Preparing for the European Accessibility Act: Lessons from the trenches

The European Accessibility Act is coming into force in Europe on 28th June 2025, requiring products and services with digital interfaces to meet accessibility standards.

As a Consultant, I was brought in to help a client ensure compliance with these new regulations. Here's what I learnt through this process.

What is the European Accessibility Act?

First proposed in 2019, the European Accessibility Act aims to harmonise accessibility requirements across EU member states. From June 2025 onward, any product or service with a digital interface (websites, mobile apps, etc.) must meet Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards.

There are some exceptions for small companies (under 10 employees and less than €10 million in revenue) until 2030. For the rest of us, potential penalties for non-compliance range from €30,000 to €1 million, depending on the country. However, we should look at this as an opportunity to make our products available to more people. 

For my client, a company with operations across the UK, Ireland, France, Italy, and Spain, compliance was crucial, as much of their software was shared across regions.

Assessing the current state

The first step was understanding where the client currently stood on accessibility. We conducted website/app audits using a WCAG checklist and accessibility web tools to identify gaps against the standards.

The WCAG is based on 13 guidelines covering areas like text alternatives for images, contrast of images, general page layout, keyboard accessibility and more.

A comprehensive list of bugs/issues and missing requirements was drawn up, but rather than log every issue in their ticketing system, we brought together the developers, designers, testers and product owners for a collaborative review, then prioritised and grouped the findings into actionable areas and various new accessibility user stories. This was to help speed up fixes and implement these solutions into a live release.
 
As for the longer-term outlook, we developed a 3-phase plan to achieve and sustain WCAG 2.1 AA overall compliance:

1. Targeted training - on accessibility principles/guidelines for different roles like UX, developer and testing.

2. Pilot implementation - working with a single product squad, embedding accessibility into design/dev testing processes.

3. Company-wide rollout - making accessibility standard practice across all products.

This included adopting automated testing tools, IDE (integrated development environment) plug-ins for developers, and Figma plug-ins for designers to catch accessibility issues early. We also adjusted our 'Definition of Done' criteria to include WCAG compliance.

The importance of empathy

However, the biggest impact came from creating an 'Empathy Lab' to build awareness of different disabilities. We set up scenarios with arthritis simulation gloves, hand weights, screen filters, and more to let people experience common accessibility hurdles first-hand.

We also connected with local accessibility advocates and communities, reaching out and hiring a specialist Consultant who is visually impaired and came monthly to test iterations and share feedback to identify gaps we wouldn't otherwise notice.

These direct experiences were invaluable for fostering empathy and an understanding of why accessibility really matters beyond just checking boxes.

While we made great strides, the journey is enduring

• Ensuring an optimal accessible experience requires continuous feedback from users experiencing various accessibility needs. 
• Exploring metrics like: At what point is our digital experience 'good enough' to attract more users away from call centres?

Interested in learning more? Michael Kennedy recently hosted a webinar on 'Testing for Accessibility and the Euro Accessibility Act', which you can access here.

To find out how AND Digital can help your organisation prepare for the European Accessibility Act, get in touch today.