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Priority Order: Where to Start

If you're just getting started, focus on the Critical items first — these are the issues most likely to trigger formal complaints and are the easiest for enforcement bodies to verify. Then work through Serious and Moderate issues.

Priority	Items to Fix First	Estimated Fix Time
🔴 Critical	Alt text, form labels, keyboard access, Accessibility Statement, feedback mechanism	1–5 days
🟠 Serious	Color contrast, focus indicators, skip link, error messages, link text, page titles	1–2 weeks
🟡 Moderate	Captions for videos, session timeouts, animation controls, ARIA correctness	2–4 weeks
🟢 Total: Level AA	All 78 WCAG 2.1 AA success criteria	Ongoing

Automated vs. Manual Testing

Automated tools are fast and cost-effective — they can catch common issues like missing alt text, color contrast failures, missing form labels, and page structure problems. However, they have significant limitations:

Automated tools detect approximately 40–60% of WCAG issues
They cannot assess whether alt text is meaningful — only whether it exists
They cannot test the actual experience of using a screen reader or keyboard navigation
Complex custom UI components (modals, date pickers, custom dropdowns) require manual testing

✅ Best Practice: Use automated scanning as your continuous baseline (run on every page, every week), then schedule manual audits by a specialist at least once per year or after major redesigns. Automated tools show you're making effort — manual audits prove you're actually accessible.

The Accessibility Statement — Your Most Important Document

Of all the items on this checklist, the Accessibility Statement carries the most legal weight. It must include:

Your compliance status — fully compliant, partially compliant, or non-compliant
Known non-accessible content — specific areas that are not yet compliant and why
Contact information — how users can report accessibility barriers
Enforcement body — the national authority users can escalate complaints to
Date of last review — showing the statement is actively maintained

Publishing a clear, honest Accessibility Statement — even if your site is not yet fully compliant — demonstrates good faith and significantly reduces your enforcement risk.

Frequently Asked Questions

When did the EAA become enforceable? ▼

The European Accessibility Act became enforceable on June 28, 2025 for most products and services. EU member states were required to transpose the directive into national law by June 28, 2022, giving businesses a 3-year transition period.

Does the EAA apply to my website if I'm based outside the EU? ▼

Yes. The EAA applies based on where your customers are located, not where your business is. If you sell products or services to EU residents, your website must comply. A US, UK, or Australian business serving EU customers is fully covered.

What's the difference between the EAA and WCAG? ▼

WCAG (Web Content Accessibility Guidelines) is a technical standard produced by the W3C. The EAA is EU law that mandates businesses meet WCAG 2.1 Level AA as the minimum standard. The EAA also adds legal requirements — like the Accessibility Statement and feedback mechanism — that WCAG does not cover.

Can I use an automated tool to become EAA compliant? ▼

Automated tools significantly accelerate compliance — they can auto-fix the most common WCAG violations and dramatically reduce your risk. However, they cannot achieve 100% compliance on their own. Use automated tools as your first layer, then complement with manual testing for complex components and custom UI.

How long does it take to become EAA compliant? ▼

For a typical business website with moderate complexity, automated fixes can resolve the most common issues within hours. Full manual remediation typically takes 2–8 weeks depending on the size and complexity of your site. Compliance is then maintained on an ongoing basis.

What if I'm a small business — am I exempt? ▼

Only "micro-enterprises" are exempt — businesses with fewer than 10 employees AND annual turnover below €2 million. If your business exceeds either threshold, you are not exempt. Even micro-enterprises are encouraged to comply where possible.

Check Your Website Against This Checklist

AccessPatch runs an automated WCAG scan on your website and auto-fixes the most critical issues. Get your compliance score in minutes — and your Accessibility Statement generated instantly.

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