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EAA Compliance Requirements: A Complete Checklist

June 28, 2025 was the compliance deadline for the European Accessibility Act. With the deadline now passed, organizations in (and out) of the EU must bring their digital content into compliance. Failure to do so can result in expensive fines and penalties. Below, we’ll review the compliance deadline and the requirements organizations must meet to be considered compliant.

Author: Missy Jensen, Senior SEO Copywriter

Published: 05/06/2026

Blank calendar with text reading 'EAA' on one of the dates. The accessibility symbol is in the background.

Enforcement of the European Accessibility Act(opens in a new tab) (EAA) began on June 28, 2025. This means any organization selling digital products or services to EU customers must comply with the accessibility requirements set out in the act. 

Below, we’ll discuss exactly what those requirements are, how to meet them, and how doing so unlocks huge opportunities for your business.

Who Needs to Comply with the EAA?

Unlike other accessibility laws, which only apply to public-sector organizations, the EAA also applies to private-sector companies, including e-commerce, banking services, media, transportation, business-to-business, business-to-government, and restaurants. 

There are exemptions to EAA compliance: micro-enterprises with less than 10 employees and an annual turnover below €2 million. These organizations do not need to comply with the EAA.

The EAA and EN 301 549

Another key EU accessibility standard to be aware of is EN 301 549(opens in a new tab). EN 301 549 is the harmonized European ICT accessibility standard that formally links EAA legal obligations (grounded in POUR principles, not the Web Content Accessibility Guidelines(opens in a new tab) (WCAG)) to concrete technical criteria. More simply, EN 301 549 is the technical rulebook that explains what “accessible” actually means under EU law. 

Under Article 15(1), meeting the EN 301 549 requirements means you're considered EAA-compliant. Because EN 301 549 incorporates WCAG 2.1 Level AA as its technical benchmark for accessible content, that's the standard organizations should aim for.

An important note: it’s EN 301 549 that enforces WCAG, not the EAA.

How to Meet EAA Compliance Requirements

With the EAA deadline now past, it’s time to take more proactive steps toward compliance. As mentioned above, the EAA does not enforce WCAG guidelines; instead, it enforces POUR principles, which require content to be perceivable, operable, understandable, and robust. However, following WCAG standards does put your organization in a good position for EAA compliance

Below is a checklist of all 78 WCAG success criteria. We recommend starting with Level A and Level AA features, as these address most accessibility barriers.

WCAG Checklist Level A

Success Criteria

Description

Complete

Non-text Content

All non-text content (i.e. images, image buttons, and image map hot spots) have appropriate alternative text.

Audio-Only and Video-Only

Descriptive and accurate transcripts are provided for video- and audio-only content.

Captions

Captions are provided for pre-recorded videos or on-live videos (e.g., YouTube)

Information and Relationships

Headings include the right semantic markup. Tables are linked to the appropriate headers and include captions if necessary. Text labels are associated with the right form inputs.

Meaningful Sequence

Navigation order follows code order; navigation is clear and intuitive.

Sensory Characteristics

Instructions are not dependent on visual location, shape, or size (i.e., ‘Instructions are listed on the right’ or ‘Click the square button to continue’).

Use of Color

Color alone is not used to portray information, nor is it used to distinguish links from surrounding text unless the color contrast ratio is appropriate.

Audio Control

Users can pause, stop, change volume, or mute audio content that automatically plays on a page for longer than three seconds.

Keyboard

Web elements can easily be shared via a keyboard and include pager-specific keyboard shortcuts.

No Keyboard Trap

Keyboard focus and shortcuts are not locked or trapped on any page elements.

Character Key Shortcuts

Users must be able to disable key commands and change to non-printable keys, such as (Ctrl, Alt, etc.).

Timing Adjustable

Pages with time limits allow users to adjust, turn off, or expand the time limit.

Pause, Stop, Hide

Automatically moving, blinking, scrolling, or updating content lasting longer than five seconds can be paused, stopped, or hidden by users.

Three Flashes or Below

Page content does not flash more than three times per second.

Bypass Blocks

Users can skip navigation or other page elements that are repeated across web pages.

