The European Accessibility Act (EAA) and Its Impact on Design

Introduction

What is the EAA?

The European Accessibility Act (EAA) is an EU directive aimed at ensuring that certain products and services provided by businesses meet accessibility requirements. The directive sets a legal framework for improving access to technology and services for people with disabilities, older adults, and others who may face temporary or permanent functional limitations.

The EAA promotes the design and development of products and services that are accessible and usable by the widest possible range of users. This includes a strong emphasis on inclusive engineering practices, encouraging designers and developers to integrate accessibility from the earliest stages of product and service development.

Who Is Affected by the EAA?

The European Accessibility Act (EAA) applies to organisations such as manufacturers, authorized representatives, importers, distributors, and service providers who offer digital and physical products and services. This includes, but is not limited to, ATMs, payment terminals, consumer electronics, operating systems, online banking services, e-commerce platforms, mobile applications, and web-based interfaces.

The EAA does not apply to certain microenterprises providing services, nor to some specific categories such as digital maps services, content not funded or controlled by the provider, or certain forms of local public transportation services. The EAA does not apply to pre-recorded time-based media published before 28 June 2025.

Detailed information on exceptions and scope can be found in the full directive available at the EUR-Lex website[1].

What Are the Requirements under EAA?

The EAA outlines which products and services shall be accessible, but it does not provide detailed technical guidelines. Instead, compliance may be assessed using the harmonized European standard EN 301 549, which serves as the main reference point.

EN 301 549 was developed by ETSI[2] in collaboration with CEN and CENELEC. It defines detailed accessibility requirements for a broad range of ICT (Information and Communication Technology) products and services, including websites, mobile applications, software, hardware (such as ATMs and kiosks), and electronic documents. It reffers to WCAG (Web Content Accessibility Guidelines) for many topics related to accessibility.

How to Improve the Accessibility of Products and Services?

Accessibility means designing products and services so that they can be used by everyone — regardless of physical, sensory, or cognitive limitations. This can be achieved through tools and features such as screen readers (e.g., NVDA, JAWS), alternative keyboards, high-contrast user interfaces, captions, voice navigation, tactile markings (e.g., braille), and well-considered UX and UI design.

Example Accessibility Improvement Plan

1. Conduct an Accessibility Audit
   • Evaluate compliance with relevant accessibility standards under the European Accessibility Act (EAA)
   • Audit scope may include: websites, mobile apps, documents, devices, customer service, and physical locations
   • Perform both manual and automated testing using tools such as:
     • WAVE Web Accessibility Evaluation Tool
     • Google Lighthouse
     • PageSpeed Insights
     • NVDA (screen reader)
2. Develop a Remediation Action Plan
   • Create a list of identified barriers and accessibility issues
   • Prioritize issues based on impact and feasibility
   • Assign responsibilities and define timelines for resolution
3. Implement Changes
   • Apply technical and design improvements
   • Enhance usability of devices and applications for all users
4. Prepare Documentation and User Communication
   • Create and publish an accessibility statement
   • Provide a clear channel for reporting accessibility issues
   • Maintain documentation of all implemented improvements
5. Continuous Improvement
   • Conduct regular audits and update accessibility practices
   • Train staff across departments (UX, IT, marketing, customer support)
   • Engage with users with disabilities for feedback and testing
   • Integrate accessibility from the start, using guidelines such as the DFX (Design for Excellence) framework
   • Review user feedback and accessibility-related reports

Example: Common Website Errors

According to the WebAIM Million 2025 report, published in February 2025, which evaluates the accessibility of the homepages of the top one million websites, 94.8% of homepages contain WCAG 2 conformance errors.

The report highlights that 96% of the detected issues fall into six main categories:[3]

• Low contrast text
• Missing alternative text for images
• Form inputs without associated labels
• Empty links
• Empty buttons
• Missing document language declaration

Below is a simplified example of a website layout before and after implementing accessibility improvements that address the six most common issues identified in the WebAIM report:

Why Is It Worth Investing in Accessibility?

Accessibility is becoming an increasingly important global topic, and implementing it brings tangible benefits, including:

• Improving quality of life for people with disabilities
• Designing with the needs of older adults in mind
• Enhancing the company's reputation as a socially responsible organization
• Increasing competitiveness and expanding the customer base
• Playing a key role in the usability and market success of electronic products
• Avoiding costly rework in production by integrating accessibility requirements early in the design process
• Improving product universality, reliability, and quality — this also aligns with Design for Reliability, leading to better user experience

Summary

The European Accessibility Act (EAA) is not just a legal obligation — it is a driver for creating better, more inclusive products and services. Accessibility has become a standard in modern design. It also enhances reliability — interfaces are more resilient to user errors and function intuitively across different environments. This creates real value: greater comfort, access to a broader market, fewer support issues, and higher user satisfaction.

If you are a designer, I strongly recommend becoming familiar with the EN 301 549 standard and the WCAG guidelines. It will pay off quickly.