June 28, 2026 marked one full year since the European Accessibility Act (EAA) became enforceable across the EU. When we published our six-month review in January, the picture was still forming: authorities were staffing up, businesses were triaging, and the big question was whether enforcement would arrive as a wave of penalties or a slow tightening.
Twelve months in, we have an answer — and a clearer view of what EU-facing businesses should actually do about it.
What year one actually looked like
The first year produced fewer headline fines than some predicted, and more of something quieter and ultimately more consequential: infrastructure. Every member state now has designated market surveillance authorities, complaint channels are live, and the machinery for investigating accessibility failures is running — just at different speeds in different countries.
The dominant enforcement pattern has been complaint-driven and corrective-first. A user or advocacy group reports a barrier, the authority investigates, and the business receives a corrective order with a deadline — fix the issue and document it, or face penalties that escalate from there. Member states set their own penalty regimes, and several allow substantial fines for continued non-conformity, but most authorities have treated year one as the period for establishing expectations rather than making examples.
Two things changed noticeably as the year went on:
- Disability advocacy organizations got organized. Structured complaint campaigns — filing coordinated reports against banking, e-commerce, and transport services — became a feature of the landscape, particularly in Germany, France, and the Nordics. Enforcement volume increasingly follows advocacy attention.
- Accessibility became a procurement question. Large EU companies started pushing EAA obligations down their supply chains, asking vendors for conformance documentation before signing. For many businesses, the first EAA pressure arrived not from a regulator but from a customer's legal team.
A reminder of who's covered
The EAA applies to products and services sold to consumers in the EU, regardless of where the company is based. If you're a US business selling to EU consumers, it applies to you. The service categories at the center of it:
- E-commerce — the broadest category, covering essentially any consumer-facing online selling
- Banking and consumer financial services
- Telecoms, and access to audiovisual media services
- Passenger transport booking and ticketing
- E-books and e-reading software
The technical benchmark is the EN 301 549 standard, which for websites and apps largely maps to WCAG 2.1 AA — the same guidelines you'd target for accessibility anywhere else. Microenterprises providing services (fewer than 10 employees and under €2 million turnover) are exempt, though their business customers increasingly ask anyway.
One nuance worth flagging: the transition window running to 2030 is narrower than commonly assumed. It shelters certain pre-existing contracts and self-service terminals — not your website. New and actively maintained digital services are covered now.
Lessons from the businesses that handled it well
The pattern we described at six months has held: companies that treated the EAA as an accessibility program rather than a paperwork exercise are having a much easier year. Three habits separate them.
They fixed the journeys, not just the homepage. Authorities and complainants alike focus on whether a person with a disability can actually complete the core task — open an account, buy the product, download the statement. A polished homepage with an inaccessible checkout is exactly the profile that draws complaints.
They published an honest accessibility statement. A statement describing your standard, your current state, and how to report barriers is expected under the EAA framework — and it works as a pressure valve. A concrete example: a mid-sized retailer selling into France received a complaint about unlabeled controls in its checkout. Because it had a statement, a feedback channel, and a documented record of ongoing fixes, the matter resolved as a corrective plan with a deadline — not a penalty proceeding.
They made accessibility continuous. Sites change weekly; a one-time audit from 2025 says nothing about your site today. The businesses in the best position treat accessibility like uptime — monitored, logged, and steadily improved.
What to prioritize now
If you serve EU consumers and you're not confident in your position, the sequence for the year ahead:
- Audit against WCAG 2.1 AA, prioritizing the transactional journeys in the covered service categories.
- Fix real barriers first — unlabeled controls, missing image descriptions, keyboard-inaccessible flows, form errors that can't be perceived. This is where AllAccessible's human-in-the-loop agentic remediation compresses the timeline: AllAccessible AI drafts the fixes with full page context, your team reviews and approves each one, and every change is recorded and reversible — the kind of documented, ongoing effort authorities ask to see.
- Publish and maintain an accessibility statement with a working feedback channel, in the languages of the markets you serve.
- Monitor continuously so new releases don't quietly reintroduce barriers, and keep the record of what you've fixed and when.
Year two will be less forgiving
Everything about year one — the corrective-first posture, the guidance, the patience — reflected authorities' view that businesses needed time to adjust. That grace period is ending. Authorities now expect businesses to know the rules, advocacy groups know how to file, and the businesses that used year one to build a real accessibility practice are visibly separating from those that gambled on enforcement never arriving.
The good news is that the work is the same work that makes your site better for every visitor. Start with an audit, fix what's real, and build the ongoing habit.
Get started with AllAccessible and make steady, documented accessibility progress before year two makes it urgent.
Frequently Asked Questions
- Does the European Accessibility Act apply to US companies?
- Yes. The EAA applies to products and services sold to consumers in the EU regardless of where the company is based, so a US business selling to EU consumers is covered. The central categories are e-commerce, banking and consumer financial services, telecoms and audiovisual media access, passenger transport booking, and e-books.
- What happened during the first year of EAA enforcement?
- Year one produced fewer headline fines than predicted and more enforcement infrastructure: every member state now has market surveillance authorities and live complaint channels. The dominant pattern was complaint-driven and corrective-first — a user or advocacy group reports a barrier, the authority investigates, and the business gets a corrective order with a deadline, with penalties escalating only for continued non-conformity.
- What accessibility standard does the EAA require?
- The technical benchmark is EN 301 549, which for websites and apps largely maps to WCAG 2.1 AA — the same guidelines used for accessibility work elsewhere. Microenterprises providing services (fewer than 10 employees and under €2 million turnover) are exempt, though business customers increasingly ask vendors for conformance documentation anyway.
- Does the EAA's 2030 transition period cover my website?
- No — that window is narrower than commonly assumed. It shelters certain pre-existing contracts and self-service terminals, not websites. New and actively maintained digital services are covered now, so waiting until 2030 is not a viable strategy for a consumer-facing site.