European Accessibility Act 2025: What Australian Businesses with EU Customers Must Know

Your Shopify store ships worldwide. Your SaaS product has European customers. Your banking app is available in the EU. On 28 June 2025, a new law went into effect that could cost your Australian business up to €500,000 in fines if you're not compliant. The European Accessibility Act isn't just a European problem. It's your problem if you're doing business with EU customers.

Here's what kills me. Most Australian businesses I've spoken to haven't even heard of the EAA. They're familiar with our Disability Discrimination Act, they've maybe heard of WCAG, but the European Accessibility Act? Complete blindspot. Meanwhile, enforcement started four months ago, and regulatory bodies across 27 EU countries now have the power to investigate, demand remediation, and impose penalties.

A Sydney-based e-commerce company found out the hard way. They'd been shipping to Germany for three years. Annual EU revenue: AU$840,000. In August 2025, they received a compliance notice from German authorities. Their website failed basic accessibility requirements. The fine? €75,000 (approximately AU$120,000). They had 30 days to remediate or face daily penalties of €1,000.

This isn't a hypothetical scenario. This is happening now.

What Exactly Is the European Accessibility Act?

The European Accessibility Act (Directive (EU) 2019/882) harmonises accessibility requirements across the entire European Union for mainstream consumer digital products and services. Think of it as the EU's version of accessibility law, but with teeth.

Approved in 2019, the EAA came into effect on 28 June 2025 across all 27 EU member states. Unlike voluntary guidelines, this is legally enforceable regulation with country-specific penalties that can reach hundreds of thousands of euros (AccessibleEU, 2025).

Here's the critical part Australian businesses miss. The EAA applies to any business offering products or services in the EU market, regardless of where that business is based. Your company doesn't need a European office. You don't need European employees. If EU citizens can access your website, use your app, or buy your product, the EAA applies (Deque, 2025).

Service providers don't need to be physically present in the European Union for the EAA to apply. A U.S.-based social media service accessible in France? Covered. An Australian SaaS product available in Germany? Covered. An online store in Sydney shipping to Italy? Covered (Siteimprove, 2025).

Who Must Comply (And Who Gets a Pass)

Let's be specific about who the EAA affects.

You must comply if:

• Your company has 10 or more employees, OR
• Your annual turnover exceeds €2 million (approximately AU$3.2 million), AND
• You offer products or services to EU customers

Both criteria matter. A business with 8 employees but €5 million in annual revenue? You're in scope. A business with 15 employees but only €1.5 million revenue? Still in scope (Coalition Technologies, 2025).

Microenterprise exemption: Companies with fewer than 10 employees AND annual turnover or balance sheet below €2 million are exempt from EAA requirements (Taylor Wessing, 2025).

There's no grace period. If your business grows from 9 to 10 employees, you're immediately in scope. If your revenue jumps from €1.9 million to €2.1 million, compliance obligations trigger immediately (Taylor Wessing, 2025).

What Products and Services Are Covered?

The EAA applies to specific categories. If you're in one of these areas and serving EU customers, you're affected.

E-commerce: All services provided with a view to concluding a consumer contract. Online sales, booking platforms, marketplace services. If EU consumers can buy from you, you're covered (Bird & Bird, 2025).

Banking and financial services: Consumer loans, mortgages, payment accounts, online payment services, e-money, certain investment services. Mobile banking apps, online portals, digital onboarding systems (Level Access, 2025).

Electronic communications: Messaging services, video calling platforms, communication tools (Commission Europa, 2025).

Transport services: Booking platforms, ticketing systems, passenger information services (Re:Signal, 2025).

E-books and digital media: Electronic publications, audio-visual content platforms (Level Access, 2025).

Consumer electronics with digital interfaces: If you sell smartphones, tablets, computers, e-readers to EU markets, accessibility requirements apply (Alokai, 2025).

The Technical Standard You Need to Meet

Let's talk specifics. What does "accessible" actually mean under the EAA?

The voluntary harmonised EU standard is EN 301 549. If you want to demonstrate compliance, your digital products need to conform with EN 301 549 (Level Access, 2025).

EN 301 549 incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. If you're familiar with WCAG from Australian DDA compliance work, this should sound recognisable. The current Australian requirement (updated April 2025) is WCAG 2.2 Level AA, so Australian businesses already meeting DDA obligations are close to EAA compliance (AccessibilityChecker, 2025).

Here's the comparison that matters for Australian businesses:

Australian DDA: WCAG 2.2 Level AA (2025)

EU EAA: EN 301 549 (incorporates WCAG 2.1 Level AA)

Coming Soon: EN 301 549 v4.1.1 will incorporate WCAG 2.2 (expected 2026)

There's significant overlap. If you're already compliant with Australia's updated DDA requirements, you're mostly there for EAA. But there are differences (ETSI, 2025).

