Introduction
Digital accessibility is no longer an optional consideration – it is an essential requirement for businesses and organisations aiming to serve all clients and users. There are over 100 million people in the European Union living with some form of disability, roughly one in four adults. Ensuring websites, applications, and digital documents are accessible to people with disabilities is not just a legal obligation but also a business imperative. Inaccessible digital content can exclude a substantial segment of the population, leading to lost clients and reputational damage.
Moreover, studies have continually shown that most websites remain far from accessible. In 2024, an analysis of the top one million websites found that 95%had detectable Web Content Accessibility Guidelines (WCAG) failures. Common problems included low-contrast text on 81% of sites, missing alternative text for images on over 54%, and many other issues – improvements have been only marginal over the past five years. This highlights the scale of work still needed for compliance and inclusion.
Against this backdrop, the European Accessibility Act (EAA) has emerged as a key piece of legislation. The EAA is an EU directive (Directive (EU) 2019/882) adopted in 2019 to harmonise accessibility requirements across member states and ensure equal access to products and services for people with disabilities. It builds on the principle that accessible design benefits everyone and removes fragmentation in accessibility laws across Europe. For professional services firms – such as legal, accounting, consulting, and other B2B service providers – understanding and preparing for the EAA is critical. Although many such firms previously had no binding digital accessibility rules (past EU accessibility laws applied mainly to public sector bodies), the new Act extends stringent requirements to the private sector for the first time. This article provides an overview of the EAA and what compliance entails for professional services organisations.
What Is the European Accessibility Act?
The European Accessibility Act is a broad EU law that sets common accessibility standards for a range of products and services. It aims to remove barriers in the internal market by requiring that key products and digital services are made accessible to people with disabilities across all EU countries. By establishing one unified set of rules, the Act makes it easier for companies to trade accessible products and services throughout the EU while ensuring a minimum level of accessibility for consumers. Member States have been transposing the directive into national law, and the EAA’s requirements will start applying on 28 June 2025. From that date, any covered product or service sold or provided in the EU must meet the specified accessibility criteria.
Scope – Products and Services Covered: The EAA focuses on areas deemed most important for people with disabilities and where inconsistent requirements previously existed. It covers a wide array of everyday products and digital services, including: personal computers and operating systems, smartphones and tablets, self-service ATMs, ticketing and check-in kiosks, television and media equipment related to digital TV services, telephony and electronic communications services, consumer banking and online banking services, e-books and e-readers, and e-commerce websites and apps (for retail and services). Transport services’ digital aspects are also in scope – for example, websites or electronic ticketing for air, bus, rail, and water transport must be accessible. In short, many mainstream technologies and services – from online shops to streaming media platforms – are required to conform to the Act’s accessibility standards. Notably, these rules apply to digital content (websites, mobile applications, electronic documents) as well as the hardware devices and terminals involved in delivering the service.
Who Must Comply: The EAA has a broad reach. It applies to any company (public or private) that provides the above products or services to consumers in the EU regardless of where the company is based. In other words, even a professional services firm outside Europe must comply if it offers in-scope services to EU customers. Manufacturers, importers, and distributors are all responsible for ensuring that only accessible products and services (within the Act’s scope) are placed on the EU market. There are a few limited exemptions – for example, micro-enterprises (those with fewer than 10 employees and under €2 million annual turnover) are exempt from the EAA’s requirements for services. Additionally, purely business-to-business services (not reaching end consumers) are generally not covered by this law. The vast majority of larger organisations, however, including most professional service providers operating internationally, will be expected to meet the new standards.
Impact on Professional Services Firms
For professional services firms, the European Accessibility Act represents a significant shift in regulatory expectations. Until now, accessibility obligations in the EU were largely confined to the public sector (such as government websites under the prior Web Accessibility Directive). Starting in June 2025, private-sector firms must also ensure their digital platforms are accessible if they fall under the Act’s scope. This could include a law firm’s client portals and informational websites, an accounting firm’s online tools for customers, or a consulting firm’s downloadable reports and mobile apps. Even if a firm predominantly serves business clients, accessibility cannot be ignored – many professional services websites host resources and publications open to the public, and staff recruitment pages and other services interface with individuals. An inaccessible website or service in these contexts can pose legal risks under the EAA as well as undermine the firm’s inclusivity and reach.
