EU Accessibility Directive Compliance

The EU's digital accessibility framework consists of two key directives that together cover both public and private sector organizations:

• Web Accessibility Directive (WAD) — Directive 2016/2102: Requires public sector bodies (governments, public agencies, universities, healthcare institutions) to make their websites and mobile apps accessible. In force since 2018. Requires WCAG 2.1 AA via EN 301 549
• European Accessibility Act (EAA) — Directive 2019/882: Extends accessibility requirements to private sector products and services in specific categories (e-commerce, banking, transport, telecom, e-books). Enforcement began June 28, 2025. Also requires WCAG 2.1 AA via EN 301 549

Both directives converge on the same technical standard: WCAG 2.1 Level AA through EN 301 549. This means the same CompliScan scan addresses compliance requirements under both directives.

If you operate a public sector website, the WAD has required compliance since 2018-2020. If you offer private sector digital services in covered sectors, the EAA now requires compliance as of June 2025.

The Web Accessibility Directive established the foundation for digital accessibility regulation in the EU:

• Scope: All public sector body websites and mobile applications, with limited exceptions for broadcasters, live streaming, and archived content published before September 2018
• Standard: WCAG 2.1 AA conformance, as specified in EN 301 549
• Accessibility statement: Public sector websites must publish an accessibility statement detailing compliance status, known issues, contact information for accessibility feedback, and the enforcement procedure
• Monitoring: Each member state designates a monitoring body that regularly audits public sector websites using a combination of automated and manual testing methods
• Compliance reporting: Member states report to the European Commission every three years on monitoring results and enforcement actions

Monitoring results across the EU consistently show that 40-60% of public sector websites fail to fully meet WCAG 2.1 AA requirements, indicating significant ongoing compliance challenges.

The European Accessibility Act significantly expands the EU's accessibility requirements into the private sector. Here is what private businesses need to know:

• Covered services: E-commerce, consumer banking, transport (air, rail, bus, waterway, urban), electronic communications, and access to audiovisual media and e-books
• Covered products: Computers and operating systems, self-service terminals (ATMs, ticketing, check-in), consumer equipment for electronic communications, e-readers, and routers
• Technical standard: EN 301 549 / WCAG 2.1 AA for digital interfaces
• Microenterprise exemption: Service providers with fewer than 10 employees and under EUR 2 million turnover are exempt from service requirements. No exemption for product manufacturers of any size
• Fundamental alteration / disproportionate burden: Businesses can claim an exemption if compliance would fundamentally alter the product/service or impose a disproportionate burden, but must document and justify this claim

The EAA does not require an accessibility statement like the WAD does, but documenting your compliance efforts is a practical necessity for responding to enforcement inquiries.

Since both the WAD and EAA require WCAG 2.1 AA, a single CompliScan scan covers the technical requirements for both directives:

• Public sector organizations (WAD): Use CompliScan to prepare for national monitoring audits. Identify violations before monitoring bodies do. Shield Pro ($149/mo) provides daily scans and PDF reports that align with accessibility statement requirements
• Private sector businesses (EAA): Establish your compliance baseline with a free scan. Use results to prioritize remediation of WCAG 2.1 AA violations. Set up ongoing monitoring with Shield ($49/mo) to maintain compliance
• Organizations covered by both: Public sector bodies that also provide services covered by the EAA (e.g., public transport booking systems) face dual obligations. CompliScan's single scan addresses both
• Cross-EU operations: The Agency plan ($299/mo) covers up to 50 sites — essential for organizations operating across multiple EU member states with different enforcement regimes

Remember: automated scanning catches 30-40% of WCAG issues. Combine CompliScan results with manual testing for comprehensive compliance under either directive.