#1 Step-by-Step Guide to EAA 2025 Compliance (WCAG 2.1 AA Made Simple)

2–5 min read

The European Accessibility Act (EAA) has been in force since 28 June 2025. If you serve EU users, you’re already expected to meet accessibility requirements aligned with EN 301 549, which references WCAG 2.1 Level AA for web and mobile content. Start with an audit, fix critical issues, verify manually, document, and monitor.

1. Confirm You’re In Scope

2. Map the Law → Technical Standard

3. Run a Baseline Audit (Automated)

4. Fix Critical WCAG 2.1 AA Issues

5. Verify Manually (You Can’t Skip This)

6. Ship an Accessibility Statement & Feedback Channel

7. Build Accessibility into UX & Performance

8. Train the Team & Set Governance

9. Monitor Continuously (Compliance Is Ongoing)


Step 1: Confirm You’re In Scope

Who’s covered? E-commerce platforms, banking and financial services, telecoms, transport/ticketing, audiovisual media services, and more—plus a broad set of ICT products. If you provide digital services to EU consumers (even from outside the EU), you should assume coverage.


Micro-enterprise note: Some service-related obligations may be relaxed for micro-enterprises (<10 employees and ≤€2M turnover). Check your national implementation—the exemption isn’t universal for everything.


Step 2: Map the Legal → Technical Standard

  • Law: EAA (Directive (EU) 2019/882) sets accessibility requirements and is enforced by Member States.
  • Standard: EN 301 549 is the harmonized standard used to demonstrate conformance.
  • Baseline: For web/mobile, WCAG 2.1 AA is the operative benchmark inside EN 301 549 today (planning for 2.2 is smart, but most enforcement still checks 2.1).


Action: Set your internal bar to “WCAG 2.1 AA (web/apps) + relevant EN 301 549 clauses (docs, software, non-web ICT).”


Step 3: Run a Baseline Audit (Automated)

Kick off with an automated scan to surface common failures fast (contrast, alt text, form labels, landmarks, focus visibility).

  • Do this: Run a free baseline with GetWCAG Scanner (add your domain, crawl key pages, export issues).

  • Why: Automated checks give you a prioritized queue and a measurable starting score.

  • Caveat: No automated tool can prove full legal compliance—manual verification is still required. (Use automation for breadth; manual for depth.)

CTA: Scan your site now with GetWCAG → GetWCAG EAA Scanner


Step 4: Fix Critical WCAG 2.1 AA Issues First

Prioritize fixes that measurably impact users and risk:

  • Perceivable: Text alternatives, captions/transcripts, contrast (1.4.3/1.4.11), meaningful image alts.

  • Operable: Keyboard access (2.1.1), skip links, logical focus order, focus visible (2.4.7).

  • Understandable: Form labels/instructions (3.3.x), clear headings, consistent navigation.

  • Robust: Valid HTML, ARIA used correctly so assistive tech can parse your UI.

Action: Assign each issue to a dev/design owner with a due date. Track re-tests in GetWCAG until they pass.


Step 5: Verify Manually (You Can’t Skip This)

  • Keyboard-only walkthrough: You must be able to do all key tasks with Tab/Shift-Tab/Enter/Space/Esc.

  • Screen reader smoke test: NVDA/JAWS (Windows) or VoiceOver (macOS/iOS) across critical flows (search, cart/checkout, login, consent, contact forms).

  • Real users if possible: Validate pain points with testers who use assistive tech.
    Manual checks are expected by regulators and fill gaps automation can’t catch.


Step 6: Ship an Accessibility Statement & Feedback Channel

While the EAA is not the same as the public-sector Web Accessibility Directive, publishing an Accessibility Statement is a best-practice signal of due diligence and helps during complaints/procurement. Include: scope, conformance level (WCAG 2.1 AA), known gaps, roadmap, and a contact method for reporting issues. Enforcement is national—show your paper trail.


Step 7: Build Accessibility into UX & Performance

EAA is about equal access, and that aligns with modern SEO/UX:

  • Core Web Vitals & mobile UX: Faster, stable pages tend to be more accessible and usable.

  • Clear IA & headings: Helps users and search engines.

  • Focus styles, hit targets, motion preferences: Reduce friction for keyboard and cognitive accessibility.

Action: Add accessibility checks to design reviews and performance budgets.


Step 8: Train the Team & Set Governance

  • Designers: Color/contrast systems, states, components.

  • Developers: Semantics, ARIA, patterns, testing scripts.

  • Content: Plain language, descriptive link text, transcripts.

  • Owners: Name an accessibility lead; define SLAs for fixing issues surfaced by monitoring


Step 9: Monitor Continuously (Compliance Is Ongoing)

Roles change, content ships daily, regressions happen.

  • Do this monthly/quarterly:
  • Automated re-scans with GetWCAG across templates and key flows.
  • Manual spot checks on top tasks and new components.
  • Update your Accessibility Statement and changelog.

CTA: Set up scheduled scans in GetWCAG so new issues are caught before complaints land.


Quick Checklist (Copy/Paste for your team)

  • We confirmed EAA scope for our services/products.
  • We set WCAG 2.1 AA (via EN 301 549) as our baseline.
  • We ran an automated baseline scan (GetWCAG) and triaged issues.
  • We fixed high-impact WCAG issues and re-tested.
  • We completed manual keyboard/screen-reader checks.
  • We published an Accessibility Statement and feedback channel.
  • We scheduled ongoing monitoring (GetWCAG) and quarterly manual reviews.
  • We updated vendor requirements for WCAG conformance.
  • We documented everything for potential inquiries.


Frequently Asked Reality Checks

  • “Is WCAG 2.2 required?” Not broadly in law yet. Prepare for it, but enforcement today points to WCAG 2.1 AA in EN 301 549.

  • “We’re a micro-enterprise—are we exempt?” Some obligations may be eased, but verify your national law and remember reputation/procurement pressures still apply. 

  • “Will an automated tool make us compliant?” No tool can guarantee compliance. Regulators expect a combo of automation + manual testing + process. 

#1 Step-by-Step Guide to EAA 2025 Compliance (WCAG 2.1 AA Made Simple) | GetWCAG Blog