Another European Accessibility Act (EAA) post, yes, but this one will perhaps be a bit different.
My opinions only, please do not forget this. I am not a lawyer and the subject is very complex, because of multiple interconnecting facts on international level. And I will just reflect upon some facts and some “between the lines”, as an opinionated messenger, hopefully add to diversity of perspectives.
EAA and this post are mostly about EU countries, but as we will see later – it’s sometimes much wider. It’s actually not so much about geography, it’s more about which products and services and if they are sold to customers in EU actually. I will not even go into products (by definition of EAA these are physical products and also have a different time-frame), just services (which means digital services actually).
That’s also why I didn’t write European accessibility era, but International accessibility era in the title. Remember General Data Protection Regulation (GDPR)? Well EAA is similar as GDPR in that way…
OK, let’s dive in. I will start with the good parts and then add some not so good parts. Then I will add some additional thoughts.
The good parts of EAA
A lot is written about the good parts and I will try not to repeat a lot here.
Awareness
I need to start with awareness, as it’s the usual suspect for lack of accessibility. With Web Accessibility Directive (WAD), I hoped, we would get more awareness. And we did. But not as much as I would like to. I see that accessibility got more “airtime”. Still not enough, especially in e-commerce that is often still ignoring accessibility, but I saw that banks listened more (still not enough, but at least they did not ignore it). And, perhaps I am in a social media bubble, but every day for the last year I got an article or a post about accessibility because of EAA coming. Amazing effect for awareness.
Harmonization
The best part is that accessibility in the private sector will be a requirement in more countries. Some countries have this requirements for decades and some just got them now. Public sector has it’s WAD for quite some time (2020) and we all can and should learn from experiences gathered there. In some ways EAA is similar to WAD, most central similarity is the harmonization.
So – the main objective of harmonization of accessibility requirements for the whole market – is really an important thing.
It is therefore necessary to harmonise accessibility requirements across the digital single market and to ensure that all Union citizens, regardless of their abilities, can enjoy its benefits.
EAA article 11 (opens in new window)
Another similarity with WAD is that WAD was the minimum, the baseline. EAA is also the minimum and countries can go beyond if they want to. And some did.
New accessibility standards and updates of existing ones
End of 2025 and sometimes in 2026 we can also expect news and updates of standards that will support EAA.
WCAG 2.2 will be integrated in EN 301 549, just a matter of time (some indications that this will be in 2026, and there will be some other updates beyond WCAG 2.2). While EN 301 549 is not directly required by the EAA we can see that authorities in different countries consider it good enough for compliance with EAA. A reminder – WCAG is not enough as EN 301 549 includes requirements that go beyond.
EN 17161 Design for All – a non technical standard will get updated. It’s not discussed enough, unfortunately, but design for all is actually mentioned in the EAA.
Accessibility should be achieved by the systematic removal and prevention of barriers, preferably through a universal design or ‘design for all’ approach, which contributes to ensuring access for persons with disabilities on an equal basis with others.
EAA article 50 (opens in new window).
Built environment will also get EN 17210 Accessibility and usability of the built environment.
Non-ICT information-related to products will also get a new standard – that’s also an amazing upside.
And we will also get a new standard for accessibility of support services related to products and services (help desks, call centres, technical support, relay services and training services).
And another extremely important standard, for accessibility and interoperability of emergency communications and for the answering of emergency communications by the public-safety answering point (PSAPs) – including to the single European emergency number 112.
Standards are essential when it comes to harmonization and I am really happy EAA provided the platform for them to arrive and update.
EAA scope is much wider than we imagine
As mentioned in the beginning – geographic scope is absolutely not only EU. Not only EU and EFTA. It’s actually worldwide. If company is for example e-commerce selling to EU, then it has to respect EAA. As with GDPR in a way. EAA is here to protect EU customers, so if you want them – yes – you have to conform to EAA.
This is amazing, but not only this. Think also about other side-effects of EAA. Cookie consent solutions nowadays are often third party. Chat as well. Payment solutions as well. Sometimes even form solutions that we use. Or CRM solutions that provide form solutions that we use. Website authoring tools and CMSes. The list goes on and on. Basically anything that will be customer facing and a part of e-commerce or banking or transportation booking digital services will need to be accessible. And people will need their third parties to conform. Or they will use others that do. This is an amazing side-effect that we really need to be aware of. I’ve done a lot of audits where third parties were integral and not accessible. This meant that we can do amazing accessibility work, but if third party that is crucial is not accessible – all that work can be lost.
