EAA Compliance Checklist for Websites: Everything You Need to Know Before the Deadline

If you run a website or webshop, or you manage digital projects for clients, the European Accessibility Act (EAA) is something you cannot afford to ignore. From June 28, 2025, many websites and digital services operating in the European Union must comply with strict accessibility standards, or risk fines, legal exposure, and loss of customers.

This post gives you a practical, step-by-step EAA compliance checklist to work through, whether you are a business owner preparing your own site or an agency making sure your clients are covered. It is also worth reading alongside European Accessibility Act 2025: What Website Owners Must Know to get the full legal context.

What Is the European Accessibility Act and Who Does It Apply To?

The European Accessibility Act is EU legislation that requires certain products and services, including websites, mobile apps, e-commerce platforms, and digital services, to be accessible to people with disabilities. It is based on WCAG (Web Content Accessibility Guidelines) 2.1 at Level AA, which sets the technical standard for what accessible digital content looks like.

The EAA applies to businesses operating within the EU that offer services to EU consumers. Private sector companies with more than 10 employees or an annual turnover exceeding 2 million euros are generally within scope, though the specific rules can vary by member state. Even if your business is headquartered outside the EU, if you are serving EU users, you likely need to be compliant.

For a deeper look at the technical requirements underpinning the EAA, the WCAG Compliance Guide is a solid starting point.

The EAA Compliance Checklist for Websites

This checklist is organized around the four core WCAG principles: Perceivable, Operable, Understandable, and Robust. Working through each section will help you identify gaps and prioritize what needs fixing.

1. Perceivable: Can Users See and Hear Your Content?

Content must be presented in ways that all users can perceive, regardless of ability.

• Alt text on all images: Every non-decorative image must have descriptive alternative text. Decorative images should have an empty alt attribute so screen readers skip them.
• Captions for video content: Any pre-recorded video with audio must include captions. Live video should also have captions wherever technically feasible.
• Audio descriptions: Pre-recorded video that contains visual-only information needs audio descriptions so users who cannot see the video still receive the full content.
• Colour is not the only means of conveying information: If you use colour to indicate an error, a required field, or any other status, there must be a secondary indicator such as an icon or a text label.
• Sufficient colour contrast: Text must meet a minimum contrast ratio of 4.5:1 against its background (3:1 for large text). This is one of the most commonly failed checks on real websites.
• Text resizing: Text must be resizable up to 200% without loss of content or functionality.
• No content that causes seizures: Nothing on the page should flash more than three times per second.

2. Operable: Can Users Navigate and Interact With Your Site?

All functionality must be operable via keyboard, not just a mouse.

• Full keyboard accessibility: Every interactive element, including menus, forms, buttons, and modals, must be reachable and usable by keyboard alone.
• No keyboard traps: Users must not become stuck inside a component and unable to move forward or back using only a keyboard.
• Skip navigation links: A skip-to-main-content link at the top of the page helps keyboard and screen reader users bypass repeated navigation on every page load.
• Descriptive page titles: Each page must have a unique, descriptive title tag that accurately reflects the page content.
• Visible focus indicators: When a user navigates via keyboard, the focused element must be clearly visible. Removing default focus outlines without replacing them is one of the most widespread accessibility mistakes.
• No time limits without user control: If a session or interaction has a time limit, users must be warned and given the ability to extend or disable it.
• Clear link text: Links should describe their destination. Generic text like “click here” or “read more” fails accessibility checks and also harms SEO.

3. Understandable: Is Your Content Clear and Predictable?

Users must be able to understand both the content and how the interface works.

• Language declared in HTML: The language of the page must be set in the HTML lang attribute. If sections of content are in a different language, that should also be marked up accordingly.
• Error identification and suggestions: Forms must clearly identify errors, describe what went wrong, and suggest how to fix it where possible.
• Labels on all form fields: Every input field must have a programmatically associated label. Placeholder text alone does not meet the requirement.
• No unexpected context changes: Navigation and components must behave predictably. Pages should not auto-redirect or change layout without user initiation.
• Consistent navigation: Navigation menus and components that appear across multiple pages must appear in the same order and location throughout the site.

