Yes, the European Accessibility Act (EAA) applies to websites and mobile apps when they deliver a product or service that falls within its scope. The law covers consumer-facing digital offerings like ecommerce, banking, transport booking, ebooks, and electronic communications. If your website or app serves consumers in the EU and delivers one of the in-scope services, it must meet the accessibility requirements set out in EN 301 549, which maps to WCAG 2.1 AA for web and mobile content. The EAA went into effect on June 28, 2025.
| Question | Answer |
|---|---|
| Does the EAA cover websites? | Yes, if the site delivers an in-scope service to EU consumers. |
| Does the EAA cover mobile apps? | Yes, when the app provides an in-scope service such as banking, ecommerce, or transport booking. |
| Which standard applies? | EN 301 549, which references WCAG 2.1 AA for web and mobile content. |
| Who is covered? | Businesses offering in-scope products or services to consumers in the EU. |
| Effective date | June 28, 2025. |
Which websites and mobile apps fall under the EAA?
The EAA does not apply to every website or app. It applies to those delivering a service listed in the regulation. That includes ecommerce stores selling to EU consumers, banking and payment services, ebook platforms and readers, passenger transport booking (air, bus, rail, waterborne), electronic communications services, and access to audiovisual media services.
If your website or app sits in one of these categories and serves consumers in the EU, the EAA covers you. A B2B-only SaaS product serving EU businesses is generally outside the consumer-service scope, though related obligations may still apply depending on the product category.
What accessibility standard do covered websites and apps need to meet?
EN 301 549 is the harmonized European standard referenced for digital accessibility under the EAA. For websites and mobile apps, EN 301 549 incorporates WCAG 2.1 AA success criteria. That is the practical target.
Meeting WCAG 2.1 AA means confirming conformance across perceivable, operable, understandable, and robust requirements. It is evaluated through a manual accessibility audit. Automated scans only flag approximately 25% of issues, so they cannot determine conformance on their own.
Are microenterprises exempt?
Microenterprises providing services are exempt from the EAA’s service-related requirements. A microenterprise is defined as fewer than 10 employees and annual turnover or balance sheet total not exceeding 2 million euros. The exemption applies to services, not products.
Most ecommerce stores, banks, transport operators, and app publishers do not qualify. If your business exceeds either threshold, the EAA applies.
What happens if a covered website or app does not conform?
Each EU member state sets its own enforcement and penalty structure. That can include fines, corrective orders, and in some cases removal of the product or service from the market. Authorities can audit covered entities, respond to consumer complaints, and require remediation within a defined timeframe.
The practical risk is twofold: regulatory action from member state authorities, and lost business from EU customers who expect accessible digital experiences.
How do you document EAA conformance?
Covered businesses are expected to publish accessibility information describing how their service meets the requirements. An accessibility statement on the website or app is the standard format. For products, a declaration of conformity and technical documentation are required.
An ACR based on the EN 301 549 edition of the VPAT template is the cleanest way to document the evaluation for procurement teams and regulators. The ACR is the completed report. The VPAT is the template used to produce it.
What steps make sense right now?
Start with scope. Confirm whether your website or app delivers an in-scope service and whether you serve EU consumers. Then conduct a WCAG 2.1 AA audit against EN 301 549 to identify issues. Remediation follows the audit, prioritized by user impact and risk. Publish an accessibility statement once you have a credible basis for the claims in it.
Frequently Asked Questions
Does the EAA apply to my US-based website if I sell to EU customers?
Yes. The EAA applies based on where the service is offered, not where the business is headquartered. A US ecommerce store shipping to EU consumers is covered if it falls within an in-scope service category and exceeds the microenterprise threshold.
Do internal business tools and B2B apps need to comply with the EAA?
The EAA focuses on consumer-facing services. Internal tools and pure B2B apps are generally outside the service scope. However, public sector procurement in the EU often references EN 301 549 independently, so B2B vendors selling to government buyers face similar requirements through a different path.
Is a WCAG 2.2 AA audit acceptable for EAA purposes?
EN 301 549 currently references WCAG 2.1 AA. A WCAG 2.2 AA audit covers everything in 2.1 AA plus additional criteria, so it satisfies the underlying requirement and positions you ahead of future updates to the standard.
How often should covered websites and apps be reevaluated?
An audit reflects a point in time. Any significant content change, redesign, or feature release can introduce new issues. A yearly audit cadence is reasonable for stable sites, with interim evaluations for major releases.
The EAA is not a light regulatory update. For in-scope websites and mobile apps, it sets a clear accessibility floor backed by member state enforcement. Knowing where your product sits in that scope is the starting point.
Contact Kris to discuss EAA conformance for your website or mobile app: Contact Kris.