EAA 2025 · 10-step checklist

EAA 2025 compliance checklist

A practical 10-step checklist for engineering and product teams shipping consumer-facing products or services into the EU under the European Accessibility Act (Directive 2019/882). Not legal advice — written for the team that has to actually build and ship.

1. 1. Confirm you're in scope

   The EAA applies to consumer-facing products and services placed on the EU market on or after 28 June 2025. In-scope services include e-commerce, banking, e-books, electronic communications, passenger-transport ticketing, and consumer hardware operating systems.

   Microenterprise exemption per Article 4(5): fewer than 10 employees andannual turnover / balance sheet under €2M, providing services. Product manufacturers are not exempt regardless of size. If you're a non-EU operator selling to EU consumers, you are in scope.

2. 2. Lock in the technical standard: EN 301 549 / WCAG 2.1 AA

   The EAA itself is principles-based; the harmonised standard EN 301 549 v3.2.1 is the technical specification you implement against. For web content, it embeds WCAG 2.1 Level AA directly. Conformance is per-page, per-app-screen, per-PDF.

   Plan for WCAG 2.2 AA migration — the next harmonised standard update is expected to reference 2.2. Building to 2.2 today futures-proofs the investment.

3. 3. Run a baseline audit

   Two parts to a credible baseline:

   • Automated scan with axe-core 4.11 against your homepage, primary conversion path, account pages, and at least one example of each template. Catches ~57% of WCAG issues. Free here: /free-scan.
   • Human audit by an IAAP-certified auditor (CPACC or WAS) for the remaining ~43% — semantic alt text, heading order, cognitive load, screen-reader experience quality. Cost ranges in the audit guide.

4. 4. Remediate critical and serious findings

   Prioritise in severity order: critical (blocks an entire flow for an AT user) first, serious (degrades the experience materially) next, moderate / minor as backlog. The single most-missed serious-severity item across audits is custom UI controls (variant selectors, custom dropdowns, modals) without correct ARIA roles or keyboard handling.

5. 5. Publish an accessibility statement

   Required elements per the EU Implementing Decision 2018/1523 template:

   • Conformance status — fully / partially / non-conformant with EN 301 549.
   • List of non-accessible content with reason (disproportionate burden, exemption, in-progress remediation).
   • Named accessibility contact (email; phone recommended).
   • Escalation procedure pointing to the relevant national authority — varies by country.
   • Assessment methodology (self-assessment, third-party audit, or combination) with date.
   • Preparation and last-review dates.

   Free template generator: /statement.

6. 6. Set up a complaint and feedback channel

   Article 23 of the EAA requires that consumers can lodge complaints. The accessibility statement's named contact + escalation path covers this in most jurisdictions. Ensure the contact mailbox is monitored — unanswered complaints escalate to the national authority.

7. 7. Stand up CI to prevent regressions

   Without a CI gate, the gains from steps 3–4 reverse within a quarter. Install axle's GitHub Action on your main repo (free for one repo) — it scans every PR and fails merges on serious-severity regressions. The CI history is also the most defensible “ongoing diligence” record in any market- surveillance enquiry.

8. 8. Retain audit-trail evidence

   Keep at minimum: the human audit report, the per-PR CI scan history, the dated accessibility statement(s), records of accessibility complaints and how you responded. Five-year retention is the EU norm for compliance evidence.

9. 9. Check the country-specific transposition

   Each EU member state transposed the EAA into national law with its own enforcement authority, fining structure, and (sometimes) language requirements:

   • Germany — BFSG
   • France — RGAA
   • Italy — Legge Stanca
   • Spain — Ley 11/2023
   • Ireland — S.I. 636/2023
   • Netherlands
   • Belgium
   • Austria — BaFG
   • Sweden
   • Portugal
   • Poland
   • Denmark

   Full overview: EAA 2025 — the directive, the obligations, the timeline.

10. 10. Schedule the annual audit refresh

    EAA conformance is a continuous obligation, not a one-time stamp. Budget for one human audit per year (or after any major redesign), and update the accessibility statement's methodology + date annually even if findings are minor. The CI evidence sits between audits.