The European Accessibility Act (EAA) from 2025: what website owners really need to know

Valdonė Butrimaitė
3 days ago
3 min read

The European Accessibility Act (EAA) will come into force in the European Union on 28 June 2025. In the public domain, this change is often presented as if it affects all websites. This is not accurate.

This article explains who the EAA actually applies to, who it doesn't, when an Accessibility Statement is needed, and where the legal risks lie .

What is the European Accessibility Act (EAA)?

The EEA is an EU directive aimed at ensuring that certain services and products are accessible to people with disabilities throughout the European Union according to uniform criteria.

Important:

The directive is not universal for all websites
It applies to specific categories of services and products

Who does the EEA apply to?

The EEA applies to businesses and organisations that provide the following services or products to end-users in the EU:

e-commerce (e-shops)
banking and financial services
insurance services
transport services (tickets, information systems)
telecommunications services
e-books and e-readers
self-service terminals, ticket machines
some mobile apps
public digital services

In such cases , the website or app becomes part of the service and is therefore subject to accessibility requirements.

Who is the EEA not usually applicable to?

Often missing :

simple representative websites
service pages without e-commerce
personal projects and blogs
small businesses that do not provide regulated services

The mere fact that a website exists does not mean that it is automatically subject to the EEA.

The issue of micro-enterprises and other exemptions

The directive provides for several important exceptions:

Microenterprises

Micro-enterprises (up to 10 employees and up to EUR 2 million in turnover) may be exempted from some requirements , however:

it depends on national implementation
not for all activities and not always

Unreasonable burden

If ensuring accessibility:

would result in disproportionate costs
would be technically impossible
would threaten the viability of the business

then an exception may be made, but it must be justified and documented .

WCAG and legal reality

Accessibility requirements are based on the WCAG 2.1 AA guidelines.

It is important to understand:

WCAG is not a law
it is a technical standard on which legislation is based
not every WCAG point is automatically mandatory for every website

The scope of the requirements depends on:

nature of the service
risk
principle of proportionality

What is an Accessibility Statement?

Accessibility Statement is a public statement that states:

whether and to what extent the service meets accessibility requirements
which parts are inaccessible
How can a user submit comments or complaints?

When is it needed?

when the service falls within the scope of the EEA
when participating in public procurement
when an organization declares compliance with accessibility requirements

When is it dangerous?

If the statement declares compliance that does not actually exist. In this case, the statement becomes a document of liability, not protection .

Fines in Lithuania

According to the Law of the Republic of Lithuania on Accessibility Requirements for Products and Services, from June 28, 2025, administrative fines may be applied, the amount of which depends on the nature, scale and duration of the violation.

Important:

fines apply only to entities to which the requirements apply
not for minor shortcomings, but for systematic or obvious disregard for requirements

What is a website owner to do?

Assess whether the activity falls within the scope of the EEA
If so, perform a basic accessibility audit
Do not undertake more than is actually implemented
An Accessibility Statement should only be prepared when it is justified.
Be guided by the principle of proportionality, not panic

Key conclusion

The European Accessibility Act is not a universal requirement for all websites . It is a targeted legal regulation for specific services.

An accessibility statement is not a formality or an SEO trick. It is a declaration of responsibility that must reflect the real situation.

This article is for informational purposes only and is not intended to be individual legal advice. The application of accessibility requirements depends on the nature of the specific activity and service.