Are you ready for the European Accessibility Act (EAA)?

This free webinar took place online on Wednesday 3 July 2024. Watch the recording below.

Our panel of experts included:

• Christopher Patnoe, Google
• Susanna Laurin, IAAP
• Vayia Malamidou, AbilityNet
• Sabine Lobnig, Mobile & Wireless Forum (MWF)

They explained:

• What is covered by the EAA, its significance and implications
• The significance of the deadline of June 28, 2025
• The steps your organisation needs to take
• How to know whether the EAA applies to your organisation

Bonus content

• The webinar recording included a short clip of Christopher Patnoe explaining how Google is approaching the European Accessibility Act. Watch the full interview with Christopher on YouTube. 
• Our panel of experts created an FAQ based on your questions about the European Accessibility Act .

Watch the webinar for free

Watch the recording below and download a copy of the transcript and slides.

Who does the European Accessibility Act apply to?

This free webinar is ideal for accessibility professionals, compliance teams, technology teams, senior leaders, and industry stakeholders who are keen to delve into the workings of the EAA.

Unlike previous accessibility legislation, the EAA extends its reach to the private sector, including businesses with at least 10 employees and a turnover exceeding €2 million. Even companies based outside the EU must comply if they sell relevant goods or services within the European Union.

What is the European Accessibility Act?

The EAA is designed to ensure equal access to digital products and services across Europe. It applies to all businesses that engage in trade within the EU, regardless of their location.

It covers a broad spectrum of goods and services. Starting from June 2025, it will be legally binding in all EU member states. Notably, it directly impacts UK businesses and also affects suppliers to both public and private sector organisations. 

The EAA’s primary goal is to enhance the lives of disabled and older individuals within the EU by establishing a common set of regulations that replace country-specific accessibility rules. 

The Act predominantly focuses on technology, covering essential products and services within computers, smartphones, TV equipment, transportation services, banking, e-books, e-commerce, ATMs, and ticketing machines. Each product or service must meet specific standards to be legally traded within the EU. 

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Meet the Panellists

Christopher Patnoe, Head of Accessibility and Disability Inclusion at Google

Christopher Patnoe is the Head of Accessibility and Disability Inclusion for EMEA at Google. He leads Google's efforts concerning the accessibility of products, focusing on people – both Google creators and end users. He has more than 25 years experience in technology and design, including time at Apple and Disney. The London Accessibility Discovery Centre opened in November 2022 and has been a huge success, attracting external attention from all over Europe as well as building strong links with internal teams. 

Susanna Laurin, Managing Director and Chair at Funka Foundation

Susanna Laurin is the Managing Director and Chair at Funka Foundation, a European based market leading consultancy focusing on accessibility. She has been a thought leader in the field of digitalisation, inclusion and e-government for more than 20 years and she is a frequent international lecturer and debater. Susanna is the Chair of the ETSI/CEN/CENELEC Joint Working Group on eAccessibility, responsible for the development and update of the EN301549, to reflect presumed conformance of the Web Accessibility Directive and the upcoming European Accessibility Act.

Susanna is leading strategic assignments and research projects on EU level, nationally and across the world. Recent assignments for the European Commission include the formal review of the Web Accessibility Directive and a study on cognitive accessibility. 

Susanna is a co-founder, Representative to the EU and also Past Honorary Chair of IAAP, the International Association of Accessibility Professionals, as well as the Representative to the EU for the UN-initiative G3ict. 

Vayia Malamidou, Accessibility and Usability Consultant at AbilityNet

Vayia Malamidou currently works as an Accessibility and Usability Consultant at AbilityNet. Her role includes carrying out design reviews, accessibility audits, user testing and providing in-depth consultancy to organisations on web accessibility and usability. 

Having spent 20 years working in a variety of digital content projects, she now specialises in the domain of digital accessibility. She is accredited with the Certified Professional in Accessibility Core Competencies (CPACC) qualification awarded by IAAP. 

