EAA Compliance Checklist: 15 Steps to Meet the European Accessibility Act

Your Complete EAA Compliance Checklist

The European Accessibility Act (EAA) is in full effect since June 28, 2025. If your business provides digital products or services to EU consumers, you need to meet the accessibility requirements set out in EN 301 549 — which aligns with WCAG 2.2 Level AA.

That's a lot of technical jargon. This checklist breaks it down into 15 clear, actionable steps that take you from "where do I even start?" to a documented compliance strategy. Whether you're a developer, product manager, or business owner, this guide gives you a practical roadmap.

Not sure if the EAA applies to you? Start with our complete guide to the European Accessibility Act.

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Phase 1: Assessment & Planning

✅ Step 1: Determine If the EAA Applies to You

Before diving into technical requirements, confirm whether your organization falls under the EAA's scope.

The EAA applies if you:

• Sell products or offer digital services to consumers in the EU
• Operate an e-commerce platform, banking service, telecom service, or transport booking system
• Are NOT a micro-enterprise (fewer than 10 employees AND under €2M turnover)

Action items:

• Review the full list of covered products and services
• Check your employee count and annual turnover against the micro-enterprise threshold
• Document your determination for compliance records

✅ Step 2: Assign an Accessibility Lead

Accessibility needs an owner. Without clear responsibility, it falls through the cracks.

Action items:

• Designate an accessibility lead or team responsible for compliance
• Ensure they have authority to prioritize accessibility fixes
• Include accessibility in job descriptions for relevant roles (design, development, content)

Tip: This doesn't have to be a new hire. Many organizations start by training an existing team member and expanding responsibility over time.

✅ Step 3: Run an Automated Accessibility Scan

Get a baseline assessment of your current accessibility status. Automated tools can quickly identify common WCAG violations across your entire site.

Action items:

• Run a free WCAG 2.2 scan on your website → to get an instant compliance score
• Scan your most critical pages: homepage, product/service pages, checkout/signup flows, contact page
• Export and save the results as your baseline report

What automated scans catch:

• Missing alt text on images
• Insufficient color contrast
• Missing form labels
• Broken heading hierarchy
• Missing document language
• Empty links and buttons

✅ Step 4: Conduct Manual Accessibility Testing

Automated tools catch roughly 30-50% of WCAG issues. Manual testing catches the rest — especially issues related to usability and context.

Action items:

• Keyboard test: Navigate your entire site using only the keyboard (Tab, Enter, Escape, arrow keys). Can you reach every interactive element? Is the focus order logical? Is focus always visible?
• Screen reader test: Use NVDA (Windows), VoiceOver (Mac/iOS), or TalkBack (Android) to navigate your site. Does every element have a meaningful label? Is the reading order correct?
• Zoom test: Zoom to 200% and 400%. Does content reflow properly? Is anything hidden, overlapping, or broken?
• Color test: Review your design without color. Can all information still be understood?

✅ Step 5: Prioritize Issues by Severity

Not all issues are equal. A missing alt text on a decorative image is less critical than an inaccessible checkout form.

Priority framework:

1. Critical — Blocks users from completing core tasks (broken forms, inaccessible navigation, missing skip links)
2. Major — Significantly degrades the experience (poor contrast on body text, missing video captions, no focus indicators)
3. Minor — Noticeable but not blocking (decorative images without null alt, minor heading order issues)

Action items:

• Categorize each issue from your audit by severity
• Create a prioritized backlog or spreadsheet
• Set target dates for fixing critical and major issues first

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Phase 2: Implementation & Fixes

✅ Step 6: Fix Structural HTML Issues

Solid, semantic HTML is the foundation of accessibility. Fix these first — they affect everything else.

Action items:

• Set the correct lang attribute on the <html> element
• Use proper heading hierarchy (h1 → h2 → h3, no skipping levels)
• Use semantic elements: <nav>, <main>, <header>, <footer>, <section>, <article>
• Ensure all pages have a meaningful <title>
• Add skip navigation links ("Skip to main content")

✅ Step 7: Make All Content Perceivable

Users with visual or hearing disabilities need alternative ways to access content.

Action items:

• Add descriptive alt text to all informative images. Use alt="" for decorative images.
• Provide captions for all pre-recorded video content
• Add transcripts for audio content
• Ensure color contrast meets minimum ratios: 4.5:1 for normal text, 3:1 for large text
• Don't convey information through color alone — use text labels, patterns, or icons as well

✅ Step 8: Ensure Full Keyboard Accessibility

Many users navigate entirely by keyboard — including people using screen readers, switch devices, and voice control.

Action items:

• Every interactive element (links, buttons, form fields, menus, modals) must be reachable and operable via keyboard
• Focus indicators must be clearly visible (WCAG 2.2 requires a minimum focus indicator area)
• No keyboard traps — users must be able to navigate away from every element
• Tab order must follow a logical reading sequence
• Custom widgets (dropdowns, carousels, tabs) must implement proper ARIA patterns

✅ Step 9: Make Forms Accessible

Forms are where conversions happen — and where accessibility most often breaks.

