The deadline has passed
The European Accessibility Act (EAA) came into force on 28 June 2025. If your UK business sells to EU consumers and you're not compliant, you're now at risk of enforcement action.
Still not compliant? Here's what to do now
1. Act immediately
Every day of non-compliance increases your risk. EU member states can now:
- Issue fines (up to €3 million in some countries)
- Order removal of your products/services from EU markets
- Face legal action from consumers
2. Implement a rapid response plan
Week 1: Emergency assessment
- Identify which products/services are non-compliant
- Assess your highest-risk areas (where you have most EU customers)
- Consider temporarily limiting EU access if severely non-compliant
Week 2-4: Quick wins
- Fix critical accessibility barriers that completely block access
- Add accessibility statements acknowledging current limitations
- Implement basic fixes: alt text, heading structure, keyboard navigation
Month 2-3: Substantial improvements
- Address WCAG 2.1 Level AA requirements systematically
- Focus on your highest-traffic areas first
- Document all improvements for potential enforcement queries
3. Prepare for potential enforcement
Document everything:
- Your remediation timeline and progress
- Evidence of good faith efforts
- Any technical or resource constraints
- Communications about your improvement plan
Be proactive:
- Contact relevant authorities in countries where you trade
- Demonstrate commitment to compliance
- Consider voluntary disclosure of your remediation plan
If you're already facing enforcement
- Don't ignore it - Respond promptly to any regulatory contact
- Get legal advice - Especially for country-specific requirements
- Show progress - Demonstrate active steps toward compliance
- Negotiate timelines - Authorities may accept phased compliance plans
The "disproportionate burden" defence
You might claim exemption if compliance would:
- Fundamentally alter your product/service nature
- Impose disproportionate costs relative to your size
But you must:
- Document this assessment thoroughly
- Notify relevant authorities
- Note: "We didn't prioritise it" isn't a valid defence
Why some businesses might be OK (for now)
- “Micro enterprises”: Under 10 employees AND under €2m turnover are exempt
- Hardware products: Have until 2030 for physical products
- Limited enforcement: Some countries are still establishing enforcement procedures
But don't rely on enforcement delays - they're temporary.
Moving forward: Compliance is non-negotiable
Immediate priorities:
- Stop the bleeding: Prevent further non-compliance in new features
- Audit thoroughly: Know exactly where you stand
- Create a roadmap: Show authorities you're taking this seriously
- Train your teams: Ensure future work is accessible
- Monitor enforcement: Stay informed about actions in your markets
Long-term success:
- Build accessibility into your development process
- Regular testing with users with disabilities
- Maintain compliance documentation
- Consider accessibility a core business requirement
The business reality
Yes, you're late. But the worst response is doing nothing. Authorities and courts are more likely to be lenient with businesses showing genuine effort to comply.
The EAA isn't going away. Neither are the 135 million EU citizens with disabilities who deserve equal access to your products and services.
Take action today
Every day matters now. Start with:
- An emergency accessibility audit
- Legal advice on your exposure
- A clear, time-bound remediation plan
- Visible progress on the most critical issues
Need urgent help with EAA compliance? We specialise in rapid accessibility remediation. Contact us for emergency support and practical solutions to get your business compliant.