Is Your Website EAA Compliant? Six Web Accessibility Questions To Ask

Forbes

17 hours ago

Ran Ronen, Founder and CEO of Equally AI , the solution that helps teams create, test and ship better accessibility from start to finish. getty
Digital leaders across industries are racing to meet the European Accessibility Act (EAA) requirements before the June 2025 deadline. Many organizations rely on basic web content accessibility guidelines (WCAG) audits and accessibility plug-ins, and with that, assume their websites are "compliant enough." In reality, surface-level fixes may create the appearance of compliance but mask critical gaps that expose your business to serious non-compliance risks.
Building on my previous articles about preparing for the EAA, including a checklist to meet EAA requirements, I would like to dive deeper into six strategic questions business leaders can ask to uncover hidden compliance gaps and build sustainable accessibility practices beyond the June 2025 deadline.
If you're offering digital products or services in the EU, chances are you're covered. Even if your company is outside the EU, if EU consumers use your product or service, the EAA applies to you. Only true microenterprises (with fewer than 10 employees and under €2 million in annual turnover) may qualify for exemption, but even then, regulators expect documented justification, and I'd still strongly recommend voluntary compliance.
Make sure to map out your products and services against the EAA's scope and requirements and understand your obligations. If you're claiming an exemption, back it with documentation that clearly outlines your eligibility, cost-benefit analysis and evidence that alternatives were explored. Also, ensure third-party vendors (e.g., digital agencies) provide accessibility-compliant components, backed by VPATs, to avoid liability. 2. What are the penalties for non-compliance with the EAA?
Fines for EAA violations vary across countries, with amounts spanning from €5,000 up to more than €500,000, influenced by factors such as the seriousness of the breach and the scale of the business and how long the issue remains unresolved. Countries like Ireland may even impose both fines and jail time of up to 18 months for serious, ongoing non-compliance.
But fines are only part of the penalties. Non-compliance can also trigger other penalties like market suspensions and public disclosure by regulations, which can disrupt operations and revenue streams, leading to long-term loss of market share and damaged customer trust.
To mitigate these risks, I'd advise business leaders to prioritize compliance for high-risk assets like websites, apps and digital customer touchpoints. Ensure you keep full documentation of your accessibility efforts, even partial ones, to demonstrate good faith if audited. 3. How will the EAA impact small businesses?
The EAA presents a dilemma for small businesses. While true microenterprises may be exempt, most small companies are expected to comply, and accessibility audits, remediation and staff training all demand serious investment. But the opportunity is equally real. Over 101 million people with disabilities across Europe remain underserved, and EAA compliance can open up new markets and strengthen your brand.
My advice? Stay lean, but be strategic. Use free or low-cost accessibility audit tools like WAVE or Lighthouse to catch high-priority issues early, but pair them with expert-led manual audits and build accessibility into your core product development cycles to stay scalable. Partnering with industry peers or accessibility consultants can also stretch your resources further and reduce long-term risk. 4. Have we localized our compliance for each EU market we serve?
While the EAA sets a unified standard, enforcement varies by member state, with each country setting its own timelines, documentation formats, complaint-handling processes and penalties. A compliance strategy that passes in one country might fall short in another, so if your business operates in multiple EU markets, you must account for these local variations to avoid compliance gaps.
My recommendation: Assign regional compliance leads or cross-functional teams to track country-specific updates, adapt enforcement expectations into your operating procedures and ensure continuous alignment across jurisdictions. If your team lacks in-house oversight, consider partnering with legal or compliance teams who actively monitor these changes to ensure you're covering all the bases. 5. Do we have a clear role for who owns accessibility in our organization?
In many organizations, accessibility responsibilities are distributed across multiple teams without clear ownership. Product leads may focus on features, legal on policies, designers on user interface (UI) patterns, etc. Under the EAA, accessibility spans all of these areas, and without a defined owner overseeing how they connect, it is almost inevitable that there will be compliance gaps.
Along with the earlier-mentioned regional compliance leads or cross-functional teams, you also want to assign someone with decision-making authority to be accountable for aligning accessibility across teams and enforcing standards that tie to EN 301 549.
That person (or team) should control priorities, sign off on risk and ensure decisions are followed through. If this structure doesn't already exist in your organization, your compliance efforts will be fragmented, putting your business at higher risk. 6. Are we prepared to maintain compliance post-June 2025?
Many businesses are racing toward June 2025 with short-term checklists, but few are building systems to stay compliant after that. Accessibility requirements won't stop evolving once the deadline passes. New features, team turnover and tech stack changes can all break compliance if there's no plan to maintain accessibility over time.
Make sure to build accessibility into your product and content teams' daily operations. That includes setting clear review cycles (my prescribed rule of thumb is monthly for new releases, quarterly for regressions and annually for full audits), using version-controlled design systems, and budgeting for ongoing accessibility updates. Conclusion
The EAA deadline is now closer than ever, and organizations must understand that beyond demanding compliance, the law will fundamentally restructure what it means to operate in the European digital economy. As such, if your business treats accessibility as a late-stage checklist, you will always be reacting—patching gaps under pressure, losing ground to faster competitors and exposing yourself to regulatory risk you didn't plan for.
The smarter path is to operationalize accessibility now: Embed it into product, engineering, customer experience and legal, and assign real accountability at the leadership level. The businesses that start asking hard questions today and build systems that hold up after 2025 won't just avoid penalties. They'll be the ones that define market leadership and accountability in the next phase of digital growth.
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