The European Accessibility Act (EAA) – New Digital Accessibility Requirements from 2025

The European Accessibility Act comes into force on 28 June 2025. The law introduces common EU requirements for digital accessibility to make digital products and services easier to use for everyone. This article explains the purpose and significance of the law, reviews the WCAG 2.1 standard and EN 301 549, and provides practical advice for businesses on how to comply with the requirements.

Purpose and Significance of the Law

The new accessibility law aims to make digital content and electronic services accessible to all citizens across the EU. In short, it should be easier for people with disabilities to shop online and use digital services in everyday life. When the law comes into force on 28 June 2025, “the internet will truly be open to all” – meaning far more people will be able to use websites, apps, and electronic products without barriers. The initiative stems in part from the EU’s desire to eliminate differences between member states’ requirements and ensure equal access to the digital single market. The law is also expected to benefit up to 15–20% of the population who currently struggle to use digital solutions due to disabilities or reduced functional abilities.

The law (officially based on EU Directive 2019/882, also known as the European Accessibility Act) sets out a number of specific accessibility requirements that all affected products and services must meet. In Denmark, the directive is implemented through the Act on Accessibility Requirements for Products and Services (often simply referred to as the “Accessibility Act”). These requirements include web content, user interfaces, self-service terminals, etc., and are largely based on existing web accessibility standards such as WCAG 2.1. In this way, the EAA continues the principles from earlier rules for public websites but expands them to also include many private actors and products.

Who Is Covered by the Law?

The Accessibility Act applies to a wide range of digital products and services, especially those targeted at consumers. Both private companies and public providers must comply with the law if they offer the following types of products/services:

• E-commerce and websites: Webshops and online services where consumers can purchase goods or services online.
• Transport and ticketing: Ticketing systems, travel booking, and self-service solutions within transportation (e.g., train or flight tickets).
• Self-service terminals: Information screens, ATMs, and other interactive terminals for public use.
• Banking, payments, and insurance: Online banking, mobile banking, and other consumer-facing financial services.
• E-books and media content: Digital books, e-reader devices, and associated reading software.
• Computers, smartphones, and OS: Consumer computer equipment (PCs, smartphones, tablets) as well as their operating systems and standard software.

The law also covers certain physical products with a digital interface – for example, smart TVs, card terminals, etc. – which must meet accessibility requirements in their operation.

Exemptions: Certain content types are specifically exempt from the requirements. For example, the requirements do not apply to videos, audio, or PDF documents published before the cut-off date of 28 June 2025. Also exempt are pure online map services (without navigation functionality) and embedded third-party content that the company does not control. Furthermore, micro-enterprises (companies with fewer than 10 employees and under EUR 2 million in annual turnover) are exempt from the law.

Transitional arrangements: Service providers who deliver services using products that were lawfully used for providing services before June 28, 2025, may continue to deliver equivalent services using those products until June 28, 2030. This means that products already in use for delivering services before June 28, 2025, may continue to be used for that purpose until June 28, 2030, without having to comply with the new accessibility requirements. This provides businesses with a five-year transitional period to adapt to the new regulations.

Consequences of Non-compliance: It is important to note that enforcement and sanctions accompany the legal requirements. After 28 June 2025, a product or service may not be marketed or offered in the EU if it does not meet the relevant accessibility requirements. Authorities can order non-compliant products to be removed from the market. In addition, violations may lead to fines – in Denmark, fines are expected to be around DKK 50,000 per violation. In short, businesses that do not comply with the EAA risk having their digital product or service either banned or financially penalised.

WCAG 2.1 – Web Accessibility Guidelines (A, AA, AAA)

A central part of meeting the accessibility requirements is following the WCAG 2.1 (Web Content Accessibility Guidelines 2.1) standard. WCAG is an international set of guidelines for making web content and apps accessible to people with various types of disabilities. WCAG 2.1 is based on four core principles – content must be perceivable, operable, understandable, and robust. These principles are translated into concrete requirements (“success criteria”) divided into three compliance levels: A, AA, and AAA. Level A is the most basic (lowest) level of accessibility requirements, covering the most essential barriers. Level AA includes all A requirements plus additional criteria considered to provide a high level of accessibility. AAA is the highest level with the most ambitious requirements – it includes all A and AA requirements plus further advanced accessibility criteria.

