The New European Accessibility Act (EAA): What applies to your website starting June 28, 2025

Hand on heart: Is your website or app truly accessible? Until now, this was considered a "nice-to-have" for many private companies. But that time is over.

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EAA has already entered into force! Starting June 28, 2025, most new digital products and services in the EU must be accessible.

If you operate a website, an online shop, or an app, you must act now. In this section of our Accessibility Hub, I will explain what the new European Accessibility Act (EAA) means for you, what technical standard underlies it, and why you should definitely focus on WCAG 2.2 now.

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In this section, we cover accessibility only in the context of websites, apps, and digital services. There are separate regulations for physical accessibility (e.g., in buildings, products) which are not discussed on this website. Also

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Since we are based in Germany, our explanations primarily refer to the national implementation of the EAA here. However, the core content applies throughout the EU.

What Applied Previously: BITV 2.0 for Authorities

Previously, accessibility in Germany (and the EU in general) was mainly relevant for the public sector. The Accessible Information Technology Ordinance (BITV) played the main role.

The BITV 2.0, which came into force in 2019, implemented § 12b and § 16 Para. 8 of the Equal Opportunities for Persons with Disabilities Act (BGG) [1]. Public bodies have since been obliged to make their websites and apps accessible. This was the German implementation of the EU Directive 2016/2102 [2].

The emphasis is on: "public bodies". This had no direct consequences for most private companies (yet).

What is Different Now: The European Accessibility Act (EAA)

Now things are getting serious. The new European Accessibility Act (EAA) completely reshuffles the deck. Authorities have already shown the way; now it is the turn of private providers.

According to § 3 Para. 2 EAA [3], this law is based on Directive (EU) 2019/882 [4], which you might know better as the European Accessibility Act (EAA). The goal? Uniform standards for accessibility across Europe—all consumers should have equal access to products and services.

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Accessibility is often viewed as an "additional cost factor." However, the reality is different: If your services are not accessible, you are turning away a population of 1.3 billion people who spend $1.9 trillion annually [5].

The crucial point: The EAA now also obligates private providers of products and services. So, if you operate an online shop for consumers, offer software, or sell digital services, you are almost certainly covered.

Who is affected by the EAA? Is it really everyone?

First, there's some good news: Not all companies are affected. The EAA primarily targets providers who offer products and services to consumers. These include, among others:

• Online shops and e-commerce platforms
• Banking and financial services
• Telecommunications services
• E-books and digital media
• Software and operating systems
• Public transportation and ticketing systems

If you are unsure whether your website falls under the EAA, our EAA Check can help you. There, you can quickly find out if you need to take action.

What Does "Accessible" Mean According to the Law? (The Technical Standard)

Okay, "accessible" is a broad term. What exactly must you technically implement?

The law is smart about this: Instead of writing technical details directly into the law (which quickly become outdated), it refers to external standards. For you as a website operator, § 4 EAA [3] is crucial: Your website is considered accessible if it complies with the "harmonized standards" published in the Official Journal of the EU [6].

And which standard is that? With Implementing Decision (EU) 2021/1339 [7], exactly one standard was established for websites: EN 301 549 (Version 3.2.1) [8]

This standard defines the technical requirements. And if you look at Chapter 9 (Web) of this standard [8], you will notice: It is based almost 1:1 on the Web Content Accessibility Guidelines (WCAG) 2.1 [9] at Levels A and AA.

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In short: If your website meets WCAG 2.1 Levels A & AA, you comply with EN 301 549 v.3.2.1 [8] and thus achieve the so-called "presumption of conformity" according to § 4 Para. 2 EAA [3].

Looking Ahead: WCAG 2.2

But beware! The ink on EN 301 549 v3.2.1 is barely dry, and the EU is already working on the next update.

The update has already been commissioned in Commission Implementing Decision C(2022) 6456 [10] and carried out in the corresponding work program M/587 [11]. The standard EN 301 549 is to be adapted in the "Web" chapter to WCAG 2.2 [12], which was published in October 2023.

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At the time of publication of this article (October 2025), the revision of EN 301 549 has not yet been completed. However, the final draft is already available.

This new version of the standard is expected to be published in the Official Journal of the EU at the end of 2025 or beginning of 2026. As soon as that happens, WCAG 2.2 will become the new legal standard.

Why You Should Focus on WCAG 2.2 Now

You might be thinking, "Great, I'll wait until 2026." – Bad idea!

The W3C, which develops the WCAG, clearly states: WCAG 2.2 builds on 2.1 and uses the same conformance model [13]. WCAG 2.2 adds new criteria (e.g., for focus visibility and drag interactions) but changes very little of the existing ones.

Therefore, if you are starting a new project or planning a relaunch now, you are extremely well advised to orient yourself directly toward WCAG 2.2 (Levels A & AA).

Why?

1. Future-Proofing: You automatically meet the "old" requirements of 2.1 and are prepared for the new standard without having to make adjustments in 2026.
2. Better UX: The new criteria in 2.2 solve genuine usability problems that benefit all your users.

