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EAA · EUROPEAN UNION

EAA 2019/882 Directive: Accessibility Obligations 2026

The European Accessibility Act has been in effect since 28 June 2025. WCAG 2.1 AA compliance is mandatory for all companies offering B2C digital services in the EU; Turkish companies are also within scope.

Effective date 28 June 2025
Minimum standard WCAG 2.1 AA (EN 301 549)
Sanction Varies by member state
Statement requirement Yes (Article 13)

What Is the EAA?

The European Accessibility Act (Directive 2019/882) is an EU directive requiring companies that offer goods and services in the EU to comply with digital accessibility standards for users with disabilities. It was published on 17 April 2019; the date for member states to transpose and apply it is 28 June 2025.

The Directive's aim is to establish a harmonized accessibility standard within the EU and, according to European Commission data, to secure equal access to digital services for approximately 87 million EU citizens with disabilities.

EN 301 549 (the European Standard harmonizing WCAG 2.1 AA) is taken as the technical reference standard. For new projects, applying WCAG 2.2 AA is recommended.

EAA Article 2

Who Is Within the EAA's Scope?

The product and service categories covered by the EAA.

E-commerce Sites

All online stores selling B2C. Trendyol Europe, Hepsiglobal, or Shopify stores fall within this scope.

Mobile Apps

B2C iOS and Android apps. Including those in the banking, shopping, transport, and entertainment categories.

Banking and Finance

Online banking, lending services, payment platforms.

E-books and Publishing

E-book platforms, digital magazine and newspaper subscription services.

Transport Ticketing Systems

Airline, railway, and bus ticket sales sites, along with real-time information systems.

Telecommunications

Mobile operator portals, plan management platforms, and customer service interfaces.

Exemption:

Microenterprises (fewer than 10 employees AND less than 2 million euros in annual turnover) are exempt. B2B-only services are out of scope. Products placed on the market before 28 June 2025 have a 5-year transition period (until 2030). Different transition periods may apply for e-books and self-service terminals.

Member State Legislation and Sanctions

The EAA is an EU directive; each member state has transposed it into national law through its own legislation. For example, in Germany the Barrierefreiheitsstärkungsgesetz (BFSG) entered into force in this context. Member states such as France, Ireland, Spain, the Netherlands, and Italy also have their own regulations.

The types and magnitudes of sanctions vary significantly by member state. Administrative fines, market bans, product recalls, and, in some countries, consumer collective actions may be among the options. If you operate in more than one EU country, each country's national legislation applies independently.

Important:

Penalty amounts and sanction types vary by member state. For specific information, refer to the current text of the national legislation of the member state where you offer your product or service and to the publications of the competent authority. This information does not constitute legal advice; legal counsel is recommended for multi-country operations.

Technical Standards

WCAG 2.1 AA · WCAG 2.2 AA · EN 301 549

The EAA's technical reference is EN 301 549 (which harmonizes WCAG 2.1 AA). For new projects, WCAG 2.2 AA is recommended.

EN 301 549

EAA REFERENCE

As a European Standard, it harmonizes the WCAG 2.1 AA criteria. It is the foundational document for EAA technical conformance evidence.

  • Covers the WCAG 2.1 AA criteria
  • Web, mobile, and software products
  • EN 301 549 V3.x current version
  • Referenced in tender specifications

WCAG 2.1 AA

EAA MINIMUM

Published in 2018. Contains 50 success criteria and adds 13 additional criteria for mobile and low vision.

  • Color contrast 4.5:1 (normal text)
  • Keyboard navigation
  • Screen reader compatibility
  • Reflow (400 percent zoom)
  • Orientation independence
Note: The EAA's legal minimum is WCAG 2.1 AA. However, current versions of EN 301 549 V3.x are increasingly converging toward WCAG 2.2. By choosing WCAG 2.2 AA for new projects, you can minimize fixes that may be needed later.

Accessibility Statement Requirement (Article 13)

Under EAA Article 13, every company within scope must publish an accessibility statement. The statement must include the following elements:

Conformance Level

A declaration of conformance to WCAG 2.1 AA, WCAG 2.2 AA, or a higher level.

Non-compliant Content

Which pages or features are not yet compliant, the reason, and the remediation plan.

Alternative Access Routes

Alternative channels such as phone and email for non-compliant content.

Feedback Mechanism

A contact channel where users with disabilities can report issues.

Right to Complain Information

Information on which national authority a complaint can be filed with.

