Accessibility beyond the deadline

On 28 June 2025, the European Accessibility Act (EAA) came into force across the European Union. This marks not only a major milestone in accessibility regulation, but also a clear shift for companies offering products and services to European consumers. Accessibility is no longer a distant item on the regulatory agenda; it is now a concrete requirement, subject to oversight and growing client expectations.

This article examines how supervisory approaches differ across EU Member States and what that means in practice for international firms. In the sections that follow, we explore early lessons from the first months of EAA implementation, strategies adopted by leading organizations, and key actions for those still moving towards full compliance.

From preparation to practice

The months since the EAA took effect have revealed a clear divide between organizations that built accessibility into product and service design from the outset and those now working to align with the requirements. Early movers have embedded accessibility standards across websites, documentation and vendor contracts, while others are allocating significant resources to update existing systems and processes. Starting points vary depending on prior priorities and business models, but the implementation challenges are now broadly shared.

These challenges are often practical. Digital channels such as e-banking applications, commercial websites, and booking platforms may need not only visual adjustments but also changes to their underlying architecture to enable accessible navigation and interaction. Customer documentation—including PDFs, onboarding forms and contracts—may need reformatting or redevelopment to ensure compatibility with screen readers or other assistive technologies.

At the same time, straightforward improvements can deliver immediate benefits. Optimizing websites for keyboard navigation and screen readers, structuring mobile applications with clearer headings and voice support, and simplifying core customer journeys can reduce friction for all users. Such measures often make it easier for customers to complete key actions and can lower support costs.

Beyond compliance, accessibility is increasingly recognized as a driver of innovation. Firms are experimenting with voice interfaces, adaptive design, and clearer information hierarchies. Although robust market data on accessibility as a differentiator is still limited, early adopters demonstrate that inclusive design can enhance customer satisfaction, make products easier to use for a wider audience, and strengthen reputation when highlighted publicly.

Supervisory authorities and enforcement

Across the EU, supervisory approaches to the EAA vary, but early signals point to a balance of support and scrutiny. Authorities are issuing guidance for small businesses, reviewing documentation from companies that claim a “disproportionate burden” for certain requirements. 

They are also conducting spot checks on services that attract higher supervisory attention or are considered critical to customers, such as banking and transport platforms.

In Luxembourg, the Office de Surveillance de l'Accessibilité des Produits et Services (OSAPS) oversees compliance with the EAA. Its mandate includes monitoring whether products and services meet accessibility standards, offering guidance and resources for micro-enterprises, and raising public awareness while gathering data on the needs of individuals with disabilities.

OSAPS has the authority to impose fines ranging from €250 to €15,000 for non-compliance, such as failing to provide requested information, obstructing market surveillance, or breaching accessibility requirements. In cases of repeated or serious violations, penal sanctions and fines of up to €1,000,000 may also be applied.

Beyond regulatory fines, the European Accessibility Act (EAA) gives individuals and advocacy groups the power to act against non-compliance. Consumers who face accessibility barriers can report issues to national authorities or seek legal remedies, while organizations representing disabled users may act on their behalf.

In countries such as the Netherlands, accessibility shortcomings in banking and other services have already been challenged, illustrating the potential for legal consequences. Formal complaints about existing or newly offered services can trigger regulatory investigations and enforcement measures, underlining the need for organizations to maintain robust accessibility practices.

Looking ahead: Milestones, standards and practical next steps

Looking ahead, businesses need to plan carefully around the EAA’s phased deadlines. Products placed on the market and services provided to consumers after 28 June 2025 must comply with EAA requirements.  Products and services lawfully offered before that date may, in many cases, continue until 28 June 2030 (or until replaced), giving service providers a limited transitional period. Member States may also allow self-service terminals (e.g., ATMs and kiosks) installed before 28 June 2025 to remain in use until the end of their economic life, but no longer than 20 years from their initial deployment. These milestones should guide product replacement cycles, service roadmaps, and operational planning.

The harmonized European Information and Communication Technology (ICT) standard EN 301 549 (European standard for digital accessibility) serves as the primary technical benchmark for ICT products and services under the EAA. It incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA as a reference framework for web and mobile content. In Luxembourg, additional national guidelines apply, including the Référentiel d’Évaluation de l’Accessibilité Web (RAWeb) and the Référentiel d’Évaluation de l’Accessibilité des Applications Mobiles (RAAM).

For business leaders, practical next steps include:

• Prioritizing the most critical customer touchpoints, such as onboarding, payments, and essential service interactions.
• Embedding accessibility criteria into procurement processes and vendor contracts.
• Training product, development, and customer-facing teams.
• Establishing governance loops for continuous monitoring and improvement.

Starting with a focused set of priorities delivers early wins, signals commitment, and builds a foundation for scaling accessibility across the organization. Accessibility improvements are not only a regulatory requirement; they also create commercial value. Reducing friction for users with diverse needs often enhances experiences for a wider customer base, including those seeking simpler and more intuitive interfaces. Early adopters can strengthen their customer proposition, lower support costs, and position inclusivity as part of their corporate responsibility narrative. Companies that embed accessibility today will be better equipped to thrive tomorrow, mitigating regulatory, legal, and reputational risks while unlocking opportunities. Accessibility is both a resilience measure and a growth driver, turning compliance into a competitive advantage.

From obligation to opportunity

The first months of the EAA’s application confirm that accessibility is no longer a theoretical agenda item. It is both a supervisory priority and a commercial opportunity. Businesses that approach accessibility as an ongoing strategy—not a one-off compliance task—will be better positioned to manage regulatory risk, deepen customer relationships, and unlock meaningful product innovation.

Executive teams should act now to embed accessibility into governance, product design and procurement. Those that move early will not only reduce risk but also gain a competitive edge by competing on inclusion and demonstrating credible social responsibility.