EAA compliance: How to achieve and maintain it

Many businesses may discover a gap between the current accessibility of their digital product or service and compliance with the European Accessibility Act (EAA) requirements. Closing this gap might seem like an impossible task.

Don’t go searching for quick fixes just yet! In this article, we’ll help you plan and execute web accessibility practices like a pro. Anyway, when law is considered, there are no shortcuts to ensuring the accessibility of websites and apps. The right methodologies and choosing a reliable ally can secure you compliance.

For more information about the EAA, read our first blog post from this series: EAA’s scope and impact on web accessibility

Table of contents:

• Ensure conformance with relevant standards
• Conduct regular testing
• Document accessibility efforts
• Ensure accessibility of third-party tools
• Keep accessibility up to date
• Foster a culture of accessibility
• Speed up your accessibility efforts with an expert partner

Ensure conformance with relevant standards

Start with WCAG 2.1

To ensure compliance with the EAA for digital services (websites and applications) follow EN 301 549. It is the primary European standard for ICT accessibility, incorporating the Web Content Accessibility Guidelines (WCAG) 2.1 Level A and AA. This means if your digital experiences already meet the WCAG 2.1 Level AA, you’re well on your way to conforming with EN 301 549 too.

Cover requirements beyond WCAG 2.1

Although EN 301 549 builds on top of WCAG 2.1 Level AA, there are additional requirements for:

• User preferences and settings (dark mode, fonts, color contrast, motion…)
• Documents and support services (accessibility statement and help pages are both examples of documenting accessibility and compatibility features)
• Authoring tools (e.g. comment section on the website (review) is considered an authoring tool)
• Biometrics, voice and video communication, real-time text

Consider aiming for WCAG 2.2 Level AA

WCAG 2.2 will soon be part of EN 301 549, and with that, a part of the Web Accessibility Directive (WAD) and the EAA. It is expected that version 4.1.1 of EN 301 549 will incorporate WCAG 2.2 by the end of 2025, or early 2026.

Even if not incorporated into the laws yet, conforming to WCAG 2.2 will save you time in the future and is considered the best practice. It is already a standard.

Make documents accessible

EN 301 549 also applies to digital and downloadable documents. All HTML documents, PDFs, Office documents, spreadsheets, and presentations have to be accessible if they are added or edited after 28th June 2025.

Even if you have an accessible HTML document on your platform, the downloadable PDF version has to be accessible too, according to the “Preservation of accessibility information during conversion” requirement of EN 301 549.

Exception: Documents published before 28th June 2025, if not updated or edited, are considered archives and do not have to comply.

Requirements for the non-web documents are explained in Guidance on Applying WCAG 2 to Non-Web Information and Communications Technologies (WCAG2ICT). Guidelines you can find here are referenced and incorporated in EN 301 549, and standards in countries beyond the EU (e.g., India, Kenya, Australia, USA).

Don’t rely on accessibility overlays and plugins

Accessibility overlays and plug-ins don’t provide compliance. They can even insert certain problems with the layout that were not present before. Learn about what plugins are useful for and their limitations.

The EAA specifically requires that digital products are designed and produced to be accessible.

Conduct regular testing

Use a combination of:

• Automated tools (e.g., axe, WAVE) to catch basic issues.
• Manual reviews using assistive technology conducted by accessibility specialists to verify compliance with WCAG 2.1 AA.
• User testing with people who rely on assistive technologies (e.g., screen readers, voice control, keyboard navigation).

Document accessibility efforts

Create and maintain an accessibility statement or Accessibility Conformance Report (ACR). Use a Voluntary Product Accessibility Template (VPAT) or similar format adapted for EN 301 549 to clearly outline how your website/app meets the relevant criteria.

This documentation helps demonstrate your commitment to compliance and can be referenced by stakeholders, regulators, and in the procurement process.