In practice, level AA is typically the target for legislation and public standards, as AA-level balances comprehensive accessibility with the practicality of implementation. For example, existing EU rules for public websites require compliance with WCAG 2.1 at level AA. Similarly, the EAA is widely expected to be fulfilled by digital solutions meeting WCAG 2.1 AA. Companies should therefore aim for at least AA-level in their websites, webshops, mobile applications, etc. Striving for AAA can further improve accessibility, but it is voluntary and often difficult to fully achieve.

WCAG 2.1 Success Criteria

In this section, we have attempted to list the success criteria for WCAG 2.1 at levels A, AA, and AAA.
W3 has a more detailed article if you want more information.

WCAG 2.1 Success Criteria – Level A

• 1.1.1 Non-text Content: Provide text alternatives for non-text content.
• 1.2.1 Audio-only and Video-only (Prerecorded): Provide alternative content for prerecorded audio and video.
• 1.2.2 Captions (Prerecorded): Provide captions for prerecorded audio content in synchronized media.
• 1.2.3 Audio Description or Media Alternative (Prerecorded): Provide either an audio description or a media alternative for prerecorded video content.
• 1.3.1 Info and Relationships: Information, structure, and relationships can be programmatically determined or are available in text.
• 1.3.2 Meaningful Sequence: Content is presented in a meaningful order.
• 1.3.3 Sensory Characteristics: Instructions are not based solely on sensory characteristics.
• 1.4.1 Use of Color: Color is not the only visual means of conveying information.
• 1.4.2 Audio Control: If audio plays automatically for more than 3 seconds, there is a way to stop or control the volume.
• 2.1.1 Keyboard: All functionality is available via keyboard.
• 2.1.2 No Keyboard Trap: Focus can be moved away from any component using a keyboard.
• 2.1.4 Character Key Shortcuts: Single-character shortcuts can be turned off, changed, or require another key.
• 2.2.1 Timing Adjustable: Users can adjust time limits.
• 2.2.2 Pause, Stop, Hide: Users can pause, stop, or hide moving, blinking, or scrolling content.
• 2.3.1 Three Flashes or Below Threshold: Content does not flash more than three times per second.
• 2.4.1 Bypass Blocks: Provide a way to skip repeated blocks of content.
• 2.4.2 Page Titled: Pages have titles that describe topic or purpose.
• 2.4.3 Focus Order: Focus can be moved in a meaningful order.
• 2.4.4 Link Purpose (In Context): The purpose of each link can be determined from link text or context.
• 2.5.1 Pointer Gestures: Functionality using complex gestures can also be operated with simple gestures.
• 2.5.2 Pointer Cancellation: Functionality can be canceled before completion.
• 2.5.3 Label in Name: Labels contain the visible text of the name.
• 2.5.4 Motion Actuation: Functionality triggered by motion can also be operated by other means.
• 3.1.1 Language of Page: The default language of the page can be programmatically determined.
• 3.2.1 On Focus: No component changes context when it receives focus.
• 3.2.2 On Input: No component changes context when data is entered.
• 3.3.1 Error Identification: Errors are identified and described to the user.
• 3.3.2 Labels or Instructions: Labels or instructions are provided when input is required.
• 4.1.1 Parsing: Content is correctly coded so it can be interpreted by user agents.
• 4.1.2 Name, Role, Value: User interface components have names and roles that can be programmatically determined.

