EAA Deadline: What Is Enforced Right Now in 2026

Deadline Status

The European Accessibility Act (Directive (EU) 2019/882) required member states to apply its provisions from June 28, 2025. That date has passed: enforcement is live in every member state, market-surveillance authorities are operating, and the first fines have been issued — including penalties reported in Sweden (~€900K) and Spain (~€600K). In 2026 the question is no longer "when do I need to comply?" but "how fast can I document compliance?".

📅 Already Passed

June 28, 2025 — obligations apply. Services contracted after this date must conform to WCAG 2.1 AA / EN 301 549.

⏳ Service Continuity Grace

Pre-existing services may continue until they undergo "significant change" — but redesigns, replatforms or major updates reset the clock to full conformance.

🏗️ Built Environment Exception

Some physical-structure exemptions run to 2030 in certain states. Digital services get no such extension.

Who is Covered

The EAA applies to products and services placed on the EU market after the deadline: e-commerce sites, banking services, e-books, ticketing machines, smartphones, TV equipment, and telecom services. For web agencies the key trigger is e-commerce: any online shop you build, host or maintain for an EU seller is in scope. Micro-enterprises (fewer than 10 employees AND under €2M annual turnover) offering SERVICES are exempt — but note this exemption does not extend to the products they sell or resell.

What Enforcement Looks Like

Each member state designated market-surveillance authorities. Enforcement so far follows a pattern: complaints from users trigger investigation, authorities issue corrective orders with deadlines, and fines follow for continued non-conformance. Several countries also allow consumer organisations to bring actions. The practical consequence for agencies: a client's accessibility complaint letter lands on YOUR desk first, because the fix lives in your codebase.

🇸🇪 Sweden

Fines up to ~€900K reported for non-conforming services after the deadline.

🇪🇸 Spain

~€600K penalties issued; consumer groups actively testing retail sites.

🇩🇪 Germany

BFSG enforcement via Marktüberwachungsstellen; BITV-style testing methodologies applied to private sector for the first time.

🇫🇷 France

Existing RGAA enforcement tightened; EAA obligations folded into the same monitoring cycle.

If You Are Non-Compliant Now

Do not panic-redesign. Regulators respond to documented good-faith remediation far better than to silence. The sequence that works: (1) run an automated scan to find the mechanical failures — contrast, alt text, headings, labels; (2) fix those, they are usually days of work; (3) publish an honest accessibility statement stating partial conformance with known issues and a feedback channel — this alone satisfies the documentation requirement while deeper work continues; (4) schedule manual screen-reader testing for complex flows like checkout. Our free scanner covers step 1 in about two minutes for most sites.

Frequently Asked Questions

Is there a new EAA deadline after June 2025?

No. June 28, 2025 was the final application date. There is no second grace period for digital services. The only remaining transitions concern pre-existing service continuity and specific built-environment items in some member states.

My site was launched before the deadline — am I safe?

Not permanently. Self-service pre-existing contracts enjoy continuity until significant change, but authorities interpret "significant change" broadly: a redesign, new checkout flow or platform migration ends the grace period. And user complaints trigger scrutiny regardless of launch date.

Are micro-businesses exempt?

Services-only exemption applies if you have fewer than 10 employees and under €2M turnover. It does NOT cover products you sell, and it does not stop enterprise clients demanding WCAG conformance contractually anyway.

What standard must we meet?

The presumption of conformity is tied to EN 301 549, which incorporates WCAG 2.1 Level AA for web content. Meeting WCAG 2.1 AA plus the statement and feedback-channel requirements covers the overwhelming majority of EAA obligations for websites.

EAA Deadline: What Is Enforced
Right Now in 2026