She is accredited with the Certified Professional in Web Accessibility (CPWA) qualification awarded by the IAAP.

Sabine Lobnig, Director for Communications at Mobile & Wireless Forum (MWF)

Sabine is the MWF’s Director for Communications. The MWF is the international association of companies with an interest in mobile and wireless communications including the evolution to 5G and the Internet of Things. One of the MWF’s main projects is the Global Accessibility Reporting Initiative (GARI). GARI’s mission is to inform consumers about existing accessibility solutions in the market today and help them identify devices with features that best help their individual needs. This includes mobile phones with built-in screen readers, “simple access” for persons who find today’s user interfaces overwhelming, Wearables with haptic feedback, Smart TVs that allow voice recognition for accessing features, or mobile apps that have been developed specifically to help overcome a barrier in daily life like finding accessible locations.

FAQs about The EAA

Frequently Asked Questions about the European Accessibility Act (EAA)

These questions were asked during the webinar and answered by our panelists afterwards. 

Q: There does not seem to be enough accessibility experts to understand the EAA requirements in practice. Some are multi-interpretable or vague. For instance, I see a lack of accessibility expertise at economic operators and market surveillance authorities. From a disability organisation perspective, what can we do about that we need more accessibility experts to fulfil the EAA requirements, in economic operators and in market surveillance authorities? 

Sabine Lobnig: One recommendation could be to revert them to platforms such as the International Association of Accessibility Professionals (IAAP) and start with the low level certifications. It is important for them to know that there are established syllabi and programmes on how you can get started in accessibility, and that you do not need to find all the necessary information on your own.  

Susanna Laurin: I believe the lack of basic accessibility knowledge among general web professionals (designers, content providers, developers etc.) is a much bigger problem than the lack of accessibility experts (which is also an issue). We need to make sure that higher education and vocational training on “anything” related to web includes digital accessibility. That is the key to sustainable change. DPOs (Disabled People's Organisations) can help by training its own staff and members (there are free trainings online) to become more aware and active in the space. I personally believe the lived experience of inaccessibility is a huge merit to anyone looking for a job in IT (Information Technology) – and demand will increase in 2025. 

Q: Would you recommend an Accessibility Maturity Assessment to work out where a company is now? 

Susanna Laurin: I would recommend to investigate the current status of your website/app/digital services. A maturity assessment could be part of that, as long as it is concrete. 

Q: What are the main differences between EN and Web Content Accessibility Guidelines (WCAG)? 

Susanna Laurin: The EN has a much broader scope since it covers hardware, software etc. and WCAG only covers web (you may also argue that WCAG covers apps, but the jury is still out on that one).  
The EN covers both functional performance and technical requirements, it has an annex on how to select which requirements etc. which the WCAG does not have.  
WCAG on the other hand, has “How to meet,” “Understanding” and “Techniques” documents that the EN does not have.

Q: I'm interested in the implications of the European Accessibility Act (EAA) for the UK. Christopher Patnoe mentioned partial overlap in some other markets. Has the UK adopted any standards since the Public Digital Accessibility Regulations 2018? Any additional legislation could be really helpful levers for negotiation with suppliers.

Susanna Laurin: I am not an expert in UK regulations. Organisations who want to sell products or services in scope of the EAA in the EU will have to comply with the requirements, no matter where they are based. 

Q: What is the uptake from the UK given we are no longer a member state - are they seeing higher levels of positive engagement or just minimum compliance to secure future business? 

Vayia Malamidou: We are seeing an increasing interest in the details of the EAA and its impact on UK-based organisations. As Susanna mentions in the questions above, “organisations who want to sell products or services in scope of the EAA in the EU will have to comply with the requirements, no matter where they are based”. From a business perspective, compliance with the minimum requirements is often the goal but, as the EAA includes principles for design for all, we are also seeing a growing willingness among businesses to go beyond mere compliance. 

