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European Accessibility Act: What US Companies Selling to the EU Must Do

By Emilia Veras. Last updated: July 13, 2026

The European Accessibility Act (EAA) has been enforceable across all 27 EU member states since June 28, 2025. It requires websites, apps, and e-commerce services sold to EU consumers to meet WCAG 2.1 Level AA. It applies to companies outside the EU, including US businesses, whenever they serve customers in the EU. The law follows the customer, not the company.

If you run a US company that sells anything to customers in the EU, this is not a European problem you can ignore. This guide covers what the law requires, who it applies to, the fines by country, the accessibility statement most teams have never heard of, and a practical way to audit and fix your site before a complaint lands.

What Is the European Accessibility Act?

The European Accessibility Act (Directive (EU) 2019/882) is an EU-wide law that requires digital products and services to be accessible to people with disabilities. It was adopted in 2019, member states had until June 28, 2025 to enforce it, and that date has passed. The European Commission estimates around 87 million people in the EU live with a disability. Earlier EU rules covered only public-sector sites; the EAA extends the obligations to the private sector.

Does the European Accessibility Act Apply to US Companies?

Yes. The EAA applies to any business that offers covered products or services to consumers in the EU, regardless of where the business is headquartered. A US-based e-commerce company selling to a customer in Germany is covered just as much as a company based in Berlin. As the legal analysis puts it, the law follows the customer, not the company (Davis Wright Tremaine, 2025). One common carve-out: microenterprises that provide services and have fewer than 10 employees and under 2 million euros in annual turnover are exempt from most requirements, though this varies by member state.

What the EAA Requires: WCAG 2.1 Level AA

The technical benchmark is EN 301 549, the European accessibility standard, which incorporates WCAG 2.1 Level AA (with WCAG 2.2 increasingly referenced). Requirements include descriptive alt text on meaningful images, visible labels on every form field, full keyboard operability with no traps, a minimum 4.5:1 text contrast ratio, visible focus indicators, information never conveyed by color alone, captions on video, skip-navigation links, and text descriptions for form errors. Many of these are visual and design-level decisions that automated DOM scanners under-detect, which is why an accessibility program needs a design QA layer.

The Accessibility Statement Is Legally Required

One of the most overlooked EAA obligations is the accessibility statement. Every covered business must publish one that declares its level of WCAG conformance, lists known accessibility issues and fix dates, provides a contact route for complaints, and states when it was last reviewed. Passing a WCAG scan does not equal full EAA compliance: the statement and the feedback mechanism are separate legal requirements (Level Access, 2026).

EAA Fines by Country

Each member state sets and enforces its own penalties, so exposure depends on which EU countries your customers are in. Maximum penalties reported by Level Access as of mid-2026:

Fines are not the only risk. Authorities can order a non-compliant product withdrawn, require an audit, and publicly name organizations that fall short. In some countries, competitors can pursue non-compliance as an unfair-competition claim.

Enforcement Is Already Happening

In the Netherlands, the Consumer and Market Authority (ACM) has sent information requests to e-commerce operators globally, including companies headquartered outside the EU, with active enforcement expected in the second half of 2026. In Germany, e-commerce operators began receiving private warning letters from law firms shortly after transposition. Enforcement will not be evenly paced across all 27 states, but the direction is consistent.

How to Audit and Remediate Before a Complaint

Run a baseline audit of your highest-traffic and checkout pages with a free accessibility checker. Review the visual failures a scanner misses (contrast, focus visibility, color-only cues, reflow, target size) with a design QA pass. Fix at the design level where possible, since a contrast failure caught in the design file is a color swap rather than a full post-launch remediation. Publish your accessibility statement. Then re-audit on every release so a regression cannot ship silently.

Frequently Asked Questions

Does the European Accessibility Act apply to US companies?

Yes. The EAA applies to any business that offers covered products or services to consumers in the EU, regardless of where the business is based. A US e-commerce store that ships to or serves EU customers is covered. The law follows the customer, not the company, so US hosting or a US-only legal entity does not put you outside its scope.

What is the deadline for the European Accessibility Act?

The enforcement deadline was June 28, 2025. The EAA has been enforceable across all 27 EU member states since that date, and enforcement actions, including information requests and fines, have been accelerating through 2026. There is no future grace period to wait for.

What are the penalties for EAA non-compliance?

Penalties are set per member state. Reported maximums include roughly 900,000 euros in Sweden, 600,000 euros in Spain, 100,000 euros per violation in Germany, and up to 5% of annual turnover for serious breaches in France and Italy (Level Access, 2026). Regulators can also order product withdrawal, require an audit, and publicly name non-compliant companies.

What must an EAA accessibility statement include?

A compliant accessibility statement declares your level of WCAG conformance (full, partial, or non-compliant), lists known accessibility issues and when you plan to fix them, provides a contact route for accessibility complaints, and states when the statement was last reviewed. Publishing this statement is a legal requirement under the EAA, separate from the technical WCAG work.

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