More providers of accessibility services
With parts of private sector required to be more accessible we got a demand for accessibility specialists. And that is another positive thing, because there are now more people learning and teaching accessibility. Or even just promoting it. And writing publicly about their “aha moments” and journeys. That’s also amazing. We all need to start somewhere, and we still definitively need more accessibility specialists.
Artificial intelligence will also be more accessible
If AI would be so hot years ago it would be less accessible. EAA is also positively impacting AI, in many ways. Starting with chatbots that are more and more popular for customer support, selfcare and contact points. And you probably noticed the integrations of AI into popular office packages, operating systems and so on. It’s a fact that EAA helps to make AI more accessible as well. And if AI powered products are integral in e-commerce – they will also need to comply with EAA.
The bad parts of EAA
I like to be positive about things, especially things that promote and improve accessibility. But we also need to be honest and transparent and sometimes we need to write about things so that things can improve. Once again – my personal views, not related to any organization I am a part of. I am human, which says that I can – and sometimes are – wrong. Just some opinions that I think will add to the reality and hopefully improve things.
Harmonization is not so harmonized
EAA is harmonized and integrated. Countries can go beyond. Many did. So at the end – we do not actually have the harmonization I was expecting.
I hoped that if I make a service in EU country A that conforms to EAA, it will also conform in country B. You can say that it does, but in reality, when EAA was implemented as a baseline and country B added their own specific requirements that country A didn’t – then harmonization stayed only in the parts of the EAA. I still need to check for all the differences and implement them, I need to check the specifics of all countries I want to sell the service in. Sure, it helps to have a common baseline, but if I am not a very large corporation, with lots of resources, I need to invest a lot of time and money into studying all the differences, so that I am covered.
Unified market – yes, but not really. Larger corporations will have huge advantage here, with the additional resources, as always.
WAD was also specific about accessibility statements. EAA tries to be, but it is less clear. Some countries require accessibility statement, but mostly we are not sure at the moment. EAA could just do like WAD did and require them. It’s again something that needs to be researched from country to country.
I would really like to see a resource of all the differences beyond EAA itself, in a central place, open source. Now we all need to check for country specifics, often translate texts, search for official sources…
It is possible to be compliant with Danish law, but not with German and French. And so on. Hope we will get clear leadership on how to deal with this situation, if we are to encourage cross-country, pan-European services, then we need to know about all requirements, and obviously target the strictest ones to comply in all.
Voluntary standards that are not so voluntary
EAA lists all accessibility requirements (opens in new window), but does not describe in detail how they should be met.
EAA does not define we need to use EN 301 549. I wish it would, because it would make things more understandable for people with disabilities, authorities and also some vendors that learned about it with experiences from Web Accessibility Directive.
I hear you say “but then we can not innovate”. I don’t want us not to innovate. We could still innovate with better methods that would work better for people with disabilities if EAA would just define something like – use EN 301 549 or something better, if you can prove it.
I understand that it can seem best to not define a standard explicitly, because then we can’t be “locked in” if there is something better than that standard out there. But we can write the law in a way that still allows better solutions. EN 301 549 is not perfect, but it is the best thing we have at the moment (when it will be updated with WCAG 2.2 and other updates). I want people with disabilities to be able to use products and services, and I know that any standard out there can fail to make sure things are actually also usable. I totally get the intention, and the gesture of freedom of choice. But when we look at the reality – EN 301 549 tries to make things more accessible than WCAG. It is currently the best accessibility standard out there. Why not refer to it explicitly and allow for better ones at the same time?
It will be interesting to see if somebody will, for example, use Accessible Perceptual Contrast Algorithm (APCA, opens in new window) instead of WCAG – a scenario that actually makes text more readable, but mathematically fails WCAG. Will authorities follow WCAG to the letter or will they recognize APCA automatically as it will actually be better for people? Hope to know the answer soon.
Nevertheless – it seems (please check in your country of interest for yourself) that EN 301 549 is the selected standard for EAA compliance in reality. Because authorities need something practical to use. And they know that with EN 301 549 they get also the WCAG and kind of cover perceivable, operable, understandable and robust (POUR, opens in new window).
