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The EAA deadline: what it means and what's enforced

A plain-language guide to the European Accessibility Act deadline: what 28 June 2025 changed, what's actually enforced, and the transitional periods.

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Pavel Charkasau

The European Accessibility Act deadline was 28 June 2025, and it has passed. Since that date, the EAA (Directive (EU) 2019/882) applies across the EU, so if you sell a covered consumer service to customers in the EU, accessibility is a current legal obligation, not something on the horizon. The "deadline" people search for is this application date: the point at which the requirements took legal effect. What the deadline did not bring is a wave of automatic fines. Enforcement happens at the national level, member states are still building up their market-surveillance machinery, and the first real cases are moving through the courts rather than landing as instant penalties. This guide explains what the deadline actually changed, what is being enforced right now and by whom, the transitional periods that give some existing setups more time, and what to do if your site is not there yet.

What is the EAA deadline?

The headline date is 28 June 2025, the day the EAA's requirements started to apply to businesses (European Commission). There was an earlier date that mattered to governments more than to companies: member states had to transpose the directive into their own national law by 28 June 2022, so that those national rules could take effect on 28 June 2025 (Directive (EU) 2019/882, Article 31).

That two-step structure is why the law you actually answer to is your country's transposition, not the directive itself. The directive sets the floor; each member state writes the statute, names the enforcement body, and sets the penalties. The substance is harmonised, but the procedure and the numbers vary from one country to the next.

Has the deadline passed, and is the law in force now?

Yes on both counts. As of 28 June 2025 the EAA applies, and the obligation is live today across all 27 member states. If you provide a covered service, the requirements are something you have to meet now, not prepare for.

The services most often caught on the web are e-commerce, consumer banking and many financial services, e-books and reading software, electronic communications, passenger transport sites and apps, and access to audiovisual media services. Selling into the EU from outside it does not get you out: a business based elsewhere still has to comply for the EU market. There is one narrow carve-out for microenterprises that provide a service, those with fewer than 10 staff and a turnover or balance sheet of €2 million or less, and both conditions have to be true at once (Directive (EU) 2019/882, Article 4). Our EAA overview breaks the scope down sector by sector if your case sits near the line.

What is actually being enforced, and by whom?

This is where the gap between the headline and the reality is widest. The EAA does not come with an EU-wide fine schedule or a central regulator. Each member state designates its own authorities to check compliance and handle complaints, and sets penalties that the directive only requires to be "effective, proportionate and dissuasive" (Directive (EU) 2019/882, Article 30). So what an enforcement action looks like, and what it costs, depends on the country.

A year in, enforcement is ramping rather than raining down. The clearest activity has been in France. In July 2025 two disability associations, apiDV and Droit Pluriel, sent formal legal notices (mises en demeure) to four large grocery retailers, Auchan, Carrefour, E.Leclerc, and Picard, giving them until 1 September 2025 to make their online services accessible. When the sites did not change, the associations filed emergency proceedings before the Tribunal judiciaire de Paris in November 2025 (Silktide). One early ruling in that batch went to the retailer, which is a useful reminder that these are contested cases working through the courts, not rubber-stamped penalties. Elsewhere, several national authorities began routine market surveillance of digital products and services through late 2025, well short of issuing immediate fines.

The honest read is that mass fines have not materialised, and the first wave of pressure is coming from complaints, formal notices, and litigation brought by disability organisations. That does not make the obligation softer; it means the realistic risk today is a complaint or a notice you have to answer, with penalties decided nationally if you ignore it.

There is also a cautionary tale from outside the EU about the other direction of risk: overstating your compliance. In April 2025 the US Federal Trade Commission approved a final order requiring the overlay vendor accessiBe to pay $1 million over claims that its product could make any website WCAG compliant (FTC). The lesson travels: document what you have actually tested and fixed, and don't let a badge claim conformance the testing doesn't support.

Are there transitional periods or extensions to the deadline?

