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Meeting European Accessibility Act (EAA) Standards: A Developer's Checklist

Joseph Gordon-Levitt

Feb 21, 2025 am 10:15 AM

Meeting European Accessibility Act (EAA) Standards: A Developer’s Checklist

This comprehensive guide provides a step-by-step checklist for developers to ensure their digital products comply with the European Accessibility Act (EAA). It's designed to help you audit, rectify, and future-proof your work, avoiding last-minute compliance struggles.

Key Highlights:

The EAA mandates website, app, and digital interface accessibility (WCAG 2.1 AA) for EU-based businesses with 10 employees and €2M annual revenue, including non-EU companies selling to EU customers.
The compliance deadline is June 28, 2025. Non-compliance risks substantial fines (€50K–€100K ), market restrictions, and even imprisonment (in some EU countries).
Proactive accessibility integration into development workflows, automated testing, and adherence to standards like keyboard navigation, semantic HTML, ARIA (when necessary), and assistive technology compatibility are crucial.

Understanding the European Accessibility Act (EAA):

The EAA is a significant EU regulation aimed at improving accessibility across digital and physical products/services. It impacts organizations with over 10 employees and €2 million annual turnover, encompassing businesses outside the EU selling within the EU.

Compliance is mandatory by June 28, 2025. Failure to comply can result in severe penalties.

The EAA's core goals are:

Eliminating barriers for disabled users accessing digital products and services.
Standardizing accessibility requirements across the EU.
Fostering business growth through a unified accessibility framework.

Affected Industries and Services: The EAA directly applies to various sectors, including:

Financial services (online banking, ATMs)
E-commerce (online stores, checkout systems)
Telecommunications (customer portals, VoIP)
Transportation (digital ticketing, scheduling systems)
Publishing & media (e-books, streaming services)

Exemptions (with caveats):

While some businesses may qualify for limited exemptions (micro-enterprises, undue burden, legacy products), they still need to provide an accessibility statement detailing compliance efforts and remaining barriers.

The Developer's EAA Checklist:

The EAA aligns with WCAG 2.1 Level AA and EN 301 549, focusing on perceivable, operable, understandable, and robust digital products. This checklist guides you through integrating accessibility:

Comprehensive Accessibility Audit: Conduct a thorough audit using automated tools (WAVE, axe DevTools, ARIA by Equally AI, Lighthouse) and manual testing (keyboard navigation, screen reader compatibility, focus management). Automated tools identify common issues (missing alt text, poor color contrast), but manual testing is crucial for a complete assessment.
Keyboard Accessibility: Ensure all interactive elements are navigable via keyboard (Tab, Shift Tab, Enter, Space). Implement clear focus indicators. Properly manage focus within modals and pop-ups.
Semantic HTML & ARIA: Prioritize semantic HTML for structure. Use elements appropriately (headings, lists, labels). Use ARIA only when necessary to enhance native HTML functionality.
Meaningful Text Alternatives: Provide descriptive alt text for images and icons. Include transcripts or captions for videos and audio.
Sufficient Color Contrast: Maintain WCAG-compliant color contrast ratios (4.5:1 for normal text, 3:1 for larger text). Use tools like Contrast Checker to verify.
Mobile & Responsive Design: Ensure responsive design adapts to various screen sizes, avoiding horizontal scrolling and using appropriately sized touch targets.
Documentation & Continuous Improvement: Maintain a record of accessibility issues, fixes, and ongoing tasks. Integrate automated accessibility checks into your CI/CD pipeline.
Accessibility Statement: Publish a statement detailing your compliance status, known limitations, improvement plans, and contact information for reporting issues.

Third-Party Integrations: Carefully assess the accessibility of third-party tools. Request accessibility statements from vendors. Test integrations and consider alternatives if necessary.

Why the EAA Matters to Developers:

The EAA's legal and financial implications are significant. Non-compliance leads to penalties, impacting development teams directly. Beyond compliance, accessibility expands your audience, improves UX, and strengthens your company's image. Proactive accessibility is crucial for future-proofing your work in a constantly evolving regulatory landscape. Prioritizing accessibility from the outset builds better software and reduces long-term costs.

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