It seems that methodologies work did not get enough resources
Now, this is perhaps a controversial and even a political question and only my own speculation. I don’t know anything about the background and financials here and honestly don’t want to use the time to research deeply. I know things are complex and took time and I really appreciate all the work done, but I can’t really understand how the methodologies seem to get such a low priority. It seems that specialist are now working round-a-clock with them and – as far as I can understand – mostly (?) as volunteers. I have forgotten where I have heard about it but I think it was in one of the webinars about EAA where it was mentioned that budget was done. If that is true, I don’t know, but it looks like it. They really deserve to be compensated for their work, and not only that – they need more people to help them. Methodologies are vital, having standards that require conformance and not having the methodologies that describe how can we reach the standard is a difficult situation for all of us. For all of EAA.
Working in accessibility is often more than just work for a lot of people, and we are often glad to contribute free of charge for the greater good. But so important things like methodologies need to be funded properly and people need to be compensated for their work. And if it is true that the funding was used, they should get a new budget.
Once again – I don’t know, but it seems like it. I may be totally off, but preparing methodologies for standards like EN 301 549 takes a looot of effort and it seems that stronger budget and more resources would help to get further.
There will be more accessibility-washing
It’s easy to “talk the talk” and not “walk the walk” and it’s happening from forever also in accessibility. But with current awareness levels, I see some companies trying to “accessibility wash” or “access wash” their efforts. This is very unfortunate, as it’s sometimes difficult to see if that was intentional or they just don’t know better.
We are all on different stages of our accessibility journeys, I totally get that. Sometimes we don’t know better. But we need to take this responsibly. It can be too quickly for some sales focused people to try to promise too much, or claim too much. It has always been so. But it’s quickly obvious for people with disabilities and we really need to do our best to prevent it. The world is full of barriers that are there because we didn’t know better. We need to work on the removal of barriers more.
Nobody is perfect, but we need to talk about this. Honesty before profit. A typical example can be an accessibility statement that has a fresh date every time we open it. With lots of words about how they really think of accessibility, but when we open the homepage we immediately see all the bad patterns in the book – from eye-sticking automatically playing hero videos with not controls to stop them, to mouse only mega menues and so on.
AI quick and fully automagical solutions for EAA compliance
AI helps a lot with accessibility. It is a fact for at least a decade now. Dependin on the definition of AI, we can also include machine learning, advanced computer vision, context based search results, image descriptions, video descriptions, audio conversions, automatic captioning, I think you can think of hundreds or even thousands of examples. And it’s a fact that AI is getting better.
But, anybody promising fully automatic AI solutions for accessibility is at least over-selling and we need to really dig into the fine print. Overlays, toolkits, plugins and similar solutions can sometimes help, but unfortunately not for everybody and not all the time.
“We didn’t have the time, so we bought a quick solution, so that we will have the time for real fixes soon” is a common thought and one of the most obvious indications of low accessibility maturity. There are no quick solutions, we need to get accessibility into processes. We need to learn about it. We need to know how to test it. And we often need help. Help from accessibility specialists that dedicated years to get to a level they can help others with accessibility.
And we would need to co-design with people with disabilities. But it seems that most of our organizations don’t recognize this even with clear evidence. AI has a lot of potential, but it needs to get the biases of our society towards disabilities out. It’s obvious that AI was trained on knowledge that is sometimes full of ableisms. Full of all kinds of biases that can be found in our society. And even if there were no biases, technology alone is not enough. Even if interfaces as we know them disappear we will still need accessibility.
Stay calm and improve
EAA really is the beginning of new, international, accessibility era. It will not happen quickly, it will take time, but the most important thing is that accessibility will be (drastically, I hope) improved. I strongly hope both authorities and organizations will recognize they have to learn a lot from people with disabilities.
I hope that people with disabilities will recognize the possibilities here as well. I hope EAA will also have positive effects on the job market. That organizations will recognize the possibilities that come from “shift left-er” – when products and services are co-designed with people with disabilities and not for them.
I may expect too much, but reading between the lines of EAA indicates this in a way. Not only more accessible products and services, but also empowering of people with disabilities, and if we go deep enough, co-creation of accessible and usable products and services.
For now, we need to stay calm and continue with improvements. Of our knowledge and understanding as a start and of our actions towards accessible products and services. Even if we are not in the scope of EAA.