Q: Do you think it is important that the drive/importance of taking action on accessibility is delivered from the top of an organisation? I see it is hard to do when there is not top leadership involvement because people perceive it as nice to have when it comes from elsewhere (e.g., DEI (Diversity, Equity, and Inclusion). 

Sabine Lobnig: Ideally it would be integrated into the corporate culture, but in the beginning most likely there has to be a commitment from the top.  

Susanna Laurin: I believe the drive can come from many levels depending on the type and size of the organisation. But leadership must be onboard, otherwise you risk killing yourself fighting for it. 

Q: May I please ask why EN 301 549 is being used in conjunction with the EAA. I am not suggesting that it should not, but I believe the EAA does not directly reference any kind of technical standard when it comes to compliance. Are people using EN 301 549 as it is the existing standard for the public sector? 

Susanna Laurin: Yes it does. Presumption of conformity is explained in Chapter 6 Article 15(2) of the EAA: “The Commission shall, in accordance with Article 10 of Regulation (EU) No 1025/2012, request one or more European standardisation organisations to draft harmonised standards for the product accessibility requirements set out in Annex I." The standardisation request is called mandate 587. An overview of what the mandate covers is published.

Q: Do you have an opinion on how the EAA might extend to the packaging of products named within the EAA? 

Susanna Laurin: The EAA already covers packaging of products in scope of the act. 

Q: How is compliance with the act monitored? And what are the penalties for non-compliance? 

Sabine Lobnig: Since the EAA is a market access directive, compliance will be monitored by the market surveillance authorities. They are differently organized in the member states. Penalties also differ between member states and range from fees for non-compliance to market withdrawal and in worst case even recall and prison time.

Susanna Laurin: Each member state has/will appoint relevant market surveillance authority/ies to monitor compliance and handle complaints. Penalties are also decided at member state level. 

Q: How alike and how different will this be from the Americans with Disabilities Act in what it requires and how it will be enforced? 

Susanna Laurin: It is extremely difficult to make useful comparisons between US and EU legislation as the whole legal system is so different. It would require many pages to list all the differences. Lainey Feingold and I are making a “US vs EU legislation” session at M-enabling in DC in October, I believe it will be streamed. 

Q: Is there a compliance difference between what is expected of small organisations vs large organisations?

Sabine Lobnig: Microenterprises are mostly exempt. Microenterprise is a business which employs fewer than 10 persons and which has an annual turnover or balance sheet total not exceeding EUR 2 million. 

Susanna Laurin: No. But if a small organisation claims disproportionate burden, it would of course be easier to argue that something is “too expensive” if you have a lower turnover. 

Q: Is compliance currently only based on company size? Any advice on how to push to make changes if we 'technically' are outside the size requirement?  

Sabine Lobnig: We have by now several reports that explain the business benefit of both, including people with disabilities in the workforce, as well as the benefit of accessible products and services to reach a huge target group. One example is the 2023 Accenture report.

Susanna Laurin: Compliance has nothing to do with the size of the organisation in scope of the legislation. There is an exemption for microenterprises. I personally never use legislation as a way to drive change, as that has a tendency to be a race to the bottom (i.e. minimum requirements). Explaining how accessibility can help “maximising the foreseeable use” of a product end/or service is usually a better way forward in my experience. 

Q: Where can we find links to the EAA? For the annexes and standards? 

Sabine Lobnig and Sussana Laurin:

• European Accessibility Act including annexes
• European Accessibility Act 
• Current version of the EN301549 (will be updated) 

Q: In the webinar there was a mention that the Act only requires businesses with 10 or more employees to comply.  Obviously, I would like to be as accessible as possible, but I just want to check if, as a sole trader, I am required to follow these standards and can get fined if I don't, or not?   

Sabine Lobnig: I recommend reading through the parts on Microenterprises in the Act.

Susanna Laurin: Microenterprises providing services are exempt. Not all microenterprises. 

