Here at Accessible.org headquarters, we’re getting the distinct impression that very, very few companies will actually be compliant with the European Accessibility Act (EAA) by the June 28, 2025 deadline. This leads us to ask, is everyone waiting to study until the night before the exam?
We say yes.
We’ve seen this play out in accessibility with Colorado state law HB21-1110 where so few state and local governments were compliant, they literally extended the deadline for a year.
Could we see an EAA deadline extension?
Very likely not. The EAA applies to new products placed on the market after June 28, 2025, but all services provided to consumers after that date must be accessible, including existing services. The only exceptions are microenterprises providing services (which are fully exempt), existing service contracts signed before June 28, 2025 (which can continue unchanged for up to 5 years), and products used in service delivery (which have transitional provisions until 2030).
Our impression is that most of the monitoring authorities in the EU member states aren’t waiting for the clock to strike midnight on June 28 to take out their penalty book and start assessing fines. However, remember that different regulators (representing different member states) will have different approaches and some may indeed apply the EAA strictly.
One potential scenario is a few larger corporations are penalized and made an example of to get other economic operators hustling to become compliant.
Another possibility is that monitoring authorities assess a slew of lighter fines early on so as not to be overly harsh, but at the same time show that EAA compliance needs to be taken seriously and that covered entities need to hurry.
It’s important to understand what actually needs to be compliant by June 28, 2025:
- New products entering the market after this date
- All services provided to consumers (not just new services)
- However, there are important exceptions: microenterprises providing services are exempt, existing service contracts can continue unchanged for up to 5 years, and products used to deliver services (like servers or terminals) can continue being used until 2030 if they were lawfully in use before the deadline
We recently wrote about what to do if you’re not going to make the EAA deadline and the advice comes down to this:
- Be proactive
- Be transparent
- Don’t lie
Also, where feasible, for products: consider withdrawing the non-compliant product from the market. For services: implement corrective measures to bring the service into compliance with accessibility requirements.
If you start really pushing for compliance, you can accomplish a lot in just a few short months — and you’ll be far ahead of many others who have procrastinated, but aren’t proactive.
A big part of EAA compliance is investing in accessibility, making real progress, tracking that progress, and keeping records. We can help with organizing your project and demonstrating you’re making a genuine effort to be compliant. This helps your organization be in the best position possible, given your current non-compliant status.
If you need to start EAA compliance efforts ASAP, we’d love to help. Just send us a message and we’ll be right back with you.
Also, have you seen our EAA in plain English outline for the admin side of compliance? That PDF is a must download because it makes the EAA obligations easier to understand.
Legal Disclaimer: This post represents our interpretation and analysis of the European Accessibility Act (EAA) and related accessibility requirements and obligations but does not constitute legal advice. While we strive for accuracy, Directives and their interpretation may vary by EU member state and change over time. Consult with legal counsel regarding your specific situation.
Update: This article has been corrected to clarify that existing services must become accessible by June 28, 2025, with an exception only for pre-existing contracts.
