2025 is here: Keys to survive the European Accessibility Act

The European Accessibility Act (EAA) represents a paradigm shift in digital inclusion within the European Union. Passed in 2019 and with compliance deadlines starting in 2025, this regulation seeks to remove barriers for people with disabilities in essential products and services, from digital platforms to physical devices such as ATMs.

Below we have compiled a series of key issues to understand and navigate it, without our digital project suffering any setbacks.

What is EAA and who is affected?

With the EAA we are not talking about a set of recommendations, but a binding directive that establishes minimum accessibility requirements to ensure equal access to goods and services.

Its application affects any entity, public or private, operating in the EU and offering products or services in key sectors such as e-commerce, digital banking, transport or telecommunications.

The products affected include consumer IT equipment (computers and operating systems), self-service terminals such as ATMs, payment machines, ticket vending machines and interactive information devices (except those integrated in means of transport). Also included are electronic readers and terminals for audiovisual or electronic communication services.

Services range from telecommunications and access to audiovisual content to digital banking services, e-commerce and key elements of passenger transport (such as websites, apps, e-tickets and real-time information). In addition, it applies to e-books and associated software, as well as interactive terminals for service provision within the EU.

It expressly excludes static content published before June 28, 2025 (e.g. historical archives on websites), pre-recorded materials prior to that date and third-party content not directly managed by the company.

Is my company obliged to comply with it?

Although the rule is broad, not all companies are required to comply with it in the same terms. Microenterprises - defined as those with fewer than 10 employees and an annual turnover of less than 2 million euros - are exempt. However, the adoption of accessible practices is recommended as a social responsibility strategy.

In addition, the directive provides for exemptions in cases of disproportionate burden, i.e. when the costs of adaptation clearly outweigh the benefits, or when the changes alter the essential nature of a product. An example cited in the regulation is digital comics, where the high visual content could justify limitations on textual accessibility.

What are the technical requirements?

The European Accessibility Act (EAA) establishes accessibility requirements for products and services in the EU, but does not define technical standards directly. Instead, it adopts EN 301 549 as a key reference, which in turn integrates WCAG 2.1 level AA as the basis for digital accessibility. EN 301 549 not only includes the WCAG 2.1 AA criteria for web content and mobile applications, but extends its scope to physical components (such as hardware, self-service terminals and telecommunication devices) and complementary services (accessible documentation, interoperability with assistive technologies).

What are the deadlines and consequences? The countdown is on

June 28, 2025 is the critical date: from then on, all new products and services must comply with the EAA. For those already in existence, such as vending machines installed before that date, the deadline extends to 2030. Penalties for non-compliance vary by country, but in Spain they can reach up to €1 million, as well as damaging the brand's reputation and restricting its ability to operate in the European market.

Well, what if I introduce a new functionality on my website?

Partial modifications to existing products and services (e.g. updating a section or adding functionality to a website) can be difficult to interpret because, in principle, only the altered parts must be accessible, while the rest maintains the deadline until 2030. However, profound structural changes (such as a total redesign) could be interpreted as a ‘new’ service/product, requiring full accessibility before 2025. New content published before that date must be accessible from launch, and unchanged static files and third party content are excluded. The key recommendation is to PROJECT - Articulo EAA (e.g. forms, web and app shopping) and avoid early comprehensive redesigns so as not to pre-empt obligations.

It doesn't affect me; why should I comply?

The European Accessibility Act (EAA) is a dynamic directive that seeks to harmonise accessibility requirements in the EU, but its scope is not static. The European Commission has already identified key products and services (such as e-commerce, transport and telecommunications), but the legal text allows for future updates to incorporate more sectors, especially those with a high impact on daily life.

As if this were not enough, the European Commission estimates that 87 million people in the EU have a disability, a group that represents a significant but historically ignored purchasing power. For example, in Spain, only 28% of mobile applications are considered accessible, limiting access to basic services such as banking and transport. Adapting products and services not only complies with business ethics, but also allows this segment to be targeted, along with older users (21% of the European population is over 65) and people in environments with technological limitations.

In addition, accessible sites tend to rank better in search engines. Accessible websites tend to follow practices such as:

• Clear semantic structure (correct use of HTML headings), favouring indexing in search engines.
• Better tagged content (alternative text in images, transcripts in videos), which enriches metadata and improves organic positioning.
• Intuitive navigation, reducing bounce rate and increasing dwell time are key factors for algorithms such as Google.

Finally, inclusive design drives solutions that benefit wider groups, such as voice control now used in hands-free devices in cars or simplified navigation that improve the experience for people with low digital literacy or slow connection environments.

These innovations, in addition to meeting standards such as WCAG 2.1 AA, position companies as leaders in usability and social responsibility.

Spain: An evolving landscape

Spain has made progress in transposing the EAA through Law 11/2023 and Royal Decree 193/2023, which extend the obligations to sectors such as energy, travel agencies or emerging digital platforms. Although the public sector is obliged from 2020 to comply with RD 1112/2018, private companies have until 2030 to adapt existing products.

In short, the EAA is a catalyst for building a fairer digital economy. Its implementation not only avoids penalties, but opens doors to underserved markets and fosters people-centred innovation. With 28 June just around the corner, it's time to act now: accessibility is no longer an extra, but the minimum standard to compete in Europe.