Comparing the EAA 2025 with ADA and AODA: What’s Different, What’s Similar

The European Accessibility Act (EAA) officially took effect on June 28, 2025, marking a major milestone for digital inclusion across Europe.
For organizations offering digital products and services, accessibility is no longer optional — it’s a legal requirement.

But how does the EAA compare to other established accessibility laws like the Americans with Disabilities Act (ADA) in the United States or the Accessibility for Ontarians with Disabilities Act (AODA) in Canada?
Although these laws share the same purpose — ensuring equal access for people with disabilities — their scope, enforcement, and technical standards differ in meaningful ways.

1. The European Accessibility Act in Effect

The EAA (Directive (EU) 2019/882) requires all EU member states to enforce accessibility rules for specific digital and physical products and services.
It applies to both EU-based companies and non-EU organizations that provide services to European users.

What the EAA Covers

• Websites and mobile applications
• E-commerce and online platforms
• Banking and financial services
• E-books and reading software
• Ticketing and self-service terminals
• Transport and communication systems

The directive defines functional accessibility requirements but relies on the harmonized European standard EN 301 549 for its technical details.
Within EN 301 549, the digital accessibility benchmark is WCAG 2.1 Level AA — the same guidelines recognized internationally by the W3C.

In practice, EAA compliance now means conforming to WCAG 2.1 AA. Organizations that meet these criteria can demonstrate technical conformance under the EAA.
Adopting WCAG 2.2 early is recommended, as future revisions of EN 301 549 are expected to align with it.

2. ADA Accessibility in the United States

The Americans with Disabilities Act (ADA), enacted in 1990, prohibits discrimination against individuals with disabilities.
While originally focused on physical environments, the ADA has been interpreted by courts and the Department of Justice to include websites and mobile applications as “places of public accommodation.”

Unlike the EAA, the ADA does not specify a technical standard such as WCAG. Instead, accessibility expectations are shaped by case law and DOJ settlements.
As a result, most organizations and courts use WCAG 2.1 Level AA as the practical benchmark for ADA digital compliance.

ADA enforcement remains reactive — primarily through lawsuits or negotiated settlements — rather than proactive regulatory audits.

3. AODA Requirements in Ontario, Canada

The Accessibility for Ontarians with Disabilities Act (AODA), introduced in 2005, takes a structured approach to accessibility.
It sets phased deadlines and reporting requirements for public, private, and nonprofit organizations.

For web and digital content, the AODA mandates conformance with WCAG 2.0 Level AA, with some exceptions for live captioning and audio descriptions.
Many organizations in Canada now voluntarily align with WCAG 2.1 to stay consistent with global best practices.

Unlike the ADA, AODA enforcement is administrative, involving compliance reports and fines rather than litigation.

4. Key Differences at a Glance

At the heart of all three frameworks lies the Web Content Accessibility Guidelines (WCAG) — a globally recognized technical standard.
WCAG 2.1 AA defines 50 success criteria under four core principles:

• Perceivable: Users must be able to perceive information presented.
• Operable: Navigation and interactions must be accessible via keyboard or assistive tech.
• Understandable: Content and interfaces must be predictable and easy to comprehend.
• Robust: Content must remain compatible with current and future technologies.

By aligning with WCAG 2.1 AA, organizations satisfy the technical foundation for EAA digital accessibility and meet expectations under ADA and AODA.

6. Enforcement in 2025 and Beyond

Since June 2025, EU member states have begun enforcing the EAA through designated national authorities.
Businesses that fail to comply risk administrative fines, restrictions on market access, or public non-compliance notices.

EAA enforcement emphasizes proactive monitoring, not reactive litigation. This contrasts with the ADA’s lawsuit-driven approach.
For global companies, this means accessibility is now a market access condition in Europe, not merely a legal defense strategy.

7. How to Stay Compliant

To maintain ongoing accessibility compliance under the EAA, organizations should:

1. Conduct regular WCAG 2.1 AA accessibility audits of websites and apps.

2. Document accessibility statements in line with EN 301 549 requirements.

3. Establish internal policies for accessible design and development.

4. Re-test and monitor accessibility after every major update.

5. Provide accessible documentation, customer support, and communication channels.

These same practices align closely with ADA and AODA expectations, allowing global organizations to maintain one accessibility standard across markets.

8. The Global Shift Toward Unified Accessibility

The EAA’s enforcement in 2025 represents a turning point: accessibility is now a regulated digital standard, not just a best practice.
By referencing WCAG 2.1 AA, the EU has joined North America in moving toward a shared, measurable definition of accessibility.

Organizations that adopt accessibility proactively benefit from reduced legal risk, better user experience, and improved SEO performance — since accessible design overlaps with many search optimization principles.

Conclusion

With the European Accessibility Act now active, accessibility has become a legal requirement for anyone serving EU customers.
Although the ADA and AODA differ in structure, all three frameworks ultimately rely on WCAG 2.1 Level AA as their technical foundation.

Achieving EAA compliance today means aligning your digital assets with WCAG 2.1 AA and maintaining accessibility as an ongoing process, not a one-time checklist.

If you want to understand where your site currently stands, start with a free WCAG 2.1 accessibility scan at GetWCAG.com.
You’ll receive actionable insights to help you meet EAA requirements and improve accessibility across your entire digital experience.