4. Robust: Does Your Site Work Across Assistive Technologies?

Content must be compatible with current and future assistive technologies, including screen readers.

• Valid HTML: Pages should use valid, well-structured HTML. Markup errors can break how assistive technologies interpret the page.
• ARIA used correctly: ARIA (Accessible Rich Internet Applications) roles, states, and properties should only be used where native HTML cannot do the job. Misused ARIA often makes the experience worse, not better.
• Status messages announced: Dynamic updates, such as success or error messages, must be announced to screen reader users without requiring a page reload or focus shift.
• Name, role, and value exposed: All user interface components must expose their name, role, and current value to accessibility APIs so assistive technologies can interpret them correctly.

Beyond the Technical Checklist: What Else Compliance Requires

Meeting WCAG 2.1 AA is the core of EAA compliance, but there are a few additional requirements worth being aware of.

First, you need an accessibility statement published on your website. This statement should explain the level of conformance you have achieved, any known limitations, and provide contact details for users to report issues or request alternative formats.

Second, there must be a process for handling accessibility feedback. If a user contacts you because they cannot access part of your site, you need a clear mechanism to respond and address their concern within a reasonable timeframe.

If your business runs an online store, the requirements are equally relevant across your entire purchase journey. The E-commerce Accessibility Solutions page outlines the specific areas that webshops need to focus on, from product image descriptions through to accessible checkout flows.

A Note for Agencies and Developers

If you work at a digital agency or as a freelance developer, the EAA affects you because your clients’ compliance is partly your responsibility, especially if you are building or maintaining their sites. Building accessibility in from the start is far less costly than retrofitting it later. The Accessibility Solutions for Agencies & Developers page covers how Scanluma can integrate into your workflow to help you deliver compliant projects to every client.

Accessibility audits should be part of every launch checklist and every major update cycle. It is not a one-time task because content changes, plugins are updated, and new features are added, all of which can introduce new accessibility issues over time.

How to Test Your Website Against This Checklist

Manual testing is important, but it is time-consuming and requires expertise. Automated scanning tools can identify a significant portion of WCAG failures quickly and consistently, making them a practical first step for any compliance audit.

Scanluma automatically scans your website for accessibility issues, maps them to specific WCAG criteria, and gives you a clear, prioritized list of what needs fixing. Rather than working through hundreds of pages manually, you get a structured report that shows where you stand and what to do next.

For a broader look at what can be tested automatically versus what needs human review, Website Accessibility Checker: How to Test Your Site in 5 Minutes walks through the process in straightforward terms.

After running an automated scan, it is worth doing some manual checks with a keyboard and a screen reader, particularly for interactive elements like forms and navigation. The two approaches together give you the most complete picture of your site’s accessibility.

What Happens If You Are Not Compliant?

Each EU member state is responsible for enforcing the EAA within its own jurisdiction, and enforcement mechanisms vary by country. Generally, authorities have the power to investigate complaints, require remediation, and issue fines for non-compliance.

The financial penalties vary, but the reputational damage of being publicly identified as inaccessible, combined with the risk of exclusion claims from users with disabilities, adds significant non-financial risk on top of any fines.

For a broader view of how accessibility regulations are evolving globally, including in the United States and elsewhere, Accessibility Regulations Around the World: A Quick Overview provides useful context.

Start Your Compliance Review Today

The June 2025 deadline is here, which means there is no more runway for delay. Whether you are a website owner working through this checklist yourself, or an agency preparing to audit client sites, getting a clear picture of where you stand is the most important first step.

Scanluma is built for exactly this purpose. It scans your site automatically, surfaces accessibility issues with WCAG references attached, and helps you work through fixes in a systematic way. Explore the accessibility solutions available for your type of business and see how Scanluma fits into your compliance workflow.

Create your free account and run your first scan today. You may find more issues than you expect, but you will definitely be glad you started when you did.