Is your product ready for the European Accessibility Act?

The practical baseline is EN 301 549, which for web and mobile content maps to Web Content Accessibility Guidelines (WCAG) Level AA (2.1 in V3.2.1, 2.2 in V4.1.1). These failures are among the most common in real-world audits, so start here.

• Every interactive element is reachable and operable by keyboard alone.Unplug the mouse and complete your primary journey, including checkout or sign-up.
• Focus is always visible.You can see where you are on the page at every step of that keyboard journey.
• Text meets minimum contrast.4.5:1 for body text, 3:1 for large text and meaningful user interface components.
• Every meaningful image has useful alternative text.Describing purpose, not filename. Decorative images are marked as such.
• Every form field has a programmatically associated label.Placeholder text alone is not a label.
• Errors are identified in text and explain how to fix them.Color alone never carries the message.
• Link and button text describes its destination or action.No bare “click here” or “read more” out of context.
• Headings are real headings, in logical order.Structure is marked up semantically, not simulated with bold text.
• Content reflows at 400% zoom without horizontal scrolling.
• Video has captions; audio has a transcript.
• The mobile app works with VoiceOver and TalkBack.Tested on device, not assumed.
• Nothing depends on color alone to convey meaning.
• Time limits can be extended, adjusted or turned off.

Automated tooling reliably catches only a portion of real barriers — commonly estimated at around a third to a half. A green score is a starting point, not evidence of conformance.

• Automated scans run in continuous integration, not just once before launch.
• Manual keyboard and screen-reader testing has been done on primary journeys.By someone who knows what correct behavior sounds like.
• We have tested with disabled users.The step most teams skip, and the one that surfaces what tooling cannot.
• Accessibility is in our definition of done.Not a separate remediation project scheduled for later.

Conformance is not only technical. The EAA imposes paperwork obligations, and this is where otherwise-compliant organizations get caught out.

• We publish an accessibility statement.Explaining how the service meets requirements, in accessible format, and easy to find.
• There is a working feedback channel for accessibility problems.And someone is actually accountable for responding.
• We hold technical documentation evidencing conformance.Products additionally require an EU declaration of conformity and CE marking.
• Accessibility requirements are written into supplier and procurement contracts.Third-party widgets, payment flows and embedded content are still your liability.
• Any exemption we rely on is documented and assessed, not assumed.“Disproportionate burden” and “fundamental alteration” require a documented, periodically reviewed assessment — a reasoned argument you must be able to produce, not a box to tick.
• We know which national authority regulates us in each market we sell into.Enforcement is national, and it differs.