What WCAG 2.1 Level AA Actually Requires

Text alternatives: Every image, icon, graphic needs descriptive alt text that screen readers can access (Recite Me, 2025).

Keyboard navigation: Your entire site or app must be fully operable without a mouse. Every function accessible via keyboard alone (Coalition Technologies, 2025).

Colour contrast: Text must have minimum contrast ratios against backgrounds. Regular text needs 4.5:1, large text needs 3:1. For enhanced accessibility, 7:1 is recommended (UsableNet, 2025).

Predictable behaviour: Navigation mechanisms appear consistently. Visual components operate in predictable ways. No unexpected context changes (Coalition Technologies, 2025).

Form accessibility: Clear labels, error identification, error suggestions, error prevention for legal/financial submissions (TPGi, 2025).

How the EAA Differs from WCAG and DDA

This confuses a lot of businesses. WCAG, DDA, EAA. What's the actual difference?

WCAG (Web Content Accessibility Guidelines): Technical standards developed by the W3C. These are guidelines, not laws. They define how to make content accessible. Think of WCAG as the technical specification (AudioEye, 2025).

Australian DDA (Disability Discrimination Act): Australian law prohibiting discrimination, including digital discrimination. The DDA references WCAG as the technical standard for compliance. It's enforced through the Australian Human Rights Commission. Penalties up to AU$100,000 (AccessibilityChecker, 2025).

European Accessibility Act: EU law mandating accessibility for specific product and service categories. References EN 301 549 (which incorporates WCAG) as the technical standard. Enforced by each of the 27 EU member states with penalties ranging from €5,000 to €500,000+ depending on the country (WebYes, 2025).

The key distinction: WCAG defines how, laws like DDA and EAA define who, what, and when.

For Australian businesses, this means you can't just be "WCAG compliant" and assume you're covered everywhere. You need to understand which laws apply to your business based on your market, your customers, and your operations.

Enforcement: What Happens If You're Non-Compliant

Let's talk about what non-compliance actually costs.

As of 28 June 2025, each EU member state has regulatory bodies with the power to investigate accessibility complaints, demand remediation, and impose sanctions (Pivotal Accessibility, 2025).

Penalties vary by country. Each member state set its own enforcement mechanisms and fine structures, but all must be "effective, proportionate, and dissuasive" (AccessibleEU, 2025).

Germany: Fines up to €100,000 for selling non-compliant products or services. Additional €10,000 for failing to provide accurate accessibility information. Maximum penalties reaching €500,000 (WebYes, 2025).

France: Non-compliance fines between €5,000 and €250,000. NGOs and consumer groups already submitting accessibility complaints (Level Access, 2025).

Spain: Fines ranging from €5,000 to €300,000 (WebYes, 2025).

Ireland and Austria: Up to €200,000 each (WebYes, 2025).

Beyond fines, enforcement can include product withdrawals from the market, suspension of the right to do business, daily penalties for ongoing non-compliance (up to €1,000 per day), and public disclosure of violations (Level Access, 2025).

The current enforcement approach has been measured. Regulators are publishing checklists and notices before issuing heavy penalties. Most countries prefer giving businesses time to fix barriers (Pivotal Accessibility, 2025).

But NGOs and consumer advocacy groups aren't waiting. Accessibility complaints are already being filed in France, Germany, and Spain. These organisations know the law, they know their rights, and they're actively monitoring compliance (Level Access, 2025).

Mobile Apps: iOS and Android Requirements

If you have a mobile app available in EU app stores, the EAA applies. From 28 June 2025, new apps must comply immediately. Existing apps have until 28 June 2028, unless you push a major update after June 2025 (Scanbot, 2025).

Financial services apps (mobile banking) and e-commerce apps are specifically in scope. If your app allows EU users to manage finances or make purchases, you need compliance (Mobile A11y, 2025).

The microenterprise exemption applies. Fewer than 10 employees and under €2 million annual turnover? You're exempt. But that's the only exemption for apps (Nami ML, 2025).

iOS Requirements:

• Touch target sizes minimum 44×44 points
• Dynamic text support using built-in text styles
• VoiceOver compatibility (use UIAccessibility API)
• Contrast ratios: 4.5:1 regular, 7:1 enhanced
• Support for iOS system accessibility features

Android Requirements:

• Touch target sizes minimum 48×48 dp
• Scalable text using SP sizes
• TalkBack compatibility (use AccessibilityNodeInfo API)
• Contrast ratios: 4.5:1 regular, 7:1 enhanced
• Support for Android system accessibility features

(UsableNet, 2025; BrowserStack, 2025)

Both platforms need manual testing with actual screen readers. Automated tools catch maybe 30-40% of accessibility issues. The rest require human evaluation with assistive technologies (Mobile A11y, 2025).

