For years, digital accessibility was treated as a "nice-to-have": a recommended best practice, but rarely a priority. As of June 28, 2025, that's no longer the case. With the European Accessibility Act (EAA) coming into force, making websites, e-commerce stores, and apps accessible is now a legal requirement for most companies selling to consumers in the European Union.
For digital product designers, this is a watershed moment. Accessibility is shifting from an ethical choice to a compliance requirement, complete with deadlines and penalties. This means knowing how to design for accessibility is now a core market-demanded skill, not a niche specialization.
In this guide, I'll explain what the new web accessibility laws are, who is required to comply, what companies need to do, and how you—as a designer—can create compliant products without turning every project into a technical nightmare.
What you'll learn in this guide:
- What the European Accessibility Act is and why it's different from previous regulations
- When it applies and to whom (including exemptions for micro-enterprises)
- Which digital products and services fall under the new law
- The key technical standard: the legal role of the WCAG
- The risks and penalties for non-compliance
- A practical, phase-by-phase guide to designing for accessibility
What Is the European Accessibility Act?
The European Accessibility Act is EU directive 2019/882, designed to harmonize accessibility requirements for products and services across all EU member countries. Before the EAA, each nation had its own fragmented rules, forcing companies selling across borders to navigate a maze of different regulations. The EAA creates a common set of requirements valid throughout the EU.
Each member state has implemented this directive into its national law. The key date is universal: June 28, 2025, the day from which new products and services placed on the market must be compliant.
This is a substantial change from the past. Previously, accessibility laws like Section 508 in the US or various national regulations in Europe primarily targeted the public sector and its major service providers. The EAA extends this mandate to the private sector, covering a vast range of e-commerce sites and digital services aimed at consumers.
Who Must Comply and When?
The general rule is simple: from June 28, 2025, new services must be accessible. While a transition period exists for some existing services, the direction is clear—accessibility is now the expected default, not the exception.
The law applies to companies offering digital products and services to consumers in the EU market, regardless of where the company is based. If you sell to European customers, these rules apply to you.
However, there is an important exemption for micro-enterprises that provide services: companies with fewer than 10 employees and an annual turnover or balance sheet not exceeding €2 million (approx. $2.1M USD or £1.7M GBP) are not required to comply with the service-related obligations. But be careful: this exemption is for services and is more limited for products. More importantly, an inaccessible website is still a website that loses customers. The exemption is a regulatory relief, not a good business strategy.
What Products and Services Are Covered?
The EAA doesn't cover "any website" indiscriminately, but it does apply to a broad list of products and services with a high impact on daily life. Key examples include:
- E-commerce and online retail services (one of the most common use cases)
- Consumer banking services and mobile banking apps
- Ticketing and transportation: buying tickets, travel information, and mobility apps
- Electronic communication services and access to audiovisual content
- E-books and their dedicated reading software
- Hardware products like computers, smartphones, and self-service terminals (ATMs, automated check-ins, ticketing machines)
For designers, this means if you work on an e-commerce platform, a booking site, a banking app, or a subscription service, accessibility is now a core requirement, just like payment security or data privacy.
The Technical Standard: WCAG Explained
The law specifies what to achieve (products usable by people with disabilities), but the how is defined by technical standards. The recognized benchmark is the WCAG—Web Content Accessibility Guidelines, specifically conformance to Level AA of WCAG 2.1/2.2, which has been adopted as part of the European standard EN 301 549.
The WCAG are built on four principles, summarized by the acronym POUR:
- Perceivable — Content must be presented in ways all users can perceive. This means alt text for images, captions for videos, and sufficient color contrast.
- Operable — The interface must be navigable. All functionality should be available from a keyboard, without depending on a mouse or complex gestures.
- Understandable — Content and operation must be clear. This includes readable text, predictable behaviors, and helpful error messages.
- Robust — Content must be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies like screen readers.
Understanding the four POUR principles is your starting point. They transform an abstract legal obligation into a concrete design checklist.
The Risks of Non-Compliance
The EAA requires member states to establish enforcement bodies and penalties for non-compliance. These penalties can include significant fines, potentially reaching a percentage of a company's revenue, in addition to a formal order to make the product or service accessible.
But the official penalty is only part of the risk. An inaccessible product:
- Excludes potential customers — The WHO estimates over 15% of the global population lives with some form of disability, not to mention temporary and situational disabilities (like a broken arm or using a screen in bright sunlight).
- Damages brand reputation, as consumers are increasingly aware of and vocal about inclusion.
- Hurts SEO, because many accessibility best practices (semantic HTML, alt text, clear structure) are also positive signals for search engines.
In other words, accessibility is good for business, even without the legal mandate.
How to Design for Accessibility in Practice
The good news is that designing for accessibility doesn't mean overhauling your entire workflow. It means integrating a few key considerations from the start, rather than trying to fix them at the end. Here are the areas where a designer has the most impact.
Contrast and Color. Ensure a contrast ratio of at least 4.5:1 between text and its background. And never rely on color alone to convey information: an error message indicated only in red is invisible to someone with red-green color blindness. We have a dedicated guide on designing for color blindness.
Keyboard Navigation. Every function available with a mouse must also be accessible using only the Tab key. Pay attention to the focus order and always make the focused element clearly visible.
Alt Text and Semantic Structure. Every informative image needs a descriptive alt attribute. Every page should have a correct heading hierarchy (one H1, with H2s/H3s nested logically). This helps screen readers and, again, SEO.
Forms and Error Messages. Field labels must be explicit and programmatically linked to their inputs. Errors should be described in text, not just highlighted with color. We dive deeper into this topic in our guide to form design.
Components and States. Buttons, links, and fields must clearly communicate their states (focus, hover, disabled) and follow basic usability principles.
The guiding principle is simple: accessibility is not a feature to be added, it's a quality to be designed. The earlier you integrate it, the less it costs.
Key Takeaways
The European Accessibility Act has transformed digital accessibility from a best practice into a legal requirement, effective June 28, 2025. It applies to a wide range of e-commerce and digital services for consumers, uses WCAG Level AA as the technical standard, and includes penalties for non-compliance.
For designers, this is a positive development: accessibility is now a recognized and required skill. Knowing how to apply it—from color contrast and keyboard navigation to alt text and accessible forms—is a fundamental part of a professional UX designer's toolkit. It's one of the pillars we teach in our complete UX Design course: how to design products that work for everyone, not just for the majority.
Frequently Asked Questions (FAQ)
Does the European Accessibility Act apply to my small e-commerce store? It depends on your size. Micro-enterprises providing services (fewer than 10 employees and up to €2M/~$2.1M annual turnover) have an exemption for their services. Above that threshold, or for products, the law applies. Regardless, an accessible site sells more.
What is the specific standard I need to follow? The standard is WCAG Level AA conformance (version 2.1 or 2.2), as adopted into the European standard EN 301 549. These are the same guidelines used as the technical reference across the entire EU.
When does this become mandatory? It is mandatory from June 28, 2025, for new services placed on the market. Some pre-existing services have a transition period, but accessibility is now the expected requirement for any new digital project.