There is also a strong business case for accessibility in professional services. Clients and talent increasingly expect inclusive practices as part of corporate social responsibility. Moreover, accessible design often leads to better overall user experience for everyone. Cleaner, more semantically structured websites tend to perform better: for instance, search engines can index them more effectively, which improves SEO rankings, and users (with or without disabilities) find them easier to navigate. Faster-loading, well-structured content and captioned videos benefit all viewers. In fact, an accessible website typically keeps visitors on the site longer and encourages broader engagement. Professional firms that invest in accessibility can enhance their brand reputation, reach a wider audience (including the millions of Europeans with disabilities), and differentiate themselves from less inclusive competitors. On the other hand, failing to address accessibility can carry reputational costs – appearing exclusive or outdated – even before any legal penalties come into play.
Compliance Requirements and Standards
What does it mean to comply with the EAA’s accessibility requirements? The Act itself defines functional accessibility outcomes (for example, that users must be able to perceive, operate, understand, and interact with digital content). In practical terms, this will be assessed largely through conformity with established technical standards for accessibility. The most widely used standard for web and digital content accessibility is the Web Content Accessibility Guidelines (WCAG), developed by the World Wide Web Consortium (W3C). The WCAG 2.1 Level AA criteria have effectively become the benchmark for accessibility laws in many jurisdictions, and the EAA is no exception – even if the law does not name WCAG explicitly, its requirements for websites and mobile apps align closely with WCAG 2.1 AA. In other words, when the law says “make your digital services accessible,” it essentially means meeting the WCAG 2.1 AA success criteria as the minimum.
For professional services firms, complying with WCAG 2.1 AA involves a range of considerations in design and development. All website visitors should be able to perceive the content (e.g. with text alternatives for images, captions for audio/video, sufficient colour contrast for text), operate the interface (e.g. fully usable via keyboard only, with clear focus indicators and no keyboard traps), understand the content and navigation (e.g. consistent structure, descriptive link texts, readable language), and robustly interact using assistive technologies (ensuring compatibility with screen readers and other aids). Documents provided in PDF or other formats should be made accessible (tags, reading order, etc.), and any mobile apps should follow similar principles. It is advisable for firms to conduct an accessibility audit of their digital properties to identify any WCAG violations. Common issues like those highlighted in industry reports – missing form labels, unlabeled buttons, or videos without transcripts – need to be addressed. Remediation may require collaboration between web developers, UX designers, and content authors to fix both code-level barriers and content issues.
Importantly, accessibility compliance is not a one-time project but an ongoing commitment. The Act’s standards may evolve (for instance, WCAG 2.2 has been published with additional criteria, and future versions will continue to improve guidance). Professional services organisations should put in place internal policies or guidelines for accessibility in all new digital content and updates. Incorporating accessibility checks into the development lifecycle – and training staff on inclusive design practices – will help maintain compliance long term. Many firms engage accessibility experts or use automated testing tools (along with manual testing by users with disabilities) to ensure they meet the requirements and to keep up with best practices.
Enforcement and Consequences of Non-Compliance
The European Accessibility Act is backed by enforcement mechanisms that give it real teeth. EU Member States are required to establish “effective, proportionate and dissuasive” sanctions for companies that fail to meet the accessibility requirements. While specific penalties will be defined in each country’s legislation, organisations can expect significant repercussions for non-compliance. Regulatory authorities will have the power to levy substantial fines for accessibility violations, especially if a company shows negligence or fails to remediate issues. In serious cases, enforcement measures could go as far as withdrawing non-compliant products or services from the market or banning their sale until they are fixed. In other words, if a firm’s software, website, or device does not conform to the EAA’s criteria, it might literally be barred from being offered to EU customers. This kind of action, while a last resort, underscores how seriously accessibility will be taken – akin to how unsafe electrical products can be pulled from shelves, inaccessible digital products could face removal from app stores or websites in the EU.