WCAG 2.1 Success Criteria – Level AA

• 1.2.4 Captions (Live): Provide captions for live audio content in synchronized media.
• 1.2.5 Audio Description (Prerecorded): Provide audio description for prerecorded video content.
• 1.3.4 Orientation: Content is not restricted to a single display orientation.
• 1.3.5 Identify Input Purpose: Input fields can be programmatically identified to enable autofill.
• 1.4.3 Contrast (Minimum): Text has a contrast ratio of at least 4.5:1.
• 1.4.4 Resize Text: Text can be resized up to 200% without loss of content or functionality.
• 1.4.5 Images of Text: Use text instead of images of text, except where essential.
• 1.4.10 Reflow: Content can be presented without loss of information or functionality, and without horizontal scrolling.
• 1.4.11 Non-text Contrast: Visual components have a contrast ratio of at least 3:1.
• 1.4.12 Text Spacing: No loss of content or functionality when text spacing is adjusted.
• 1.4.13 Content on Hover or Focus: Content that appears on hover or focus can be dismissed, moved, or remains visible.
• 2.4.5 Multiple Ways: More than one way is available to locate a web page within a set of pages.
• 2.4.6 Headings and Labels: Headings and labels describe topic or purpose.
• 2.4.7 Focus Visible: Keyboard focus is visible for all components.
• 3.1.2 Language of Parts: The language of each passage of text can be programmatically determined.
• 3.2.3 Consistent Navigation: Navigation mechanisms appear in the same order each time they are repeated.
• 3.2.4 Consistent Identification: Components with the same functionality are identified consistently.
• 3.3.3 Error Suggestion: If errors are detected, suggestions for correction are provided.
• 3.3.4 Error Prevention (Legal, Financial, Data): Users can review, confirm, and correct before final submission.

WCAG 2.1 Success Criteria – Level AAA

• 1.2.6 Sign Language (Prerecorded): Provide sign language interpretation for prerecorded synchronized media.
• 1.2.7 Extended Audio Description (Prerecorded): Provide extended audio description for video.
• 1.2.8 Media Alternative (Prerecorded): Provide a full text alternative for prerecorded synchronized media.
• 1.2.9 Audio-only (Live): Provide alternative content for live audio.
• 1.3.6 Purpose of UI Components: The purpose of UI components can be programmatically determined.
• 1.4.6 Enhanced Contrast: Text has a contrast ratio of at least 7:1.
• 1.4.7 Low or No Background Audio: Background audio is low or can be turned off.
• 1.4.8 Visual Presentation: Users can customize the visual presentation of text.
• 1.4.9 Images of Text (No Exception): Avoid images of text altogether.
• 2.1.3 Keyboard (No Exception): All functionality is accessible via keyboard without exception.
• 2.2.3 No Timing: No time limits.
• 2.2.4 Interruptions: Users can postpone or suppress interruptions.
• 2.2.5 Re-authenticating: Users can return to where they were after re-authenticating.
• 2.3.2 Three Flashes: No content flashes at all.
• 2.4.8 Location: Indicate the user’s current location within the site.
• 2.4.9 Link Purpose (Link Only): The purpose of a link is clear from its text alone.
• 2.4.10 Section Headings: Sections have descriptive headings.
• 3.1.3 Unusual Words: Explain any unusual words.
• 3.1.4 Abbreviations: Abbreviations are explained or defined.
• 3.1.5 Reading Level: Text is understandable at a lower secondary education level, if possible.
• 3.1.6 Pronunciation: Provide pronunciation when needed to understand the meaning.
• 3.2.5 Change on Request: Context changes only upon user request.
• 3.3.5 Help: Help is available for form completion.
• 3.3.6 Error Prevention (All): Input can be reviewed, confirmed, and corrected for all task types.
• 4.1.3 Status Messages: Status messages are programmatically determined without a change of focus.

EN 301 549 Standard and Its Relation to WCAG and the EAA

EN 301 549 is the European standard for ICT accessibility that greatly complements and specifies the requirements in the EAA. This standard ("Accessibility requirements for ICT products and services") compiles the technical specifications for accessibility of websites, software, mobile applications, hardware, and other IT products. For web content and applications, EN 301 549 refers directly to the WCAG criteria – in fact, the requirements in EN 301 549 correspond to web content meeting WCAG 2.1 level AA.

The purpose of EN 301 549 is to serve as a harmonized European reference: If you follow the standard, you can assume you meet the legal requirements. The European Commission is expected to designate EN 301 549 (in an updated version) as the official harmonized standard for accessibility requirements under the EAA. A revised version of EN 301 549 is under development and is expected no earlier than the end of 2025. Until then, companies must rely on the current version and the WCAG 2.1 guidelines, which are already familiar from existing legislation.