Page Titles

The webpage has a descriptive, informative page title.

Focus Order

The order of links is clear and follows a logical, intuitive order.

Link Purpose

Users can understand the purpose of a link from the text alone. Links with similar text that redirect to different locations are easily distinguishable.

Pointer Gestures

User actions can be performed with a single pointer gesture.

Pointer Cancellation

Inadvertent activation of controls is avoided by non-use of the ‘onmousedown’ activation.

Motion Actuation

Functionalities triggered by user movement or moving the device can be disabled, and similar functionality can be achieved via standard controls like buttons or controls.

Error Identification

Form validation or input errors are clearly identified and access to the error is quickly provided.

WCAG Checklist Level AA

Success Criteria

Description

Complete

Captions

Live media with audio constraints synchronized captions.

Audio Description

Users have access to audio descriptions for non-live video.

Orientation

Web page orientation is not limited to portrait or landscape; users can adjust as needed.

Identify Input Purpose

Fields that collect certain user information have an ‘autocomplete’ attribute defined.

Contrast

Both text and images have a contrast ratio of at least 4.5:1. Large text has a ratio of at least 3:1.

Resize Text

Page elements are still readable and functional when zoomed to 200%.

Images of Text

If a visual representation can be portrayed through text alone, an image alone is not used to present text.

Reflow

Functionality is not lost when content is presented at a width of 320 pixels. Horizontal scrolling is avoided as much as possible.

Non-Text Contrast (Minimum)

A minimum contrast ratio of 3:1 is available for different objects, such as icons, charts, or graphs.

Text Spacing

Content or functionality is not lost when users adjust paragraph spacing.

Content on Hover or Focus

Content presented in hover or focus can be dismissed without moving the keyboard or printer.

Multiple Ways

Users have more than one way to find other web pages on a site.

Headings and Labels

Page headings and labels are informative and are not duplicated unless absolutely necessary.

Focus Visible

A visible indicator is present for page elements when they receive a keyboard focus.

Focus Not Observed

Elements with keyboard focus are entirely visible.

Dragging Movement

Actions that require pointer dragging can also be done with a single pointer.

Target Size

Pointer sizes are at minimum 24 by 24 pixels unless specified otherwise.

Language of Parts/Page

Language of pages is easily identifiable via the ‘lang’ attribute.

Consistent Navigation

Elements that repeat across a web page (e.g., a search bar) are consistently labeled as such across individual web pages.

Error Suggestion

When an error is detected, suggestions are provided for how to remedy the issue in a timely, accessible way.

Error Prevention

If a user changes or deletes financial, legal, or test data, the action can be reversed, confirmed, or verified as needed.

Excessive Authentication

Cognitive functions are not required during authentication processes unless it can be completed in another way, bypassed, or identification of non-text content is provided by the user (e.g., user-provided image).

Status Messages

Status messages are announced to screen readers via live region or ARIA alerts.

WCAG Checklist Level AAA

Success Criteria

Description

Complete

Sign Language

Sign language interpretation is provided for media with audio.

Extended Audio Description

When the original video contains insufficient pauses and is not optimized for audio description, a separate video with sufficient pauses and audio descriptions is provided.

Media Alternative

Pre-recorded media includes a descriptive transcript.

Audio-Only

Descriptive text is provided for live content that contains audio.

Identify Purpose

ARIA is used to enhance HTML semantics, enabling users to more easily understand the purpose of interface elements.

Contrast

Images and text have a color contrast ratio 7:1; large text has a contrast ratio.

Low or No Background Audio

Audio content has little to no background noise, ensuring it is easily distinguished.

Visual Presentation

Blocks of text over one sentence in length are: Less than 80 characters wide, not fully justified, have adequate line spacing, include appropriate foreground and background colors, and does not require horizontal scrolling if size is doubled.

Images of Text

Text within an image is used only for decoration, or if the information cannot be presented through text alone.

Keyboard

All functionalities are available via the keyboard.

No Timing

There are no time limits or constraints to page content or functionality.

Interruptions

Interruptions such as alerts or updates can be postponed by the user.