Q: I would like to know if there has been an economic evaluation of the increased sales or turnover for firms when becoming more accessible in Europe, will businesses need a third-party accessibility audit to prove their accessibility? If yes, what qualifications will third party organisation have to offer? Either way, who will guarantee the compliance of businesses? 

Sabine Lobnig: You have three ways of showing compliance with market access directives: 

1. following harmonised standards 
2. self-assessment  
3. notified labs  

The responsible market surveillance authority will check for compliance and is the authority you need to prove compliance to.  

Susanna Laurin: The economic operator is responsible for the accessibility of their product or service. Third part assessment is not needed.  
The business case for accessibility is an eternal discussion. From a scientific point of view it is very hard to prove that increase of sales is happening because of an accessibility problem being solved, because that would require the organisation to do exactly the same marketing etc. for a period of time, measure sales and customer satisfaction (how many started sales but fell out) and then make only specific accessibility remediations and do exactly the same test again. Usually, you do not only make accessibility updates, but you also do several things at once. So how can I know that it was the accessibility solution that made sales increase? 

Q: Our website contains a lot of images of properties, with vast descriptions of holiday lets, can you provide us with some advice on how we would make this accessible? 

Susanna Laurin: I would need to look at the website to say anything useful, but from what you explain, a first step may be to make sure your images have alternative texts. 

Q: In the webinar, the mention of global harmonisation with the EU is leading the way. Several counties (including Australia, Canada, Kenya, and Mexico) have already adopted EN 301 549. Do you know which other counties are considering adopting EN 301 549?

Susanna Laurin: I do not believe anyone talked about global adoption, the use of the EN is a decision made by each country individually.  

Q: Can I ask if broadcasters and streaming companies will be required to make their content (i.e. TV shows etc.) accessible? 

Susanna Laurin: Yes. 

Sabine Lobnig: “(…), this Directive applies to the following services provided to consumers after 28 June 2025: (…) (b) services providing access to audiovisual media services;  

So, yes. 

Additionally, we have the Audiovisual Media Services Directive (AVMSD) which refers to the EAA for accessibility requirements.  

Q: I work at a UK charity where accessibility is unfortunately not a primary focus. What can I do to shift our attention to better align with EU standards on accessibility? 

Sabine Lobnig: EDF’s European Accessibility Act Toolkit for transposition might be an inspiration, as they list activities that DPOs can do to push for the EAA implementation, but you can extrapolate from there to accessibility in general.  

Susanna Laurin: I would ask: if the charity does important work that they are proud of, or any kind of communication – why would they want to exclude 15-20% of the population from their message? Meeting EU standards may not sound very appealing but taking one or two steps to make sure that their outreach reaches as many as possible may be a way forward.

Q: Could there be any impact to private company products/services that are not listed? 

Susanna Laurin: Indirectly yes. In the EU, we often talk about the “spill-over” effect. When sector A is starting to see accessibility as a natural thing to do, chances are that sector B (where companies do business with sector A) does the same thing. In the long term, the scope of the legislation could of course be widened, but I don’t see that happening any time soon. 

Q: Will companies using accessibility overlays be considered compliant? 

Susanna Laurin: An overlay does not make the website neither accessible nor compliant. 

Q: Does the Act also cover educational services? If an educational organisation is based outside the EU but the student is based in an EU country, will this directive apply? 

Susanna Laurin: The EAA covers consumer products and services. 

Q: What advice would you give to someone who has no official role or responsibility regarding accessibility implementation and working for an organization that is not really supporting these efforts? Beyond awareness (which we currently do), in your experience how can we get better prepared before we must react in noticeably short notice?

Susanna Laurin: Tricky question without context, but I believe meeting users with disabilities is what usually makes people focus on the topic. And again, I would always recommend investigating the current state – where do we have most challenges – and then start prioritising and acting from there.

Sabine Lobnig: Stress the business benefit and start implementing accessibility now. We have by now several reports that explain the business benefit of both, including people with disabilities in the workforce, as well as the benefit of accessible products and services to reach a huge target group.  One example is the 2023 Accenture report.

