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, making 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 concrete guidance for businesses on how to comply with the requirements.

The Purpose and Significance of the Law

The new accessibility legislation 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 takes effect on 28 June 2025, the "internet will truly be open to all" – meaning that many more people will be able to access websites, apps, and electronic products without barriers. The initiative stems in part from the EU's desire to eliminate discrepancies between member states' requirements and ensure equal access to the digital single market. At the same time, the law is expected to benefit a significant portion of the population who currently struggle to use digital solutions due to disabilities or functional impairments.

The law (officially based on EU Directive 2019/882, also known as the European Accessibility Act) sets out a range of specific accessibility requirements that all relevant products and services must meet. In Denmark, the directive is implemented via the Act on Accessibility Requirements for Products and Services (commonly referred to as the "Accessibility Act"). These requirements include, among others, 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 builds on principles from previous rules for public websites but extends them to include many private operators and products as well.

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 airline tickets).
• Self-service terminals: Information displays, ATMs, and other interactive public terminals.
• Banking, payment, and insurance: Online banking, mobile banking, and other consumer-oriented 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 includes certain physical products with a digital interface – such as smart TVs, payment terminals, etc. – which must comply with accessibility requirements in their operation. (The focus is B2C; pure B2B solutions are generally outside the scope.)

Exceptions: Microenterprises (fewer than 10 employees and an annual turnover or balance sheet total under €2 million) that provide services within the directive’s scope are generally exempt from many of the service-related requirements. For products, microenterprises still have product obligations but may be subject to simplified administrative requirements. In addition, businesses can be exempted if meeting the requirements imposes a disproportionate burden or would fundamentally alter the product or service.

Transitional Arrangements: Service providers may continue to deliver equivalent services using products that were lawfully in use for that purpose before 28 June 2025, until 28 June 2030. Self-service terminals already in use before 28 June 2025 may be used for their economic lifespan, up to a maximum of 20 years from initial use.

Consequences of Non-Compliance: 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 may order the withdrawal from the market and impose sanctions. There is no unified fine level across the EU; specific fines and enforcement actions are determined nationally.

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

A central part of meeting accessibility requirements is adhering to the WCAG 2.1 standard (Web Content Accessibility Guidelines 2.1). WCAG provides international guidelines for making web content and apps accessible to people with various types of disabilities. WCAG 2.1 is based on four fundamental principles – content must be perceivable, operable, understandable, and robust. These principles are implemented through specific requirements (called “success criteria”), which are divided into three levels of compliance: A, AA, and AAA. Level A is the most basic (lowest) level of accessibility requirements, addressing the most essential barriers. Level AA includes all A-level requirements plus additional criteria considered to provide a high level of accessibility. AAA is the highest level, with the most ambitious requirements – including all A and AA requirements plus additional advanced criteria.

In practice, level AA is typically the target in legislation and public standards, as it 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 expected to be largely fulfilled by ensuring that digital solutions meet WCAG 2.1 AA. Businesses should therefore aim for at least AA-level compliance for their websites, webshops, mobile applications, etc. Striving for AAA can further enhance accessibility but is voluntary and often difficult to achieve fully.

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 wish to explore further.

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 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 solely dependent on sensory characteristics.
• 1.4.1 Use of Color: Color is not used as the only visual means of conveying information.
• 1.4.2 Audio Control: If audio plays automatically for more than 3 seconds, a way to pause or reduce volume is provided.
• 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 the keyboard.
• 2.1.4 Character Key Shortcuts: Single-character shortcuts can be turned off, remapped, or require a modifier 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 moves in a logical order that preserves meaning and operability.
• 2.4.4 Link Purpose (In Context): The purpose of each link is clear from its 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 cancelled before completion.
• 2.5.3 Label in Name: Labels include the visual text of the control.
• 2.5.4 Motion Actuation: Functionality that operates through motion can also be operated by other means.
• 3.1.1 Language of Page: The page's default language 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 user input is received.
• 3.3.1 Error Identification: Errors are identified and described to the user.
• 3.3.2 Labels or Instructions: Users are provided with labels or instructions when input is required.
• 4.1.1 Parsing: Content is correctly coded for user agents to interpret.
• 4.1.2 Name, Role, Value: Interface components have programmatically determined name and role.

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 descriptions for prerecorded video content.
• 1.3.4 Orientation: Content is not restricted to a specific display orientation.
• 1.3.5 Identify Input Purpose: Input fields can be programmatically identified for 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 unless essential.
• 1.4.10 Reflow: Content can be presented without loss of information or function 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/function when text spacing is adjusted.
• 1.4.13 Content on Hover or Focus: Hover/focus content can be dismissed, moved, or remains visible.
• 2.4.5 Multiple Ways: More than one way is available to locate a web page.
• 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: Language of text passages can be programmatically determined.
• 3.2.3 Consistent Navigation: Navigation appears in the same order across pages.
• 3.2.4 Consistent Identification: Components with the same functionality are consistently identified.
• 3.3.3 Error Suggestion: Suggestions for corrections are provided if errors are detected.
• 3.3.4 Error Prevention (Legal, Financial, Data): Users can review, confirm, and correct critical input.

