EAA Year One: What UK Businesses Should Know
The European Accessibility Act (EAA) came into force on 28 June 2025. One year in, we have enough data to move past speculation and look at what is actually happening with enforcement, and what it means for UK businesses.
The headline: no fines have been issued yet. But enforcement is building faster than most people expected.
The enforcement landscape so far
Sweden's enforcement authority, the Swedish Agency for Accessible Media, has opened 28 formal investigations into digital services since June 2025. These span e-commerce, banking, and travel booking platforms. No penalties have been issued at the time of writing, but several investigations are reportedly close to concluding.
France moved faster on individual enforcement. The first court proceedings under the transposed French legislation were filed in March 2026 by disability rights organisations targeting two major retail platforms. The outcomes are pending but have already prompted several French retailers to commission emergency audits.
Norway, which adopted EAA-aligned legislation through the EEA Agreement, has taken perhaps the most aggressive stance. Their enforcement model includes daily penalty payments for non-compliance, accruing from the date of a formal finding. Three companies have received formal warnings.
Germany, Italy, and the Netherlands have designated enforcement bodies but have not yet opened public investigations. The expectation across the industry is that enforcement in these markets will accelerate in 2027 as market surveillance programmes mature.
Why UK businesses should pay attention
The UK is not in the EU. The EAA does not directly apply to UK-registered businesses operating solely within the UK. But there is an important caveat that many businesses are overlooking.
If your business sells digital products or services to consumers in EU member states, the EAA applies to those products and services. An e-commerce site based in Manchester that ships to France, Germany, or any EU country must comply with the EAA for those transactions. A SaaS platform with EU subscribers must meet the requirements. A travel booking site accessible to EU consumers falls within scope.
The EAA covers: e-commerce services, banking and financial services, e-books and e-readers, transport ticketing platforms, and telecommunications services. If your digital service touches EU consumers in any of these categories, you have compliance obligations regardless of where your company is registered.
The UK's own obligations
Separately from the EAA, UK businesses have obligations under the Equality Act 2010. The Act requires service providers to make reasonable adjustments for disabled people, and courts have consistently interpreted websites and apps as services.
The Royal National Institute of Blind People (RNIB) and other disability organisations have been increasingly active in pursuing complaints. While the UK has not seen the volume of litigation common in the US, the trend is upward.
The Equality and Human Rights Commission (EHRC) published updated guidance in 2025 making explicit that digital services must be accessible to disabled users. While this guidance is not legislation, it signals the direction of regulatory expectation.
For public sector organisations, the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 already mandate WCAG 2.1 AA compliance. Non-compliance carries reputational risk and potential enforcement action from the Government Digital Service (GDS) monitoring programme.
The standard both frameworks point to
Both the EAA and the UK Equality Act point to the same technical standard: WCAG 2.2 (or at minimum 2.1) at Level AA. The EAA references the harmonised European standard EN 301 549, which itself maps to WCAG.
This is good news if you are trying to comply with both. Meeting WCAG 2.2 AA gets you most of the way for both frameworks. You do not need to implement two different sets of requirements.
Practical steps for UK businesses
Scan your site. Run an automated accessibility scan with Lumi to establish a baseline. This takes minutes and identifies the structural issues that are cheapest to fix: missing alt text, contrast failures, broken ARIA, heading hierarchy problems.
Fix critical issues. Prioritise anything that blocks users entirely: keyboard traps, missing form labels, inaccessible navigation. These are the issues most likely to trigger complaints and most damaging to user experience.
Publish an accessibility statement. The EAA requires a publicly available accessibility statement for digital services. Even for UK-only businesses, publishing a statement demonstrates good faith and sets expectations with users. Include your current conformance level, known issues, and a way for users to report barriers.
Commission a manual audit. Automated scanning catches 30-40% of issues. A manual audit by a trained auditor testing with real assistive technology finds the rest. Livana delivers audit findings as tickets directly in Lumi, so your development team can track and resolve them alongside their existing workflow.
Monitor continuously. Accessibility is not a one-time project. Code changes, content updates, and third-party widget updates can introduce new issues at any time. Use Lumi for ongoing monitoring to catch regressions before your users do.
Where this is heading
Enforcement under the EAA will intensify. The UK's own regulatory environment is tightening. The commercial case is already settled: the Click-Away Pound report found that 69% of disabled consumers abandon inaccessible websites, representing GBP 17.1 billion in annual lost spending.
The question is not whether your business needs to invest in accessibility. It is whether you do it proactively, on your own terms, or reactively, in response to a complaint or legal action.
Year one of the EAA has been a warning period. Year two is unlikely to be as gentle.