Q: Does the act apply to newly generated apps and websites, or if existing (older products) need to be updated by that date as well? 

Susanna Laurin: EAA covers products and services placed on the market after 28 June 2025. 

Q: Do providers of audio visual services have to (mandatory) provide subtitles and audio description, or is the requirement only that if they provide these services, they need to be clear, accessible etc? 

Susanna Laurin: EAA requirements for audiovisual media services are covered in Annex 1 Section 4. 

Q: It is difficult to gauge precisely whether our services (as a UK company) fall under the "Products or Services in scope of the Act". Can you advise where I could go to seek clarification?

Sabine Lobnig: The market surveillance authority or regulator is responsible for your sector. For telecom, it would be Ofcom for instance.  

Susanna Laurin: Read the EAA: Article 2 lists the products and services in scope. Article 3 is a list of definitions.

Q: It was mentioned that 26 out of 27 EU members have implemented EAA to local law. Which is the missing one? 

Susanna Laurin: All member states have either transposed or are in the process of transposition. Bulgaria hasn’t reported it’s measures to the voluntary repository, but that doesn’t mean they haven’t done anything. 

Q: I work in the charity sector, is there anything specific in the EAA that would be helpful for us to look into? We don’t sell products, or services, but do have an online donation service.  

Susanna Laurin: The EN301549 standard is relevant to all organisations, not only the ones in scope of the legislation.

Q: What are your thoughts on the EAA having an impact on other countries outside of the 'European continent', where companies like Samsung, Sony, Honor, LG, Huawei, are based in Asia? Do you think that changes to products will lead to a push for better global accessibility globally with manufacturers not wanting to re-create devices across regions 'just' to be complaint? 

Susanna Laurin: Yes, definitely. The EAA covers economic operators who want to sell their products or services in the EU. It usually doesn’t make economic sense to sell different versions of products to different regions, therefore it is probable that the EAA will lead to global companies selling (more) accessible products at a global scale.

Sabine Lobnig: Yes. Companies prefer to sell the same device model in all world markets without having to adjust to regional requirements. Hence, why we stressed the importance of global harmonisation. Members of the Mobile & Wireless Forum report on the accessibility features in their devices in the GARI (Global Accessibility Reporting Initiative) database (www.gari.info), which covers all regional requirements.  

Q: Who will be monitoring the compliance of the European Accessibility Act?

Sabine Lobnig: The national market surveillance authorities.  

Susanna Laurin: Surveillance authorities in each member state. 

Q: I work in a web development agency, if we are implementing a website for a client which is a private company are we directly liable under EAA for the accessibility of what is produced, or is that the responsibility of the client? 

Susanna Laurin: The economic operator manufacturing, importing, distributing or representing products or services in scope of the EAA are responsible for meeting the requirements (not the supplier of the website). But as a supplier to an organisation in scope of the act, you should be careful with the contracts you sign, so you are in agreement on what happens if your client receives a complaint. And – if you have for example the International Association of Accessibility Professionals (IAAP) certified staff, you will most probably have a business advantage. 

Q: What steps can companies take if they realize that complying with certain standards will result in an undue burden? How can they demonstrate this as part of a procurement process under the EAA? 

Susanna Laurin: This is described in Chapter 4 of the EAA.

Q: We are a company with less than 10 people and under £2m revenue, so as I understand it, we do not need to be compliant with EAA, but we use bigger vendors to sell eBooks. Will we have to be compliant to keep using these vendors?  

Susanna Laurin: A bigger vendor is in scope of the EAA, so they will need to sell e-books that are compliant. Which indirectly means that you will have to comply as well. 

Q: Are widgets and overlays outright banned to use or can they be used as a tool amongst other things? 

Susanna Laurin: Nothing is banned, but tools added on top of a website does not make the website itself compliant. Some of these tools add more accessibility issues than they claim to solve. 

