European Accessibility Act: how to comply with WCAG 2.1 AA in 2026
The European Accessibility Act has been in force since 28 June 2025. We explain who's covered, what WCAG 2.1 AA requires, and how to audit your site to avoid penalties.
The European Accessibility Act (EAA) has been in force across the European Union since 28 June 2025. For most companies, the question is no longer "when does it apply?" but "does my website actually comply?". This guide summarises what the law requires, who is covered, and how to approach an accessibility audit without wasting time.
Who does the EAA apply to?
Directive (EU) 2019/882 extends accessibility obligations — previously focused on the public sector through Directive (EU) 2016/2102 and Spain's Real Decreto 1112/2018 — to the private sector. After national transposition, the following are covered, among others:
- E-commerce and online sales applications
- Consumer banking and payment services
- Transport services and ticket booking
- E-books and reader software
- Electronic communication services
Service-providing microenterprises (fewer than 10 staff and under €2M turnover) are exempt, but the exemption does not extend to products. It's worth checking case by case with legal counsel.
The technical standard: WCAG 2.1 AA
The harmonised standard EN 301 549 — referenced by the EAA — relies on WCAG 2.1 Level AA. AAA is not required. In practice, the highest-impact areas are:
- Alternative text on images and non-text content
- Color contrast minimum 4.5:1 for body text and 3:1 for large text
- Full keyboard navigation without focus traps
- Heading hierarchy (single
h1, orderedh2/h3) - Form fields with associated labels via
<label for>oraria-labelledby - Visible focus indicators
- Declared language via
<html lang> - Compatibility with screen readers and assistive technologies
Penalties in Spain
Real Decreto 1112/2018 sets out the sanctions regime; non-compliance can lead to serious or very serious fines. But the real risk goes beyond fines: an inaccessible site excludes people with disabilities (1 in 6 Europeans, according to Eurostat), hurts SEO, and damages brand reputation.
The 9 most common issues we find
In our audits we repeatedly see the same findings:
| Issue | Frequency | Severity |
|---|---|---|
Images without alt attribute | Very high | Error |
Missing <html lang> | High | Error |
| Incorrect heading hierarchy | High | Warning |
Forms without associated <label> | High | Error |
| Generic link text ("click here", "more") | Medium | Warning |
Missing viewport meta | Medium | Error |
Missing or duplicate <h1> | Medium | Warning |
| Incorrect ARIA usage | Medium | Error |
| Insufficient contrast | Medium-high | Error |
How to audit your site: three layers
A complete audit combines three levels:
- Automated: a tool detects roughly 30–40% of technical issues. Useful for scanning many pages quickly. You can start with our free web accessibility scanner.
- Manual: keyboard navigation, reading order review, visible focus, transcripts, captions. Requires WCAG knowledge.
- With assistive technologies: VoiceOver, NVDA, JAWS and screen magnifiers, simulating real-world use.
Only the combination of all three gets you to real compliance. Automated tools are a starting point, not a certificate.
How to get started this week
If you haven't audited your site yet, this is the shortest path:
- Run the free scanner against your home page and two key pages (login, checkout, contact form).
- Fix critical "error" issues:
alt,lang,<label>and contrast. These typically recover 10–30 accessibility points without touching the design. - If there are structural barriers (navigation, focus order, misused ARIA), consider a professional audit with a prioritised remediation plan.
Conclusion
EAA compliance is no longer optional. The good news: the highest-impact fixes are technical and fast to apply. A serious audit combined with a well-prioritised remediation plan usually brings a site to AA conformance in weeks, not months.
Need a professional audit, or unsure whether your site falls under the EAA's scope? Get in touch and we'll review your case.