Re-Authenticating

Users can re-authenticate a page and continue activities without losing data.

Timeouts

Users are adequately warned of timeouts that can result in data loss (unless data can be preserved for more than hours of user inactivity).

Three Flashes

No page content flashes three times per second.

Animations from Interactions

Non-essential animations and movements can be disabled by users.

Location

A web page that’s part of a sequence of web pages are indicated as such through breadcrumbs or specifying sequence steps.

Link Purpose

Users can distinguish the purpose of each link through link text alone.

Section Headings

Sections of content are designated using headers.

Focus not Obscured (Enhanced)

Elements with keyboard focus are entirely visible.

Focus Appearance

Instances where custom indicators or backgrounds are in place have at least a 3:1 contrast between focused/unfocused states, and are at least as large as the area of 2 pixel thick perimeter surrounding the element.

Target Size

Clickable targets are 44 by 44 pixels in size unless an alternative target size is provided.

Concurrent Input Mechanisms

Content is not limited to one specific input type (i.e., keyboard-only or touch-only) and supports alternative inputs.

Unusual Words

Unfamiliar or ambiguous words are defined through an index, definition list, or other appropriate method.

Abbreviations

Unfamiliar abbreviations are expanded and defined the first time it is used.

Reading Level

More understandable alternatives are provided for advanced content (typically provided for content above a ninth-grade reading level).

Pronunciation

Pronunciation guides are provided for words that are vital to the comprehension of the page.

Change on Request

Substantial changes (i.e. spawning of pop-up windows or changes in keyboard focus) are initiated by the user and can disable options if desired.

Help

Instructions or cues are provided to users who need assistance to complete tasks.

Error Prevention

Users can reverse, verify, or confirm submissions after information is submitted.

Accessible Authentication (Enhanced)

Cognitive function tests are not required for any step in the authentication process unless the test can be bypassed or completed with assistance from another mechanism.

The Benefits of EAA Compliance

The EAA is not just another regulation. It’s a huge step in creating a more accessible digital and physical marketplace. It’s also one that unlocks numerous benefits:

  • Minimizes financial and legal risk: Meeting EAA requirements reduces your exposure to fines, penalties, and market restrictions, and lowers the likelihood of costly legal action down the line.

  • Higher SEO rankings: Accessible websites rank higher in search results — and the overlap between accessibility and SEO is only growing, putting your products in front of more people organically.

  • Expand your audience reach: More than 135 million people in the EU live with a disability(opens in a new tab). By making your digital content more accessible, you can tap into this underserved market and unlock new revenue opportunities.

  • Maintain a strong business reputation: By meeting EAA requirements, you showcase your commitment to providing an accessible, inclusive experience for all users, which builds trust with consumers, partners, and investors.

The bottom line: meeting EAA compliance requirements goes far beyond just fulfilling legal obligations. EAA compliance delivers tangible benefits that drive significant business growth and long-term success.

Is It Too Late for EAA Compliance? 

EAA enforcement has been in effect since June 28, 2025. Organizations that provide products or services within the EU (even if they’re not headquartered there) must meet EAA accessibility requirements. The EAA is now a national law across all EU member states, with individual governments responsible for ensuring compliance. Organizations that have not yet achieved compliance face active enforcement risk and should prioritize fixes. 

As mentioned above, failing to meet EAA requirements can result in serious consequences, both financially and from a business perspective. Financially, non-compliance can result in fines and penalties of up to €100,000. You may also face market restrictions for failing to meet accessibility best practices. From a business perspective, non-compliance can damage your brand reputation, especially given the increased public awareness of accessibility issues. Failing to meet accessibility requirements can put your company in a negative light, eroding customer trust and decreasing brand loyalty.

Close the Gap on EAA Compliance with AudioEye

EAA enforcement is active, and the window to get compliant is closing. AudioEye gives you the fastest, most defensible path forward: automated detection that identifies more WCAG issues than competing tools in independent testing, Expert Audits from accessibility specialists and members of the disability community, and AudioEye Assurance, the only legal guarantee that has held up in court. 

Whether you're just starting or closing the final gaps, start your path to accessibility with a free accessibility scan.

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