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-only content.
• 1.3.6 Purpose of UI Components: The purpose of interface 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 adjust visual presentation of text.
• 1.4.9 Images of Text (No Exception): Images of text are avoided entirely.
• 2.1.3 Keyboard (No Exception): All functionality is accessible via keyboard, with no exceptions.
• 2.2.3 No Timing: No time limits are set.
• 2.2.4 Interruptions: Users can postpone or suppress interruptions.
• 2.2.5 Re-authenticating: Users can return to previous steps and correct input.
• 2.3.2 Three Flashes: No content flashes at all.
• 2.4.8 Location: Indicate the user’s current location on the site.
• 2.4.9 Link Purpose (Link Only): The purpose of links is clear from link text alone.
• 2.4.10 Section Headings: Sections have descriptive headings.
• 3.1.3 Unusual Words: Unusual words are explained.
• 3.1.4 Abbreviations: Abbreviations are explained or defined.
• 3.1.5 Reading Level: Content is understandable at a lower secondary education level.
• 3.1.6 Pronunciation: Pronunciation is available when meaning is unclear without it.
• 3.2.5 Change on Request: Context changes only occur on user request.
• 3.3.5 Help: Users are provided help when completing forms.
• 3.3.6 Error Prevention (All): Input is reviewed, confirmed, and correctable for all tasks.
• 4.1.3 Status Messages: Status messages are programmatically determined without focus change.

EN 301 549 Standard and Its Relation to WCAG and EAA

EN 301 549 is the European standard for ICT accessibility and largely complements and specifies the requirements in the EAA. For web content and applications, EN 301 549 directly references the WCAG criteria – in practice, the required level corresponds to WCAG 2.1 AA. The fully updated, EAA-harmonized version is expected sometime in 2025; until then, the current edition is used alongside the EAA requirements.

In addition to WCAG, EN 301 549 also includes requirements for other product aspects, such as hardware (screens, keyboards, terminals), document formats, speech recognition, etc. This makes it relevant for the EAA, which not only covers the web, but also physical products with digital interfaces. Once the standard is officially recognized under the EAA, compliance with EN 301 549 will provide a presumption of conformity with the law’s requirements.

Advice for Businesses and Developers: How to Comply

The transition to the new accessibility requirements may seem extensive, but with timely planning and the right actions, companies can ensure their products and services comply with the EAA. Below are specific steps to get started:

• Start now: Implementing web accessibility takes time. Start early with a plan for how to make your digital solutions accessible.
• Learn the requirements: Familiarize yourself with the WCAG 2.1 guidelines and understand what's required at levels A and AA. Educate your development team on best practices (correct HTML, ARIA landmarks, contrast, keyboard operability, etc.).
• Assess current state: Conduct an accessibility audit of your website, app, or product and identify gaps compared to WCAG.
• Prioritize and implement improvements: Begin with critical barriers (level A) and work towards AA. Some changes are small (alt-texts, HTML validation), others more significant (navigation, video players, component libraries).
• Involve users and experts: Test with users with disabilities and assistive technologies (e.g., screen readers), and consider external expert reviews.
• Integrate accessibility into processes: Build accessibility into design briefs, requirement specifications, and QA. Think “design for all” from the beginning to avoid costly rework later.

By following these recommendations, businesses can not only achieve compliance but also realize commercial benefits. An accessible website or product can be used by a broader audience and often improves the overall user experience for everyone.

Country-Specific Information

Denmark/Greenland: The directive is implemented via Act No. 801 of 7 June 2022 on Accessibility Requirements for Products and Services. Supervision and enforcement are handled by relevant authorities depending on the sector (e.g., the Danish Safety Technology Authority). The rules apply from 28 June 2025, with transitional provisions as described in the law.
Greenland is not an EU member and is associated as an Overseas Country and Territory (OCT). Therefore, EU directives such as the EAA do not apply directly in Greenland unless specifically implemented into Greenlandic law. Refer to any local regulations and announcements.

Sweden: The directive is implemented via Lag (2023:254) om vissa produkters och tjänsters tillgänglighet, effective from 28 June 2025. Supervision is divided among competent sector authorities.

Finland: Implemented through national legislation (e.g., 102/2023) and supplemented by government decrees specifying product and service requirements. Effective from 28 June 2025; market supervision is handled by competent authorities (e.g., Traficom for relevant areas).

Netherlands: Implemented via Implementatiewet toegankelijkheidsvoorschriften producten en diensten (No. 36.380). Rules apply from 28 June 2025; sector-specific authorities are responsible for enforcement.

Germany: Implemented through the Barrierefreiheitsstärkungsgesetz (BFSG) and related ordinance BFSGV. Applicable from 28 June 2025 with detailed requirements for both products and services, including market surveillance.

France: Implemented in French law, including Loi n° 2023-171 du 9 mars 2023 (Art. 16) and Décret n° 2023-931 and Arrêté du 9 octobre 2023, which specify accessibility requirements for covered products and services. Effective from 28 June 2025.

Spain: Implemented via Ley 11/2023, de 8 de mayo (Title I). Provisions apply from 28 June 2025 and include product and service requirements, transitional measures, and market oversight.

Norway: Not an EU member; the EAA is EEA-relevant and expected to be implemented into Norwegian law, but the effective date is not yet finalized. National authorities have initiated the process; businesses should monitor Norwegian updates.

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 comply with accessibility standards so that all users – regardless of disability – have equal access. WCAG 2.1 and EN 301 549 will be the cornerstones of technical compliance. By prioritizing accessibility now, companies can not only avoid sanctions but also gain a competitive advantage.

Accessibility 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 that all our clients can also be compliant. This work continues to ensure that both current and future components of the system meet the law. The goal is for all parts of the system to comply with at least level AA – and where possible, AAA.

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 text on images, ensuring meaningful headings, and utilizing the accessibility features available directly in our drag-and-drop editor.