100 days to the European Accessibility Act: a practical plan
On 28 June 2025 accessibility becomes a legal requirement for many online services sold to EU consumers. A hundred days is enough to make real progress — if you start now.
By the Xuru Technologies team · 21 March 2025
Key takeaways
- The European Accessibility Act (Directive (EU) 2019/882) applies from 28 June 2025.
- It covers services including e-commerce, consumer banking, e-books, electronic communications and elements of passenger transport such as booking websites and apps.
- Microenterprises providing services (fewer than 10 staff and turnover or balance sheet up to €2 million) are exempt from the service requirements.
- WCAG 2.1 AA, the basis of the harmonised standard EN 301 549, is the practical target; WCAG 2.2 AA is a sensible goal.
Accessibility is often treated as a nice-to-have. In the EU it is about to become a condition of doing business online — and it opens your website to millions more customers.
What is changing
The European Accessibility Act was adopted in 2019 and transposed into national laws by EU member states, with the requirements applying from 28 June 2025. National authorities will enforce it, and penalties are set by each country. It applies to businesses providing covered services to consumers in the EU, including those based outside the EU.
Who needs to act
- Online shops selling to EU consumers.
- Travel and transport booking websites and apps.
- Banking and payment services for consumers.
- Agencies and suppliers building these services, whose clients will ask for compliance.
A 100-day plan
| Days | Focus |
|---|---|
| 1–20 | Audit key journeys: home, search, product, basket, checkout, account, contact |
| 21–60 | Fix the blockers: keyboard access, labels, contrast, alt text, error messages |
| 61–80 | Test with screen readers and real users; fix third-party widgets or replace them |
| 81–100 | Publish an accessibility statement and a contact route; train your team |
Avoid quick-fix overlays; see why overlays don't make a site compliant.
Frequently asked questions
Does the EAA apply to businesses outside the EU?
Yes, if they provide covered services to consumers in the EU, such as selling online to EU customers.
Is my small business exempt?
Microenterprises providing services are exempt from the service accessibility requirements. Check your headcount and financial figures, and note that larger clients may still require accessibility from you.
What standard should we follow?
The harmonised European standard EN 301 549 references WCAG 2.1 AA for web content. Aiming for WCAG 2.2 AA covers it and future-proofs your site. This is not legal advice.
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