Beyond official regulators, there is also the possibility of legal challenges from consumers or advocacy groups. In many European countries, consumer protection organisations or equality bodies can take legal action on behalf of individuals with disabilities who are unable to use a service. Competitors might also raise accessibility as an issue if they believe a firm’s non-compliance gives an unfair advantage or harms consumers. All of this means that professional services firms should treat accessibility compliance with the same diligence as data protection or other regulatory requirements – it will be closely watched. Compliance violations will not only incur financial penalties but can also trigger serious reputational damage. In an age of social media, a law firm or consultancy being called out for an inaccessible website could quickly find itself in negative headlines.
We have already seen early examples of enforcement that signal what is to come. In 2024, Spain’s National Court upheld a €90,000 fine against a major airline for having a website that did not meet accessibility requirements. That case – under existing national disability law – demonstrates that authorities are willing to penalise digital inaccessibility. As the EAA comes into force, similar enforcement can be expected across the EU for non-compliant services, with penalties potentially even higher for large companies. Professional services firms, despite not being consumer retailers, are not immune: if, for instance, an accounting firm’s tax filing portal is unusable by a client with a visual impairment, the firm could face complaints and sanctions under the new regime.
Preparing for Compliance
With the June 2025 deadline fast approaching, professional services organisations should act promptly to ensure compliance. By now, firms should familiarize themselves with the EAA’s specific requirements and assess which parts of their operations are in scope. A thorough accessibility audit of customer-facing digital assets is a crucial first step. This includes corporate websites, client login areas, mobile apps, PDFs and reports provided to clients, and even multimedia content. Any issues identified – whether missing alt text on images, PDF documents that are not screen-reader friendly, or an online form that cannot be navigated without a mouse – need to be remedied in line with WCAG guidelines. It’s wise to prioritize fixes that address the most common barriers (like those six problem areas found on the majority of websites) since resolving those will dramatically improve overall accessibility.
Next, firms should update their development and content processes to integrate accessibility by design. Ensure that new websites or features are built to WCAG standards from the start, rather than trying to bolt on fixes later. Providing training for web developers, content creators, and IT staff on accessibility best practices will build internal capacity to maintain compliance. Many organisations appoint an accessibility champion or task force to coordinate these efforts, often drawing on expertise from external consultants or agencies when needed. Additionally, it’s prudent to draft an accessibility statement for your website (as required by some laws) that transparently communicates your commitment, the standards you aim to meet, and contact information for users to report difficulties. This not only is good practice but also shows regulators a posture of accountability.
Finally, management should recognise accessibility compliance as part of the firm’s risk management and ESG (Environmental, Social, and Governance) profile. Just as data privacy or financial compliance is discussed at the leadership level, digital accessibility should be on the agenda. The costs of retrofitting websites or facing legal action far outweigh the investment needed now to build accessibility in. By treating the European Accessibility Act as an opportunity – to improve user experience, demonstrate inclusivity, and innovate services for a wider audience – professional services firms can turn compliance into a strategic advantage. In summary, the EAA is a wake-up call: accessible design must become standard practice. Firms that take action now will not only avoid penalties come 2025, but will position themselves as forward-thinking, socially responsible leaders in their field.
References
- Council of the European Union. Disability in the EU: facts and figures. (Infographic, 2023). Available at: Consilium.europa.eu (Accessed May 2025).
- WebAIM. The WebAIM Million – 2024 Report on the accessibility of the top 1,000,000 home pages. (Feb 2024). Available at: WebAIM.org.
- Netherlands Enterprise Agency (RVO). European Accessibility Act for products and services. (Business.gov.nl, Effective date 28 June 2025). Available at: business.gov.nl.
- Centre for Excellence in Universal Design (Ireland). European Accessibility Act. (NDA Ireland, 2023). Available at: UniversalDesign.ie.
- Osborne Clarke. The EU Accessibility Act – Two Months to Go! (Insight article, 6 May 2025). Available at: osborneclarke.com.
- AccessibleEU News (European Commission). Vueling Airlines fined for failing to make their website accessible.(Servimedia, 26 April 2024). Available at: accessible-eu-centre.ec.europa.eu.
- Lanier, S. Navigating the Future: The Evolution of the European Accessibility Act. (Siteimprove Blog, 16 May 2025). Available at: siteimprove.com.