Accessibility Law Strategy: From Requirements to Implementation

We summarize what the EU's European Accessibility Act (EAA) and its implementation means in practice for product teams. From legal responsibility to concrete technical requirements.

The law can seem overwhelming at first glance. But when you break it down into actionable steps, the path forward becomes clear. This guide helps you create a strategy that doesn't just meet minimum requirements – but creates real value for users and organization.

We cover the legislation background, who's covered, technical requirements, and how to prioritize resources for maximum effect.

Overview of regulations

There are several laws regulating digital accessibility in the EU. Here are the most important:

Web Accessibility Directive (WAD)

Applies since 2016/2019 for public sector. Requires websites and apps to meet WCAG 2.1 Level AA. Enforcement varies by member state.

European Accessibility Act (EAA)

Comes into full force June 28, 2025 and covers private sector. Covers e-commerce, banking services, transport services, e-books, and more. Enforcement by national consumer protection authorities.

National implementations

Each EU member state implements these directives into national law. Technical requirements are consistent (WCAG 2.1 AA), but enforcement mechanisms vary.

Common denominator: All point to WCAG 2.1 Level AA as the technical standard.

Is your organization covered?

Public sector: Yes, without exception. Government agencies, municipalities, regions, and organizations funded more than half by public money.

Private sector (after June 2025):

If you offer any of these services to consumers:

Exceptions:

Micro-enterprises (under 10 employees and under €2M revenue) are exempt from service requirements, but not from product requirements if they sell physical products with digital interfaces.

B2B:

The directive focuses on B2C. Purely internal systems and B2B services are generally not covered – but public procurement can require accessibility compliance.

Technical requirements: WCAG 2.1 AA explained

WCAG (Web Content Accessibility Guidelines) is the technical standard the law references. Level AA contains 50 success criteria, organized in four principles:

1. Perceivable

Users must be able to perceive content with their senses – vision, hearing, touch.

2. Operable

Users must be able to interact with the interface.

3. Understandable

Users must be able to understand content and how the interface works.

4. Robust

Content must work with different user agents, including assistive technology.

WCAG isn't a checklist to tick off – it's principles for building products that work for everyone.

Prioritizing the work

You can't fix everything at once. Here's a proven prioritization framework:

Phase 1: Critical blockers (immediate)

Problems that make it impossible for users with disabilities to use the service at all:

Phase 2: Serious issues (1-3 months)

Problems that severely degrade the experience:

Phase 3: Medium issues (3-6 months)

Problems that irritate but don't block:

Phase 4: Improvements (ongoing)

Polish that raises quality further.

This order ensures you won't be reported for blocked user journeys while you're polishing details.

Building an accessibility roadmap

A roadmap provides structure and shows leadership the work is under control.

Step 1: Inventory (Week 1-2)

Do an initial scan with Xrayd or similar. Document all findings and categorize by severity.

Step 2: Gap analysis (Week 3)

Compare against WCAG 2.1 AA requirements. Identify which criteria you pass and which fail.

Step 3: Prioritization (Week 4)

Use the prioritization framework above. Create a backlog with clear owners.

Step 4: Implementation (Months 2-6)

Work systematically through the backlog. Integrate accessibility into sprints.

Step 5: Validation (Month 6)

Do an expert review to verify critical issues are addressed.

Step 6: Continuous improvement (Ongoing)

Establish routines to prevent regression. See our guide on long-term follow-up.

Resource planning: What does it cost?

Cost depends on current state. A site with many problems requires more resources than one that's already decent.

Initial remediation phase:

Expect 10-30% of a developer's time for 3-6 months, depending on site size. Design changes may require additional resources.

Expert audit:

€5,000 - €20,000 for external review, depending on scope.

Ongoing maintenance:

After initial remediation, expect 5-10% of development time to maintain accessibility.

Tools:

Xrayd and similar services cost a few hundred euros per month. That's cheaper than a consultant hour and scales better.

ROI:

Beyond avoiding fines, accessibility improves SEO, reduces support tickets, and opens markets (15% of population has disability).

Legal liability: Who's held accountable?

The organization is ultimately responsible. Individual developers or designers cannot be personally fined – it's the company that owns the product.

Sanctions for violations:

Enforcement:

National consumer protection authorities can act on their own initiative or after complaints. Users can report problems directly to the authority.

Tip:

Document your efforts. If you can show you're actively working on accessibility with a reasonable plan, authorities often view transitional gaps more favorably.