Although the EAA does not specifically require an accessibility statement, it does require that accessibility and compatibility features be documented and explained. Each EU member country decides on a format of accessibility statement needed. Get informed about what template to use for the market you are serving.

Ensure accessibility of third-party tools

A website owner is responsible for ensuring that all integrated tools, such as chat widgets, payment gateways, and booking systems, provide an inclusive user experience.

Ensuring that your tools comply with accessibility laws can be tricky. Here are some helpful steps to follow:

• Choose providers with a strong track record in accessibility.
• Check for accessibility statements and Accessibility Conformance Report (ACR) — Voluntary Product Accessibility Templates (VPATs).
• Test the tools yourself or get an assessment from a reliable accessibility service provider.
• Monitor updates and re-test accordingly to ensure updates haven’t introduced new barriers.

Keep accessibility up to date

Accessibility is an ongoing process. As you add new features or redesign your site/app, re-check for compliance.

Component testing and automated accessibility testing are crucial for consistent monitoring and a shift-left approach in development.

Stay informed about updates to EN 301 549 or WCAG to keep pace with evolving standards.

Foster a culture of accessibility

While the European Accessibility Act (EAA) itself does not explicitly mandate them, training and in-house advocacy are both widely recognized best practices that help organizations maintain compliance.

These are some ways to achieve them:

• Training sessions:
  • Offer introductory courses covering accessibility fundamentals (e.g., WCAG) to all relevant teams: developers, designers, content creators, product managers, and customer support.
  • Provide advanced or role-specific training for employees who need deeper technical knowledge (e.g., dev teams learning accessible coding patterns, QA teams performing manual accessibility tests).
  • Consider targeted tailored sessions. Building in-house expertise can be a lengthy process with a lot of way-finding. If you are in a time crunch, consider tailored training by accessibility specialists that will target the exact knowledge level of the team, while addressing issues and features relevant for your project.
• Accessibility champions:
  • Designate “champions” or “ambassadors” in each functional area (e.g., design, development, content writing, customer support).
  • Champions serve as go-to resources for their teams, disseminating best practices and helping troubleshoot accessibility issues.
• Cross-functional collaboration
  • Encourage cross-department collaboration by having champions and team members share updates on accessibility improvements and user feedback.
  • Promote knowledge sharing via internal wikis, workshops, or user testing sessions to ensure everyone stays current on new guidelines and techniques.
• Integrate accessibility into processes
  • Bake accessibility checks into existing workflows (e.g., design sprints, code reviews, QA processes).
  • Ensure that onboarding for new hires includes a module on accessibility principles, so the culture is reinforced from day one.
  • Include accessibility requirements in your procurement process. Ensure any contractors and third-party providers comply with EAA and monitor accessibility.
• Continuous improvement and monitoring
  • Set up regular audits and user testing to identify barriers and measure progress.
  • Create metrics and goals for accessibility (e.g., reducing open accessibility tickets, meeting WCAG 2.1 AA success criteria), and track them the same way you track other quality metrics.
• Leadership Support
  • Demonstrate top-level commitment by allocating budget and resources for training, user testing with assistive tech, and the necessary tools for accessibility audits.
  • Having executive endorsement for accessibility programs signals its importance and helps champions effect real change.

Speed up your accessibility efforts with an expert partner

Navigating the complexities of EAA compliance can be challenging. Partnering with an expert web accessibility solution provider can help you stay on track and meet the EAA deadline.

However, choosing the right partner requires careful consideration. Not knowing the ins and outs of complex accessibility requirements can lead to frustration and wasted time. To avoid trial and error, it’s crucial to recognize potential red flags when evaluating accessibility vendors.

AccessLiaison is a web accessibility brand of ALAS d.o.o. Our experts have 2 decades of providing top-quality IT services for different industries. Our accessibility services combine advanced technology with manual testing, accessible design, and development.

We can address all your accessibility concerns and help you achieve legal compliance, ensure enjoyable experiences for all users, and maintain accessibility over time.