In addition to WCAG, EN 301 549 includes requirements for other product aspects, such as hardware (screens, keyboards, terminals), document formats, speech recognition, and more. This makes it relevant for the EAA, which covers not only the web but also physical products with digital interfaces. In short, EN 301 549 connects the dots between WCAG requirements for web content and the broader accessibility requirements in the EAA for all types of ICT products. Once the standard is officially recognized under the EAA, compliance with EN 301 549 will give a presumption of meeting the legal requirements.

Advice for Businesses and Developers: How to Comply

Transitioning to the new accessibility requirements may seem extensive, but with timely planning and the right measures, businesses can ensure their products and services comply with the EAA. Here is a set of practical steps to get started:

• Start now: Implementing web accessibility can take time. Experience shows that even many public sites struggled to meet requirements despite years of notice. Therefore, begin planning now for how to make your digital solutions accessible.
• Understand the requirements: Familiarize yourself with the WCAG 2.1 guidelines and learn what is required at levels A and AA. Educate your development team on best practices in accessibility – such as correct use of HTML tags, ARIA landmarks, contrast and color choices, etc. Many free resources and guides on web accessibility are available online (including W3C’s documentation and our list above). The better you understand the principles, the easier they are to implement.
• Map your current state: Conduct an accessibility audit of your current website, app, or product. Identify which WCAG requirements are not currently met. A systematic review provides a concrete overview and helps prioritize efforts.
• Prioritize and implement improvements: Create an action plan to fix the identified accessibility issues. Start with the critical barriers (level A) and work up through the AA-level requirements. Many adjustments will be minor (e.g., adding alt text or fixing HTML validation errors), while others may require larger changes – such as redesigning navigation for better keyboard control, replacing video players to support captions, or upgrading frameworks to support accessible components.
• Involve users and experts: Test your solution with users who have disabilities or using assistive technologies such as screen readers. Their feedback is invaluable for discovering practical problems. Consider also consulting accessibility experts, who can provide guidance and independent evaluations. An external expert review ensures nothing important is overlooked and gives peace of mind that you’re on the right track.
• Integrate accessibility into your processes: Make accessibility a natural part of your development lifecycle moving forward. Include accessibility requirements in design briefs, specifications, and QA testing. When accessibility is considered from the start of new projects, you avoid expensive corrections later. This "design for all" principle (also known as universal design) is also covered by standard EN 17161, which the EAA refers to as best practice.

By following this advice, businesses can not only achieve legal compliance but also gain business benefits. An accessible website or product can be used by a broader customer base, increasing potential users and market reach. Accessibility often improves the overall user experience for everyone – not just people with disabilities – so the effort can result in more satisfied customers overall. In short: investing in digital accessibility pays off, both to meet legal obligations and to strengthen your market position.

Conclusion

The European Accessibility Act (EAA) marks a milestone for digital inclusion in the EU. From June 2025, both public and private actors must ensure that a wide range of digital products and services meet accessibility standards, giving all users – regardless of disability – equal access. WCAG 2.1 and EN 301 549 will be the cornerstones in technical compliance, and it is crucial to begin implementing changes well in advance. By following the described recommendations and prioritizing accessibility now, businesses can avoid penalties and gain a competitive edge by offering better and more inclusive user experiences. The EAA is therefore not just a compliance task, but an opportunity to make the digital world more welcoming for all.

Accessibility Law in the Flex4B System

At Flex4Business ApS, we have long been working to ensure that the Flex4B system (ticketing system, webshop, CMS, and card system) complies with the new accessibility law, so all our customers are also in compliance.
It is an ongoing effort to ensure that both existing and new parts of the system meet the requirements.
Our goal is for all parts of the system to meet at least level AA, and to meet level AAA wherever possible.

Remember that as a customer of the Flex4B system, you are also responsible for ensuring that the content you create complies with the law.
This includes, for example, choosing high-contrast colors, using ALT tags for images, ensuring that headings describe content, and all the other aspects you can easily manage directly in our drag-and-drop editor.