European Accessibility Act (EAA): What It Is, Who It Applies To, and How to Be Compliant in 2026

TL:DR The EAA at a Glance

• What it is: A landmark EU directive harmonising accessibility requirements for key digital products and services.
• The Deadline: Enforcement began in June 2025, making 2026 the critical "risk window" for businesses still operating with legacy accessibility debt.
• Applicability: It applies to any business (including UK and US firms) selling products or services to consumers in the EU.
• The Standard: The presumptive benchmark for compliance is WCAG 2.2 AA.
• The Stakes: Non-compliance carries significant legal risks, potential fines (up to €250,000 in certain regions), and exclusion from public tenders.

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1. What Is the European Accessibility Act?

The European Accessibility Act (Directive 2019/882) is a legal framework designed to remove barriers for the 135 million people in the EU living with disabilities. Unlike previous regulations that focused primarily on the public sector, the EAA brings the private sector into the fold.

It is a "harmonising" directive. This means it provides a common set of rules for all EU Member States, ensuring that a website compliant in France is also compliant in Germany or Ireland. For digital leaders, it shifts accessibility from a "marketing feature" to a core pillar of infrastructure governance.

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2. When Does the EAA Apply? (The 2026 Timeline)

While the EAA was adopted years ago, the enforcement timeline is now active:

• June 28, 2025: The official date Member States began applying the measures. All new services and products placed on the market must be compliant.
• 2026 & Beyond: This is the operational reality phase. Regulatory bodies are now monitoring the market, and the "grace period" for legacy services is narrowing.
• June 2030: The final hard deadline for services using products already in use before 2025 (transition period).

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3. Who Must Comply with the EAA?

The most common misconception is that the EAA only applies to EU companies; this is incorrect. The EAA is market-based, not location-based.

You must comply if you are:

• A UK or Global Business: If you provide services or sell goods to EU consumers, you are in scope.
• An E-commerce Platform: Any online shop operating in the EU.
• A Service Provider: This includes banking, transport, e-books, and telecommunications.
• A Large Enterprise: Companies with 10+ employees and >€2m turnover are generally covered.

Important Note: Micro-enterprises (fewer than 10 employees and <€2m turnover) are often exempt from the full technical requirements of the EAA, though they are still encouraged to follow accessibility best practices to avoid "reasonable adjustment" claims under local laws.

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4. What Accessibility Standard Is Required?

While the EAA describes functional goals (making things perceivable, operable, etc.), the technical path to meeting those goals is defined by WCAG 2.2 AA.

The EU harmonised standard EN 301 549 points directly to WCAG. By meeting the 55 success criteria of WCAG 2.2 AA, you are effectively meeting the EAA’s requirements.

• Why 2.2? It is the most recent stable version, adding 9 new criteria (6 at Level AA) specifically focused on mobile interactions and cognitive disabilities.
• Why AA? Level A is too low for meaningful inclusion; Level AAA is often technically unfeasible for complex sites. Level AA is the "Goldilocks" zone of compliance.

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5. What WCAG 2.2 AA Requires (The Practical Checklist)

To be EAA-compliant, your Webflow site must address these core requirement groups:

Visual & Keyboard Operability

• Visible Focus: A user navigating via keyboard must clearly see where they are on the page.
• Focus Not Obscured: Sticky headers or overlays cannot hide the element currently in focus.
• 24x24px Targets: Interactive elements (buttons, icons) must be large enough for those with motor impairments.

Structure & Content

• Heading Hierarchy: Semantic $H1$ to $H6$ order for screen readers.
• Alt Text: Meaningful descriptions for images (not just keyword-stuffing).
• Consistent Help: If you have a help link or chatbot, it must be in the same place on every page.

Complex Interactions

• No Dragging-Only: If your site uses "drag to unlock" or sliders, there must be a single-click alternative.
• Accessible Authentication: You cannot rely solely on "cognitive tests" (such as puzzles or password memorisation) for logins without offering alternatives, such as biometrics or email links.

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6. How Does the EAA Affect UK Businesses?

Post-Brexit, the EAA is not part of UK law. However, the Equality Act 2010 already requires service providers to make "reasonable adjustments" to ensure disabled users are not disadvantaged.

In practice, the EAA sets the "ceiling" for accessibility. If your site is built to WCAG 2.2 AA to satisfy EU customers, it automatically exceeds the requirements of the UK Equality Act. For UK businesses, aligning with the EAA is the safest way to future-proof against local litigation.

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7. Does the EAA Apply to Webflow Websites?

Yes. Platforms like Webflow, Shopify, or WordPress are merely tools. The EAA is concerned with the output.

Webflow provides high-level accessibility tools (custom alt text, semantic tagging, etc.), but the developer is responsible for implementing them.

• Automated Overlays: Be cautious of "one-line-of-code" accessibility plugins. These often fail to satisfy legal requirements because they don't fix the underlying source code.
• Accessibility Debt: Most EAA risks are introduced during the design phase (low contrast) or the build phase (bad div structure).

Paddle Creative Insight: In Webflow audits, accessibility failures are rarely caused by missing settings – they’re caused by visual design decisions made before development even begins.

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8. Common Misconceptions

• "We don't have an EU office, so we're fine." (Wrong: If you have EU users, the law applies.
• "My site is accessible because I used a plugin." (Wrong: Overlays are often considered a "red flag" by regulators.
• "Accessibility is just for blind people." (Wrong: EAA covers cognitive, motor, and auditory impairments).

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9. How Do You Become Compliant with the EAA?

Compliance is a process, not a checkbox.

1. Applicability Audit: Determine if your traffic and revenue fall within EAA thresholds.
2. Technical Audit: Perform a manual and automated review against WCAG 2.2 AA.
3. Remediation: Fix structural issues (code) followed by content issues (alt text).
4. Accessibility Statement: Publish a transparent report on your site's status.
5. Ongoing Governance: Ensure new marketing campaigns don't break compliance.

Paddle Creative Insight: Automated tools only catch about 30% of accessibility issues. Real EAA compliance requires manual testing – especially for keyboard navigation and screen reader logic. In our experience, legacy "div-soup" builds are the #1 cause of EAA failure.

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Is your Webflow site ready for 2026?

Don't wait for a compliance audit to find out your site is a liability.

Book a call with Paddle Creative

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