European Accessibility Act (EAA) — what changed in June 2025

The European Accessibility Act is the EU's parallel to ADA Title III — but more prescriptive, more proactive, and now actively enforced. Most US founders building consumer apps have never heard of it. EU regulators have started sending advisory letters to non-compliant operators, and a handful of countries have already issued fines. Here's what changed in June 2025 and what to do.

What the EAA actually requires

The European Accessibility Act (Directive (EU) 2019/882) was adopted in 2019 with a six-year implementation window. The compliance deadline — June 28, 2025 — has now passed. Each EU member state has transposed the directive into national law; the substantive standard is identical across the bloc, but enforcement and penalties vary.

The technical standard referenced by the EAA is EN 301 549 ("Accessibility requirements for ICT products and services"). For web content and mobile apps, EN 301 549 references WCAG 2.1 at Level AA — meaning the substantive accessibility requirements are familiar territory for anyone who's already addressed ADA Title III. There are some additional layers (real-time text, voice integration, hardware features) that go beyond WCAG, but for a typical SaaS app, WCAG 2.1 AA compliance gets you most of the way there.

Who's in scope

The EAA applies to specific product and service categories, not to "all websites." The categories most relevant to vibe-coded apps are:

1. E-commerce services — any consumer-facing site that sells goods or services online.
2. Consumer banking and payment services — payment apps, account interfaces, and online card services.
3. E-readers and e-books delivered electronically.
4. Passenger transport services — booking, ticketing, real-time travel information.
5. Audiovisual media services — streaming UIs, EPGs (electronic program guides), and access services.
6. Telecommunications services and the consumer devices that interact with them.

Pure B2B services, internal-tools, and personal blogs are generally outside scope. If your app falls in a covered category and you serve EU consumers (or even one EU consumer), you're in scope — there's no "meaningful EU presence" threshold like there is for some other EU regulations.

The microenterprise exemption

The EAA exempts "microenterprises" from the substantive accessibility requirements when they provide services (not products). The threshold is conjunctive — you must satisfy both criteria:

Most vibe-coded apps qualify for the exemption initially. The trap: the exemption is service-specific. If you're a founder running a microenterprise service business but you also sell a physical product (the EAA distinguishes), the product side has no exemption. And the moment you cross either threshold, the exemption lifts — and you get a 12-month grace period from your member state's market surveillance authority to come into compliance, not a fresh six-year window.

What enforcement has looked like so far

Enforcement started slowly — most member states spent late 2025 on guidance and capacity-building. The first half of 2026 has seen the cadence pick up. Public reporting indicates:

• France — DGCCRF (the consumer-protection authority) has issued ~140 "mise en demeure" notices since October 2025, mostly against e-commerce sites. Initial fines start at €5,000.
• Germany — Marktüberwachungsbehörden have inspected ~60 apps in the financial and e-commerce sectors, with 8 fines issued in the €10,000–€25,000 range.
• Spain — AESIA (the digital accessibility authority) prioritized public-sector and large e-commerce; private fines started Q1 2026.
• Ireland — NDA has so far operated mostly in advisory mode, with formal enforcement expected later in 2026.

These numbers are small compared to ADA's 3,000+ federal cases per year, but the trajectory matters: the EAA's enforcement curve is climbing, not flat. The first complete enforcement year (mid-2026 to mid-2027) is widely expected to produce thousands of advisory actions and hundreds of fines across the bloc.

Where vibe-coded apps typically fail EAA inspections

The substantive failures are the same as on the ADA side — labels, contrast, alt text, focus order, keyboard support — but the EAA's documentation requirements add a procedural layer that ADA doesn't have:

1. Missing accessibility statement on the website (required by EN 301 549).
2. No clear feedback mechanism for users to report accessibility issues (required by Annex VII).
3. Form labels missing or placeholder-only (WCAG 2.1 §1.3.1).
4. Insufficient contrast (§1.4.3).
5. Images without alt text (§1.1.1).
6. Keyboard navigation broken on modals, dropdowns, or interactive components (§2.1.1).
7. Time-limited interactions without extension options (§2.2.1) — a frequent issue with one-time-password flows in fintech apps.

Practical steps to comply

If your app falls in scope and your microenterprise exemption doesn't apply, the practical path is:

1. Run a WCAG 2.1 AA scan. axe-core, Lighthouse, or Comply Code all surface the substantive issues.
2. Remediate the failures — most are quick fixes (labels, contrast adjustments, alt text). Allocate ~1 day of dev time for a typical small app.
3. Publish an accessibility statement. Annex V of the EAA gives you the format; a template fits on one page. Link from the footer.
4. Add a feedback mechanism. "Report an accessibility issue" form or dedicated email. This is procedural and easy.
5. Document conformity. Keep records (scan outputs, remediation timeline, third-party audit if you got one). If a market surveillance authority asks, you want to hand them a file.

Bottom line

If you ship to EU consumers and you're in one of the covered service categories, the EAA applies to you, and the microenterprise exemption may or may not save you depending on your size. The substantive work overlaps almost entirely with ADA remediation — fixing for one largely fixes for the other. What's different is the procedural layer: accessibility statement, feedback mechanism, conformity records. Those don't exist in ADA-land but are a 1-day add. Worth doing before a market surveillance authority asks.