Don't wait for the deadline. Digital accessibility is not a sprint to 2025, but a marathon. Start now and adopt the modern standard immediately.

The European Accessibility Act (EAA) marks a turning point for digital accessibility in the EU. Starting June 28, 2025, many private providers will be obliged to make their websites and apps accessible.

The basis for this is EN 301 549 v3.2.1, which is based on WCAG 2.1. However, looking ahead shows: WCAG 2.2 will soon be the new standard.

If you are starting a new project or planning a relaunch now, you should orient yourself directly toward WCAG 2.2. This way, you are not only legally compliant but also offer a better user experience for all.

What You Should Do Next

Here are the next steps you should take to make your digital offering EAA-compliant:

• First, do the EAA Check to find out if your website is affected. Then you can specifically plan the next steps.
• If so, read up on possible special regulations in our article "What exceptions are there in the EAA?".
• If you haven't found an exception for yourself, look at the section Risks and Fines for Non-Compliance with the EAA to understand the consequences.
• I recommend that you first fill out and publish the Template for the Accessibility Statement according to EAA on your website. This is an important step toward transparency and shows your commitment to accessibility.
• The article How Does an Official EAA Compliance Inspection Work? helps you prepare for potential checks.
• And if you have questions, check out the EAA FAQ. There you will find answers to the most frequently asked questions on the topic from our practice.

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We are constantly expanding this section with new articles and resources. Feel free to check back often to stay up-to-date on the EAA and digital accessibility!

Accessibility is no longer a "nice-to-have"—it is mandatory. But it is also an opportunity to make your offering accessible to everyone, thereby increasing your reach and success.

So, let's get started!

Disclaimer

This article does not constitute legal advice and does not replace professional legal consultation. The information is based on the status as of October 2025 and may change. For binding legal advice, please consult a qualified lawyer or other professional in the field of accessibility and IT law.

1. Bundesministerium der Justiz, “Gesetz zur Gleichstellung von Menschen mit Behinderungen.” 2018. [Online]. Available: https://www.gesetze-im-internet.de/bgg/ ⤴
2. Das Europäische Parlament und der Rat, “Richtlinie (EU) 2016/2102 des Europäischen Parlaments und des Rates vom 26. Oktober 2016 über den barrierefreien Zugang zu den Websites und mobilen Anwendungen öffentlicher Stellen.” 2016. [Online]. Available: https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX:32016L2102 ⤴
3. Bundesministerium der Justiz und für Verbraucherschutz, “Gesetz zur Umsetzung der Richtlinie (EU) 2019/882 des Europäischen Parlaments und des Rates über die Barrierefreiheitsanforderungen für Produkte und Dienstleistungen (Barrierefreiheitsstärkungsgesetz – BFSG).” 2023. [Online]. Available: https://www.gesetze-im-internet.de/bfsg/ ⤴
4. Das Europäische Parlament und der Rat, “Richtlinie (EU) 2019/882 des Europäischen Parlaments und des Rates vom 17. April 2019 über die Barrierefreiheitsanforderungen für Produkte und Dienstleistungen (European Accessibility Act).” 2019. [Online]. Available: https://eur-lex.europa.eu/eli/dir/2019/882/oj?locale=de ⤴
5. Forrester Research, “Accessibility Is Still Vital For Businesses.” Feb. 03, 2025. [Online]. Available: https://www.forrester.com/blogs/accessibility-is-still-vital-for-businesses/ ⤴
6. Amt für Veröffentlichungen der Europäischen Union, “Amtsblatt der Europäischen Union - Direkter Zugang.” 2025. [Online]. Available: https://eur-lex.europa.eu/oj/direct-access.html ⤴
7. Europäische Kommission, “Durchführungsbeschluss (EU) 2021/1339 der Kommission vom 12. August 2021.” 2021. [Online]. Available: https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32021D1339&from=DE ⤴
8. ETSI, “ETSI EN 301 549 V3.2.1 (2021-03) - Accessibility requirements for ICT products and services.” 2021. [Online]. Available: https://www.etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf ⤴
9. W3C, “Web Content Accessibility Guidelines (WCAG) 2.1.” 2021. [Online]. Available: https://www.w3.org/TR/WCAG21/ ⤴
10. Europäische Kommission, “C(2022) 6456 - COMMISSION IMPLEMENTING DECISION on a standardisation request to the European standardisation organisations.” 2022. [Online]. Available: https://ec.europa.eu/transparency/documents-register/detail?ref=C(2022)6456 ⤴
11. ETSI, “Work Item M/587 - Accessibility requirements for public procurement of ICT products and services.” 2021. [Online]. Available: https://portal.etsi.org/webapp/workProgram/Report_WorkItem.asp?wki_id=64282 ⤴
12. W3C, “Web Content Accessibility Guidelines (WCAG) 2.2.” 2023. [Online]. Available: https://www.w3.org/TR/WCAG22/ ⤴
13. W3C, “WCAG 2.2 - 5. Conformance.” 2023. [Online]. Available: https://www.w3.org/TR/WCAG22/#conformance-to-wcag-2-2 ⤴