Action items:

• Every input field must have a visible label programmatically associated via <label> or aria-labelledby
• Error messages must be specific, visible, and announced to screen readers
• Use aria-required or the HTML required attribute for mandatory fields
• Group related fields with <fieldset> and <legend>
• Provide input assistance — format hints, autocomplete attributes, and clear instructions
• Ensure form validation doesn't rely solely on color (e.g., red borders without text explanation)

✅ Step 10: Address WCAG 2.2-Specific Criteria

WCAG 2.2 introduced several new success criteria. Don't overlook these — they're part of the current EN 301 549 standard.

New in WCAG 2.2:

• Focus Not Obscured (Minimum) (2.4.11 AA) — When an element receives focus, it must not be entirely hidden by other content (like sticky headers or cookie banners)
• Dragging Movements (2.5.7 AA) — Any action that requires dragging must also have a non-dragging alternative (click-based)
• Target Size (Minimum) (2.5.8 AA) — Interactive targets must be at least 24×24 CSS pixels, or have sufficient spacing
• Consistent Help (3.2.6 A) — Help mechanisms (contact info, chat, FAQ links) must appear in a consistent location across pages
• Redundant Entry (3.3.7 A) — Don't make users re-enter information they've already provided in the same process

Want a deeper understanding? Read our WCAG 2.2 beginner's guide.

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Phase 3: Documentation & Compliance

✅ Step 11: Write an Accessibility Statement

An accessibility statement is your public declaration of compliance. Some member states explicitly require it.

Your statement should include:

• Which standard you conform to (EN 301 549 / WCAG 2.2 Level AA)
• Date of last assessment
• Known limitations and their reasons
• Planned improvements with timelines
• A feedback mechanism — how users can report accessibility issues
• Contact information for your accessibility team

Tip: Place your accessibility statement in the footer of every page so it's easy to find.

✅ Step 12: Create Internal Accessibility Documentation

Compliance requires more than a public statement. Maintain internal records that demonstrate your commitment and process.

Document:

• Audit reports and scan results (baseline and follow-ups)
• The remediation plan and progress tracking
• Training records for your team
• Design system accessibility guidelines
• Testing procedures and schedules
• Third-party vendor accessibility assessments

✅ Step 13: Train Your Team

Accessibility breaks when only one person understands it. Build organizational knowledge.

Training should cover:

• Developers — Semantic HTML, ARIA, keyboard interaction patterns, common coding pitfalls
• Designers — Color contrast, focus states, touch targets, inclusive design principles
• Content creators — Writing alt text, creating accessible documents, using heading structure correctly
• QA/Testing — Keyboard testing, screen reader basics, using accessibility checking tools
• Product managers — EAA requirements, prioritization, including accessibility in acceptance criteria

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Phase 4: Monitoring & Maintenance

✅ Step 14: Set Up Continuous Monitoring

Your website isn't static. Every content update, feature release, or design change can introduce new accessibility issues.

Action items:

• Schedule regular automated scans (weekly or after each deployment)
• Use our scanning tool to monitor your compliance score over time
• Include accessibility checks in your CI/CD pipeline if possible
• Conduct a full manual audit at least once per year (or after major redesigns)
• Track your compliance score trend — it should improve over time, not regress

✅ Step 15: Establish a Feedback Loop

Real users will find issues that testing misses. Make it easy for them to tell you.

Action items:

• Provide a clear, accessible contact method for reporting accessibility barriers
• Commit to a response timeline (e.g., acknowledge within 5 business days)
• Track reported issues and their resolution
• Use feedback to prioritize future improvements
• Consider a user testing program that includes people with disabilities

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Quick-Reference Summary

| Phase | Steps | Focus | |-------|-------|-------| | Assessment | 1–5 | Determine scope, audit, prioritize | | Implementation | 6–10 | Fix HTML, content, keyboard, forms, WCAG 2.2 | | Documentation | 11–13 | Accessibility statement, records, training | | Monitoring | 14–15 | Continuous scanning, user feedback |

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Common Mistakes to Avoid

Before you dive in, learn from what trips up most organizations:

• Relying only on automated tools — They're essential for scale but catch only a fraction of issues. Always supplement with manual testing.
• Treating accessibility as a one-time project — It's an ongoing process. Without monitoring, you'll regress.
• Ignoring third-party content — Embedded videos, chat widgets, payment forms, and social feeds must also be accessible. If a third party provides it on your site, you're still responsible.
• Waiting for perfection — Don't delay your accessibility statement because you're not 100% compliant. Transparency about known issues and your plan to fix them is better than silence.
• Forgetting mobile — The EAA covers mobile apps and mobile web experiences. Test on actual devices, not just desktop.

What Happens If You Don't Comply?

Enforcement varies by member state, but consequences are real:

• Financial penalties up to €100,000+ depending on the country
• Daily fines for ongoing violations (Norway: €4,500/day)
• Product removal from the EU market
• Consumer complaints and potential lawsuits

For a detailed look at enforcement by country, read our guide on EAA fines and penalties.

Start Your Compliance Journey Now

The best time to start was before the deadline. The second best time is right now. Begin with Step 3 — an automated scan that shows you exactly where you stand.

Scan your website for free → Get a complete WCAG 2.2 compliance report in 60 seconds. No signup, no commitment — just clarity on what needs fixing.