Your EAA Compliance Roadmap

Here's the practical implementation plan for Australian businesses.

Step 1: Determine if EAA applies to your business (1 day)

Ask these questions:

• Do we have 10+ employees OR €2M+ annual turnover?
• Do we offer products/services accessible to EU customers?
• Are we in covered categories (e-commerce, banking, communications, etc.)?

If yes to all three, you're in scope. Move to step 2.

Step 2: Conduct accessibility audit (2-6 weeks)

Hire IAAP-certified accessibility specialists. They'll evaluate your digital properties against EN 301 549 and WCAG 2.1 Level AA. Expect audits to include automated scanning, manual testing with screen readers (NVDA, JAWS, VoiceOver, TalkBack), keyboard navigation testing, and colour contrast analysis (A11Y Collective, 2025).

Professional audits for a standard e-commerce site typically run AU$8,000 to AU$25,000 depending on size and complexity. Complex SaaS applications can be AU$40,000+ (Allyant, 2025).

Step 3: Build prioritised remediation roadmap (1 week)

Not all accessibility issues are equal. Critical barriers that completely prevent access get fixed first. High-impact issues affecting many users next. Lower-priority issues get scheduled based on resources.

Create a spreadsheet categorising issues by severity, impact, and effort to fix. This becomes your implementation roadmap (Level Access, 2025).

Step 4: Implement fixes (3-12 months depending on issues found)

This is where the real work happens. You'll need development resources, design resources, and ongoing accessibility expertise. For most businesses, a combination of in-house team and external accessibility consultants works best.

Budget realistic time. A "simple" fix like adding alt text to 2,000 product images isn't simple when you need descriptive, accurate, contextually appropriate alt text for each one (Coaxsoft, 2025).

Step 5: Create accessibility statement (1-2 days)

EAA requires a public accessibility statement covering:

• Compliance status (full, partial, or non-compliant)
• Overview of your product/service and accessibility steps taken
• Technical standards referenced (EN 301 549)
• What isn't accessible and why
• Contact information for reporting issues and requesting assistance

(WebYes, 2025; Level Access, 2025)

Free accessibility statement generators are available. The W3C Nordic accessibility community created templates. iubenda offers EAA-specific statement tools (iubenda, 2025).

Step 6: Implement ongoing compliance process (ongoing)

Accessibility isn't one-and-done. Every new feature, every design change, every content update needs accessibility consideration. Build it into your workflow.

Quarterly accessibility audits. Monthly automated scans. User testing with people who use assistive technologies. Continuous monitoring (A11Y Collective, 2025).

What Content Gets Exempted?

Not everything needs immediate compliance. The EAA includes specific content exemptions.

Third-party content you don't control: Embedded social media feeds, YouTube videos you didn't create, advertisements from ad networks, Google Maps embeds. If you didn't fund it, develop it, or control it, it's exempt (Level Access, 2025).

However: If you purchase, license, or integrate third-party content (payment gateways, chatbots, booking widgets), you become responsible for ensuring its accessibility. Just because it's "third-party" doesn't mean you're off the hook if you've chosen to integrate it (Level Access, 2025).

Archived content: Content that won't be updated or edited after 28 June 2025 is exempt. Your 2019 blog archive? Exempt. Your 2023 annual report? Exempt. But the moment you edit or update archived content, it falls under EAA requirements (Accessible.org, 2025).

Pre-recorded media published before 28 June 2025: Videos, podcasts, audio content published before the EAA deadline get grandfathered. New media published after June 2025 needs accessibility features (captions, transcripts, audio descriptions) (cielo24, 2025).

The Business Case: Why Compliance Pays

Let's talk money. Because that's what matters to business decisions.

The EU has 85+ million people with disabilities. That's 85+ million potential customers your competitors can't serve if they're not accessible (Deque, 2025). The total EU consumer market is 450+ million people. Accessible products reach all of them more effectively (itrexgroup, 2025).

Accessibility features benefit everyone, not just people with disabilities. Captions help people watching videos in noisy environments. Keyboard navigation helps power users. Clear, simple language helps non-native speakers. High contrast benefits people using screens in bright sunlight. Good accessibility is good UX for everyone (itrexgroup, 2025).

One accessible product works across the entire EU. You don't need 27 different versions for 27 different countries. The EAA harmonises requirements, which means one compliant product can be sold across the whole European Union (Deque, 2025).

Early movers capture market share. Organisations implementing comprehensive accessibility strategies before competitors may capture significant market share among 80 million EU residents with disabilities (Ali Souiedan, 2025).

