European Accessibility Act (EAA)
What is the European Accessibility Act (EAA)?
The European Accessibility Act (EAA) is an EU directive requiring certain products and services, e-commerce among them, to be usable by people with disabilities. Member states have applied the measures since 28 June 2025. For a website that means WCAG level AA: contrast, keyboard operation, labelled fields and an order anyone can complete. Micro-enterprises providing services stay outside the obligations.
Example
A sports-equipment shop with eight staff and €1.4 million turnover meets the definition of a micro-enterprise — fewer than ten people, and turnover or balance sheet total at or below €2 million — and as a service provider sits outside the act’s obligations. The next year it hires three more and has eleven people: it no longer does, whatever the turnover. The thresholds are easy to calculate; whether a particular business is in scope is a lawyer’s question, not the site builder’s.
What it means inside a shop that is in scope: the order can be completed with the keyboard alone; the address fields have labels a screen reader reads out; “invalid phone number” appears as words beside the field rather than as a red border; the label on the pay button clears 4.5:1 against its background. The confirmation email and the invoice are part of the service too.
Why it matters for a business
The dates have passed: the measures have applied since 28 June 2025. A service contract agreed before that date may run on unchanged until it expires, and no later than 28 June 2030; a self-service terminal already in use may stay to the end of its economic life, and no longer than 20 years from entering use.
Enforcement is national: products sit with the market surveillance authorities, services with whichever body each state designates; a consumer or an organisation can complain, and penalties are set by the member state. In Bulgaria the directive is transposed by the Accessibility Requirements for Products and Services Act, in force since 2025.
The technical benchmark is not new. The European standard EN 301 549 points at WCAG: the edition the EU cites today asks for WCAG 2.1 level AA, while edition 4.1.1, published in September 2026, moves to WCAG 2.2 and is still to be cited in the Official Journal. WCAG 2.2 builds on 2.1 and adds criteria, so “EAA conformance” for the web means the same testable list that web accessibility uses anyway.
Labelled fields, contrast, keyboard operation and clear error messages are part of how we build the order path in online store development. A conformance audit, and the legal assessment of scope, are separate.
What to ask
- Is the business in scope at all — by headcount, turnover and type of service? A lawyer answers that, not a developer.
- Can the whole order be completed with a keyboard?
- What are the contrast ratios on the buttons and the body text?
- Is there an accessibility statement and a channel for reports?
- Are the emails, invoices and documents the shop sends accessible too?
- Who checks accessibility on every later change to the shop?