Last Updated Date

The date on which the statement was prepared or updated.

cerez.io and the EAA

Measure, document, improve.

cerez.io is not an overlay; it offers a real scanner, a measurable report, and a statement generator. Full compliance requires source code fixes; we shorten the process and produce the evidence.

Accessibility Widget

40+ features, 10+ ready-made profiles (visually impaired, dyslexia, senior, seizure safe, etc.), support for 10 languages. Single-line embed code, Shadow DOM architecture.

WCAG 2.2 Scanner

0-100 compliance score, severity-ranked violation list (Critical, Serious, Moderate, Minor). Based on axe-core and Pa11y, with automatic fix suggestions.

Statement Generator

Automatically generates an EAA Article 13 compliant accessibility statement. Keeps the statement synchronized with the latest scan results.

AI Alt-Text Suggestion

Generates descriptive alt-text suggestions for images using the OpenAI Vision API. Human review is recommended. Available on Pro and higher plans.

SSS

Frequently Asked Questions

Short answer: Yes. Turkish companies offering goods or services in the EU fall within the EAA's scope as of 28 June 2025. If you have an EU distributor, an e-commerce site (Trendyol Europe, Hepsiglobal, etc.), or a B2C SaaS service, the EAA applies. It is not mandatory for the Turkish domestic market. This information does not constitute legal advice.

Short answer: Yes, the three regulate different topics on different timelines and can overlap. For cookies, KVKK applies domestically and the GDPR when you sell into the EU; for web accessibility, the EAA applies in the EU market (WCAG 2.1/2.2 AA, 28 June 2025) while Circular 2025/10 applies domestically to public bodies and a large part of the private sector (WCAG 2.2 A, 21 June 2026). A Turkish e-commerce site selling into the EU can be subject to all three. cerez.io brings cookie consent and accessibility measurement into a single panel. This information is not legal advice.

Short answer: Microenterprises (fewer than 10 employees AND less than 2 million euros in annual turnover) are exempt. B2B-only services are out of scope. Products placed on the market before 28 June 2025 have a 5-year transition period (until 2030). Different periods apply for e-books and self-service terminals.

Short answer: The types and magnitudes of enforcement vary by member state. The EAA is an EU directive; the national legislation that transposes it into domestic law is decisive. Sanctions such as administrative fines, market bans and collective lawsuits may apply. Typically a warning comes first, then a remediation period, then enforcement. For specific information, consult your country's national legislation.

Short answer: WCAG 2.2 AA (October 2023) adds 9 new success criteria on top of 2.1: Focus Not Obscured (2.4.11), Dragging Movements (2.5.7), Target Size Minimum 24x24px (2.5.8), Consistent Help (3.2.6), Redundant Entry, Accessible Authentication and others. For the EAA, a minimum of WCAG 2.1 AA is sufficient, but 2.2 is recommended. The cerez.io Accessibility Widget is built to the WCAG 2.2 AA standard.

Short answer: Yes. Under EAA Article 13, every company within scope must publish an accessibility statement. The statement must include the compliance level, non-compliant content and a remediation plan, alternative access methods, a feedback mechanism, complaint authority details and the date of the last update. The cerez.io Statement Generator produces this statement automatically.

Short answer: The Accessibility Widget is added with a single-line embed code, and 40+ features and 10+ profiles become active. The WCAG 2.2 scanner runs regular scans to produce a 0-100 score and a prioritized violation report. The Statement Generator automatically creates an EAA Article 13 compliant statement. AI alt-text suggestions are also available on Pro plans (human review recommended). Full compliance requires source code fixes and manual review; cerez.io shortens the process and documents the evidence. Not an overlay.

Short answer: EN 301 549 is the European Standard that harmonizes the WCAG criteria as an EU technical standard. The EAA uses EN 301 549 as its technical compliance reference. Compliance with EN 301 549 V3.x (WCAG 2.1 AA) meets the EAA's technical requirements. Newer versions are also converging toward WCAG 2.2.

Short answer: Each member state appoints its own supervisory authority. In Germany the relevant body operates within the BFSG framework, and other member states have their own competent authorities. It starts with a consumer complaint and continues as market surveillance. In some countries civil or collective lawsuits are also possible.

Start your EAA compliance process by measuring it. başlatın.

40+ features, 10+ profiles, support for 10 languages, WCAG 2.2 scanning and an EAA statement generator. Dual KAİK and EAA compliance, Turkish support, not an overlay.

This page is for general information purposes and does not constitute legal advice. For obligations specific to your company, consult your legal counsel.


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