If your product is not EAA compliant, the first step is to get a clear picture of where you stand. That means conducting an accessibility audit against EN 301 549, the standard the European Accessibility Act references. From there, you prioritize the issues identified, remediate them, and document your conformance status with an ACR.
The European Accessibility Act went into effect on June 28, 2025. Products and services covered under the law are expected to meet accessibility requirements now. If your product does not conform, you are not alone, but acting quickly matters.
| Step | What It Involves |
|---|---|
| Audit | A manual accessibility audit against WCAG 2.1 AA or WCAG 2.2 AA and EN 301 549 to identify all conformance issues |
| Prioritize | Rank issues by user impact and legal risk so your team addresses the most critical problems first |
| Remediate | Fix accessibility issues in your product with developers who understand WCAG success criteria |
| Document | Produce an ACR using the VPAT EN 301 549 edition and publish an accessibility statement |
| Monitor | Ongoing scans and periodic audits to maintain conformance as your product evolves |
Why EAA Compliance Cannot Wait
The EAA applies to a broad range of products and services sold or offered within the European Union. This includes e-commerce websites, banking apps, self-service terminals, and digital services like streaming platforms.
EU member states each have their own enforcement body and penalty structure. Fines, product withdrawal from market, and service suspension are all within scope for noncompliance. The longer you wait, the more exposure you carry.
Start with an Accessibility Audit
Before fixing anything, you need to know exactly what is wrong. An accessibility audit evaluates your product against WCAG 2.1 AA (the conformance standard mapped to EN 301 549) and identifies every issue that needs attention.
Scans can flag some issues, but they only detect approximately 25% of accessibility issues. A manual audit conducted by a qualified auditor is the only way to determine WCAG conformance. Accessible.org audits are always fully manual, covering every applicable success criterion.
If your product is a web app, mobile app, or SaaS platform, the audit scope should cover representative screens and key user flows. Your auditor will walk through the product the way a real user would, including with assistive technology.
How Do You Prioritize What to Fix First?
Once the audit report is delivered, you will have a list of issues with severity ratings. Not every issue carries the same weight. A missing form label on your checkout page affects more users than a contrast issue in your footer disclaimer.
User Impact and Risk Factor prioritization formulas help your team decide where to start. Focus on issues that block core functionality first: navigation, forms, authentication, and transactional flows. These are the areas enforcement agencies and users will notice.
Accessible.org audit reports include severity ratings that map directly to remediation priority.
Remediate Accessibility Issues
Remediation is the actual development work. Your engineers or a remediation partner work through each issue in the audit report, making code-level changes to bring the product into WCAG conformance.
Common fixes include adding proper heading structure, correcting ARIA attributes, providing text alternatives for images, and making interactive components keyboard accessible. Some issues require design changes. Others are simple code updates.
Remediation is most efficient when your developers understand what each WCAG success criterion requires. Accessibility training for your development team reduces the time and cost of fixing issues and prevents new ones from being introduced.
Document Your Conformance Status
After remediation, you need documentation that demonstrates your product’s accessibility status. Two key documents apply here.
An Accessibility Conformance Report (ACR) is created using the VPAT template. For EAA compliance, the EN 301 549 edition of the VPAT is the correct choice. The ACR details how your product conforms (or partially conforms) to each applicable criterion. Understanding ACRs and the VPAT process is important before you request one.
An accessibility statement is a public-facing document that describes your product’s conformance level, known issues, and contact information for users who encounter accessibility problems. Some EU member states require an accessibility statement as part of EAA compliance.
Set Up Ongoing Monitoring
Conformance is not a one-time event. Every product update, new feature, or content change can introduce new accessibility issues. Periodic audits and automated scanning between audits help you catch regressions early.
Pairing periodic manual audits with continuous scanning creates a practical maintenance approach.
What If You Cannot Fix Everything Right Away?
Most products will not go from noncompliant to fully conformant overnight. That is expected. What matters is demonstrable progress and a documented plan.
Create a remediation roadmap with target dates for each phase. Prioritize the issues with the highest user impact. Document your plan and make it available if an enforcement body requests it. A product with known issues and an active remediation timeline is in a very different position than one with no plan at all.
Some organizations also publish interim accessibility statements that acknowledge current shortcomings and outline the timeline for resolution. Transparency works in your favor.
Do You Need an Accessibility Consultant?
If your team has no experience with WCAG or EN 301 549, working with an accessibility consultant or audit provider shortens the path to EAA compliance significantly. An experienced auditor knows which issues carry the most risk and can advise on remediation strategy alongside the audit itself.
Accessible.org provides EAA-specific consulting and audit services mapped to EN 301 549. That includes audits, remediation guidance, ACR creation, and accessibility statements.
Can my product still be sold in the EU while noncompliant?
It depends on the member state and enforcement timelines. Some enforcement bodies may issue warnings before penalties. But continued sale of a noncompliant product carries increasing legal and financial risk. Starting remediation now reduces that exposure.
Which VPAT edition do I need for the EAA?
The EN 301 549 edition. This maps your product’s conformance to the European standard referenced by the EAA. If you also serve U.S. customers, the INT edition covers both Section 508 and EN 301 549 in a single report.
How long does it take to become EAA compliant?
Timeline depends on the size of your product and the number of accessibility issues identified. A small web app might reach WCAG 2.1 AA conformance in a few weeks. A large SaaS platform with multiple user roles and complex workflows could take several months of phased remediation.
Is WCAG 2.2 AA required for EAA compliance?
EN 301 549 currently maps to WCAG 2.1 AA. Some organizations are moving to WCAG 2.2 AA proactively because it is the newest version and may be adopted in future EN 301 549 updates. Either standard satisfies current EAA requirements, but 2.2 AA positions you ahead of regulatory changes.
The EAA deadline has passed, but the window for action is still open. A structured approach, starting with an audit and moving through prioritization, remediation, and documentation, is the clearest path to compliance.
Contact Accessible.org for EAA compliance consulting, EN 301 549 audits, and ACR creation.
