Web accessibility requirements in the EU

In effect by mid-2025.

The European Accessibility Act. Image: https://wpvip.com/wp-content/uploads/sites/3/2023/10/European-Accessibility-Act-2025-featured-blog-image.png

Depending on your field of work as a UX designer, you may have come across accessibility requirements from time to time. These requirements dictate how digital products must comply with accessibility standards, to make the product more accessible to all users, including users with disabilities.

In the EU, a significant change is coming. From mid-2025, all private companies must comply with a new set of accessibility requirements to improve usability for users with disabilities. Government institutions in Denmark already follow these regulations by law, but now the private sector must comply as well.

The deadline is Approaching

The Web Accessibility Directive (WAD) primarily targets public sector websites and applications. However, the game is changing with the introduction of the European Accessibility Act (EAA).

As of a deadline set by the European Union and the EAA, within June of this year (2025), most private companies should have made changes and adjustments to adhere to the new EAA.

As of the 28th of June 2025, the EAA will come in to effect.

The EAA aims to standardize accessibility requirements across EU countries, replacing fragmented national laws.

But first let’s travel back in time an have a look at how the EU’s accessibility requirements have evolved over time.

Data and insights from multiple sources: Kruso — Web Accessibility, European Union Directive. Design by author.

The EU didn’t do this overnight

For many designers in the private sector this may come as a bit of a surprise and may be accompanied by an increase workload because of the rapidly approaching deadline.

But this is by far something the EU just have come up with overnight and the backing of this is quite large according to studies done on this topic.

A study done in 2015 by the EU, with the goal of assessing the impact. With the study focus on the approximation of the laws, regulations and administrative provisions of the Member States as regards the accessibility…

The study saw that 97 % of 25.516 respondents agree that people with disabilities should be able to participate fully in society like people without disabilities.

78 % of Europeans think that having common rules on accessibility in the EU will make it easier for companies to operate in another EU country.

Data from respondents from all 27 member states regarding the question: “Do you think that having common rules in the EU will make it easier for companies to operate in another EU country?”. Graph from: https://ec.europa.eu/social/BlobServlet?docId=15018&langId=en

Across Europe as a whole, 48% agree that “existing rules on accessibility are sufficient to ensure them a good access to goods and services” whilst 47% disagree.

Data from respondents from all 27 member states regarding the question: “To what extent do you agree with the following statement regarding people with disabilities: existing rules on accessibility are sufficient to ensure them a good access to goods and services”. Graphic from: https://ec.europa.eu/social/BlobServlet?docId=15018&langId=en

Who Are Going to be Affected?

The European Accessibility Act (EAA) introduces new requirements to ensure that certain products and services are accessible to people with disabilities. These rules apply across the EU and aim to create a more inclusive digital and physical environment.

The following list and data is from a Danish government site and may vary in other EU member states depending on how that country implements the EAA according to national and local law.

The EAA applies to various products and services, including:

• Technology & Devices: Computers, tablets, smartphones, operating systems, routers, modems, e-book readers, and TV receiver boxes.
• Self-Service Machines: ATMs, payment terminals, ticket machines, check-in kiosks, and interactive information screens.
• Digital Services: E-commerce platforms, e-books, online banking, and electronic communication services (e.g., internet access and emergency calls).
• Transport & Travel: Websites, apps, e-tickets, information screens, and interactive terminals related to travel services.
• Banking & Financial Services: Credit agreements, investment services, and electronic payment services.
• Media & Entertainment: Streaming services and related websites/apps.

What are the requirements?

The requirements are not easy to summarize. They are complex and vary depending on the type of digital product or service your company offer. Some products may face specific accessibility requirements, while others may be unaffected if they don’t fall within certain categories requiring compliance.

The 4 Principles of Accessibility

The main requirements will always be that the companies must “comply” with the 4 principles of accessibility

• Be Perceivable — Information must be available in multiple formats (e.g., screen readers, captions).
• Be Operable — Products/services must be navigable without requiring a mouse (keyboard-friendly).
• Be Understandable — Clear instructions, labels, and logical navigation.
• Be Robust — Work with assistive technologies like screen readers.

Levels of Compliance

If a company want to be complaint to the EAA, basic levels of compliance within web accessibility must be meet. Here is a list of the different levels of compliance within the Web Content Accessibility Guidelines or WCAG.

These are as following:

Level A — This is the minimum level of compliance. Addresses the most critical barriers that prevent people with disabilities from accessing content.

Examples of Level A requirements:

• Providing alt text for images.
• Ensuring that all functionality is available via keyboard navigation (not just a mouse). Tabulation is key here.
• Avoiding content that flashes more than three times per second (to prevent seizures).

Level AA — The most widely adopted standard, including in the European Accessibility Act (EAA). Ensures that websites and digital services are reasonably accessible to most users with disabilities.

Examples of Level AA requirements:

• Text must have a sufficient contrast ratio (e.g., dark text on a light background).
• Forms should include clear labels and instructions.
• Websites should be navigable in a logical and predictable way.

Level AAA — The most comprehensive level, but not mandatory for most businesses. Provides the best possible experience for people with disabilities.

Examples of Level AAA requirements:

• Sign language interpretation for video content.
• Enhanced contrast ratios for maximum readability.
• Alternative text descriptions for complex visual content like graphs.

Disclaimer

After extensive research on the EAA, I still find it unclear exactly when a company must be fully compliant. The June 28th, 2025, deadline seems to mark the point by which companies should have made the necessary accessibility improvements.

Much of the official material — whether from the EAA or my own government — is written in complex legal language, making it difficult to extract the practical implications.

For context, these are my observations as a UX designer with experience working with WCAG and accessibility requirements.

If you’re interested in knowing more about the EAA, I can recommend the EU’s website — here’s plenty of useful material to read and learn more about the web accessibility requirements across the European Union.

The following study was very insightful and helpful to my research: Impact assessment accompanying Proposal for a Directive on the approximation of the laws, regulations and administrative provisions of the Member States as regards the accessibility requirements for products and services

Thank you for reading.

Hi, I’m Marcus Fleckner — a UX/UI designer and freelance photographer. I write about my passion for design, maps and photography. Join my weekly newsletter📨 to get fresh insights and inspiration.