There is no general extension. The application date stands. What exists instead are narrow transitional measures in Article 32 that mostly cover legacy products and contracts, not your live website:

  • Service contracts agreed before 28 June 2025 may continue unchanged until they expire, but for no longer than five years from that date (so to 28 June 2030 at the latest).
  • Products that providers were lawfully using to deliver a service before 28 June 2025 may keep being used until 28 June 2030.
  • Self-service terminals lawfully in use before 28 June 2025 may continue to the end of their economic life, capped at 20 years from when they entered use.

Read those carefully before you lean on them. They give breathing room for things like an old ticketing kiosk or a multi-year hardware contract. They do not give your e-commerce site until 2030 to add alt text and fix keyboard access. For ordinary web content, the date that applies to you is 28 June 2025.

What does meeting the deadline actually require?

The EAA says you must be accessible; EN 301 549 is the standard that says how. The current legally referenced version, v3.2.1, incorporates WCAG 2.1 Level AA for web content, so WCAG 2.1 AA is the practical bar today (a v4.1.1 update aligning with WCAG 2.2 is expected, but until it is formally cited, 2.1 AA is what counts). Meeting the relevant parts of EN 301 549 also gives you a presumption of conformity with the EAA, which is why it doubles as both the technical target and the documentation framework via its Annex C.

Two things follow. First, you need an accessibility statement: the EAA expects in-scope providers to publish information explaining how the service meets the requirements. Second, you have to actually know where you stand, and that takes two layers of testing. Automated tools catch the high-frequency, machine-detectable defects quickly, but only a share of the total. Deque's analysis of more than 2,000 audits found automation identified about 57% of issues by volume, while estimates that count the share of WCAG success criteria put it closer to 30% (Deque). Either way, a real gap remains that only manual review closes. Our WCAG checklist gives you the manual list so the part a scanner can't judge doesn't get skipped.

What happens if you miss the deadline?

Not an automatic penalty. The first consequence is usually a complaint or a formal notice through your national authority or from a disability organisation, asking you to fix specific barriers within a window. Ignore that, and the matter can escalate to enforcement action and penalties set under your country's transposition, plus the reputational cost of being named. The point of the law is to get barriers removed, so showing documented, ongoing effort puts you in a very different position from a business with no visibility into its own problems. Treat the deadline as the point your obligation became active and your evidence trail started to matter, not as a cliff edge with a fixed fine attached.

What should you do now if you're behind?

Start with a measurement, not a panic. Scan your most important pages for the machine-detectable issues, then run a manual pass for what the scanner can't see, like completing checkout with a keyboard and whether focus order makes sense. Triage the findings (fix critical and serious issues first), publish an honest accessibility statement that records your current status and your plan, and keep re-testing as you ship. Being partway there with a documented plan is a defensible place to be. Claiming you're done when you aren't is the part that gets businesses into trouble.

Frequently asked questions

Has the EAA deadline already passed?

Yes. The European Accessibility Act applies from 28 June 2025, so the deadline is in the past and the obligation is current for in-scope businesses.

Is there an extension to the EAA deadline?

There is no general extension. Article 32 provides narrow transitional periods for certain pre-existing service contracts and products (up to 28 June 2030) and self-service terminals (up to 20 years), but these do not extend the date for ordinary website content.

What is the penalty for missing the EAA deadline?

Penalties are set by each member state, not by the EU centrally, and must be effective, proportionate, and dissuasive. There is no single EU-wide figure, and enforcement so far has run through complaints, formal notices, and court cases rather than automatic fines.

Does the EAA deadline apply to businesses outside the EU?

Yes. If you provide a covered consumer service to customers in the EU, you are in scope regardless of where your company is based.

What standard do I need to meet by the deadline?

EN 301 549, which currently incorporates WCAG 2.1 Level AA for web content. Meeting the relevant clauses gives a presumption of conformity with the EAA.

Check where your site stands

The deadline has passed, so the useful move now is to find out where you actually are. Run a free scan to surface the machine-detectable issues on your key pages, then work through the manual checklist for what a scanner can't judge. You'll have a real picture to act on, and the evidence to write an honest accessibility statement instead of a guess.

Pavel Charkasau, founder, wcagc.com. Last updated 29 June 2026.

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