Q: What is the risk that a lack of harmonisation of member states' regulations could diminish the scope of the EAA? 

Susanna Laurin: Member states can choose to go beyond the minimum requirements, not do less. I don’t see how that could diminish the scope. 

Q: Is there a course available to prepare professionals to fulfil the EAA requirements? 

Sabine Lobnig: The International Association of Accessibility Professionals (IAAP) is working on that.  

Susanna Laurin: There are many providers of courses, for example, the Funka Foundation offers customised courses depending on sector and role. There are quite a lot of free resources online as well, but I am not sure how precisely they focus on the act. 

Q: Does the Act apply to internal/colleague-used systems, as well as external/consumer-used systems? We often find it more difficult to persuade leaders to apply the same standards to colleagues as we would expect for consumers.  

Susanna Laurin: The EAA covers consumer products and services. 

Q: Why are schools excluded from EAA? 

Susanna Laurin: That sounds like a misunderstanding. EAA doesn’t define or exclude sectors, it covers products and services. In the Web Accessibility Directive, member states can opt out when comes to schools and kindergarten. 

Q: For a US company that ONLY sells products in the UK, should they be concerned with complying with the EAA? 

Susanna Laurin: Not as long as the UK doesn’t decide to implement the EAA. 

Q: Does the European Commission plan to have a informational meeting regarding the EAA act? Companies may not know about the law in their country and that they have to abide by it -  who has to notify them of new changes? 

Sabine Lobnig: The AccessibleEU Centre is organizing informational events in the members states. Usually, the chambers of commerce inform their members of such regulatory changes.  

Susanna Laurin: European Directives are transposed into national law, so it is up to each member state to inform, monitor enforcement etc of the act. 

Q: We are a B2B consultancy working in the UK (in Ireland) does the EAA apply to B2B or just B2C? 

Susanna Laurin: The EAA covers consumer products and services. 

Q: Would you consider packaging of products part of the scope of the EAA or only in spirit? 

Sabine Lobnig: The EAA specifically says: “In addition to the requirements of Section I, the packaging and instructions of products covered by this Section shall be made accessible, in order to maximise their foreseeable use by persons with disabilities.”  

Susanna Laurin: Packaging of products in scope of the EAA must be accessible. That clearly stated in Annex 1 section 2. 

Q: Do you think this will open more digital accessibility positions in Europe? 

Sabine Lobnig: Yes. 

Susanna Laurin: The demand for accessibility professionals in the EU is already high, and I am convinced it will increase further. 

Q: Does this act also cover things like elevators? If yes, then what if the accessibility is implemented partially because of the software limitation/integration? 

Susanna Laurin: Member states may opt in for adding EAA accessibility requirements for the built environment (including elevators) to their national legislation. 

Q: Will businesses need a third-party accessibility audit to prove their accessibility? What qualifications must a third-party organisation have to offer accessibility audits? Who will guarantee businesses’ compliance? 

Susanna Laurin: There is no requirement for a third-party assessment. However, the surveillance authority in a member state may choose to set up guidelines around this. 

Q: Do you have any guidance for convincing senior members within an organisation on the importance of accessibility? In particular making our own tools accessible.  

Susanna Laurin: If you want to sell to 15-20% of the population, it makes business sense to provide accessible products and services. In my experience, meeting people with disabilities and seeing how they may struggle with inaccessibility (of your tools) is often what makes people understand the importance. 

Q: I wonder about regulation of exceptions and how these exceptions can be communicated: As example, I do not believe that a radio station streaming their broadcast online, would need to provide alternative content (subtitles) for people with hearing impairment? Can you please elaborate? 

Susanna Laurin: EAA covers audiovisual media services, not radio stations. 

Download the slides and transcript

You can download your copy of the slides [PowerPoint] we used in the webinar.

You can download your copy of the transcript [Microsoft Word Document] of the webinar. 

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