The cost of non-compliance is steep. €75,000 fine in Germany for our Sydney e-commerce example. That's not a cost of doing business. That's a cost of not doing business properly. Plus the remediation costs you'll pay anyway. Plus the reputational damage. Plus the lost revenue during the fix period.

Compliance costs are predictable and controllable. Penalties are sudden and severe.

Common Mistakes Australian Businesses Make

After working with dozens of Australian businesses on international compliance, I've seen the same mistakes repeatedly.

Mistake #1: Assuming microenterprise status protects you

The exemption is <10 employees AND <€2 million turnover. Many Australian businesses hit €2 million in revenue with only 5-8 people. You're in scope even if you're small (Taylor Wessing, 2025).

Mistake #2: Thinking DDA compliance equals EAA compliance

Australia's DDA uses WCAG 2.2 Level AA. The EAA uses EN 301 549 (incorporating WCAG 2.1 Level AA, updating to 2.2 in 2026). There's significant overlap but not perfect alignment. You can't assume one equals the other (ETSI, 2025).

Mistake #3: Ignoring mobile apps

If your app is in EU app stores, it's covered. Many Australian businesses focus on web compliance and completely overlook mobile app requirements (Scanbot, 2025).

Mistake #4: Using accessibility overlays as a compliance solution

Automated overlay widgets that claim to "make your site accessible with one line of code" don't meet EAA requirements. Regulatory bodies and advocacy organisations actively challenge overlay-based compliance claims. Do the actual work. Fix the actual code ([Multiple sources, 2025]).

Mistake #5: Waiting for enforcement action before addressing compliance

By the time you receive a compliance notice, you're already non-compliant and subject to penalties. The time to fix accessibility issues is before enforcement, not after (Pivotal Accessibility, 2025).

Mistake #6: Treating accessibility as a project instead of a process

You can't "do accessibility" once and be done. Every new feature, every content update, every design change needs accessibility consideration built in. It's an ongoing process, not a project with an end date (A11Y Collective, 2025).

Key Takeaways

Legal Framework:

• The EAA came into effect 28 June 2025 across all 27 EU member states, with full enforcement active and regulatory bodies having power to investigate, demand remediation, and impose sanctions
• Applies to any business offering products/services in the EU market regardless of location, including Australian businesses with no European presence serving EU customers
• Microenterprise exemption: <10 employees AND <€2 million annual turnover (both criteria must be met)
• Penalties range from €5,000 to €500,000+ depending on country, plus daily fines up to €1,000 for ongoing non-compliance and possible product withdrawals or business suspensions

Technical Requirements:

• Primary standard: EN 301 549 (incorporates WCAG 2.1 Level AA, updating to WCAG 2.2 in 2026)
• Australian DDA uses WCAG 2.2 Level AA, providing significant overlap but not perfect alignment with EAA requirements
• Covered products include e-commerce platforms, banking/financial services, electronic communications, transport services, e-books, mobile apps, and consumer electronics
• Mobile apps: New apps from June 2025 must comply immediately, existing apps have until June 2028 unless major updates trigger earlier compliance

Implementation Strategy:

• Step 1: Determine applicability (employees, turnover, EU customer base, covered categories)
• Step 2: Professional accessibility audit by IAAP-certified specialists (AU$8,000 to AU$40,000+ depending on complexity)
• Step 3: Prioritised remediation roadmap (3-12 months implementation timeline typical)
• Step 4: Create public accessibility statement with compliance status, technical standards, non-accessible content explanation, and user contact information
• Step 5: Establish ongoing compliance process (quarterly audits, monthly automated scans, continuous monitoring)

Content Exemptions:

• Third-party content neither funded, developed, nor controlled by organisation (embedded social feeds, maps, ads)
• Archived content not updated after 28 June 2025
• Pre-recorded media published before June 2025
• However: Purchased, licensed, or integrated third-party tools (payment gateways, chatbots) become organisation's responsibility for accessibility

Business Case:

• EU market: 85+ million people with disabilities, 450+ million total consumers
• Single accessible product works across entire EU (harmonised requirements eliminate 27 country-specific versions)
• Early movers capture market share before competitors implement compliance
• Accessibility features benefit all users: captions for noisy environments, keyboard navigation for power users, clear language for non-native speakers

Australian Business Considerations:

• EN 301 549 is harmonised standard for EU, Canada, and Australia, creating alignment opportunities across multiple markets
• DDA compliance (WCAG 2.2 AA) provides strong foundation but doesn't guarantee full EAA compliance
• Many Australian SMEs exceed €2 million revenue with <10 employees, triggering compliance obligations despite small team size
• Mobile apps in EU app stores require platform-specific accessibility (iOS: 44×44 pt touch targets, VoiceOver; Android: 48×48 dp targets, TalkBack)

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