The EU accessibility deadline already passed

The European Accessibility Act is Directive (EU) 2019/882. Member states had to apply its measures from 28 June 2025. It covers consumer products and services placed on the EU market, including e-commerce, banking, transport and e-books. The Commission’s page on the directive says it harmonises requirements for products and services. A company outside the EU is in scope when it offers those services to consumers in the Union. Selling into France from Manchester is not a loophole. Confirm the transposition in each country you sell to. They are not identical.

The technical bar the directive points at is EN 301 549, which takes in WCAG 2.1 Level AA for web content and adds requirements for documents and software. WCAG 2.2 is the newer W3C recommendation. It is the one we design to. Citing 2.2 alone and calling the site ‘EAA compliant’ is sloppy, because the harmonised standard is the one a member state points at. Say which standard, which level, which pages, and the date. W3C has been plain that a logo is not a conformance claim.

Microenterprises have a narrow exemption in the directive: fewer than 10 people and turnover or balance sheet not over €2 million. Most clients are over that line, or they sell through a platform that is. Services already on the market can have a longer transition, in places out to 28 June 2030. A new service placed on the market after 28 June 2025 should not be planned against the later date. Read the national law before you treat 2030 as a holiday.

Penalties are national, not one EU fine. Commentaries on the German transposition cite fines up to €100,000. French commentaries cite a range well above that, plus a separate penalty for a missing accessibility statement. Those figures are secondary and they move. The durable fact is the one in the directive: each country designates an authority, and a missing statement plus an inaccessible checkout is what advocacy groups have already written to retailers about. French organisations sent notices to grocery sites within days of the deadline. That is reporting, not a judgment.

If you sell to EU consumers, the build needs an accessibility statement that names the known gaps, a contact for barriers, and a keyboard path through the thing you actually sell. We will not put a badge on a footer and call that compliance.