European Accessibility Act 2025: how it impacts UX design and websites

On 28 June 2025, the European Accessibility Act (EAA) comes into force, and it is set to transform the digital landscape for businesses across the EU, including Ireland. This new law mandates that digital products and services are designed to be accessible to people with disabilities.

“Accessibility is not just a legislative requirement or a business consideration – it’s a social responsibility. At Matrix, we believe that digital experiences should be usable by everyone, regardless of ability. Embracing accessibility is a chance to do better by our users and lead by example.”
— Jeff Sheridan, Managing Director, Matrix Internet

Its scope is broad – covering everything from websites and mobile apps to self-service kiosks (like ATMs and ticket machines), e-readers and smartphones, online banking platforms, e-commerce sites, transport information systems, and more. In short, if you offer digital tools or content in the EU – whether in retail, finance, travel, media or consumer devices – you will likely be affected. Below, we explain what the EAA entails, why it matters for user experience (UX) and your business, and how you can prepare.

What is the European Accessibility Act?

The European Accessibility Act is an EU directive (Directive (EU) 2019/882) aimed at harmonising accessibility requirements across member states. By introducing common rules for accessible products and services, the EAA seeks to remove fragmented national standards and ensure a single market for accessibility. According to the European Commission, businesses will benefit from uniform EU rules that reduce costs, ease cross-border trade, and open new market opportunities for accessible offerings. . Meanwhile, persons with disabilities (and the elderly) will benefit from a greater availability of accessible products and services – often at more competitive prices – and face fewer barriers in areas like transport, education and online services. In other words, the EAA is not only a civil rights initiative but also a push for innovation and inclusivity in the European digital economy.

Who must comply?

The EAA applies to both public and private sector organisations that provide the products or services within its scope. This includes manufacturers, digital service providers, and any business responsible for offering those products or services in the EU. Notably, micro-enterprises (companies with fewer than 10 employees and under €2 million turnover) are exempt from the EAA’s requirements for services. However, even small businesses are encouraged to voluntarily improve accessibility, since doing so can expand their customer base and demonstrate social responsibility.

What products and services are covered?

The Act targets areas that are most important for people with disabilities and that previously had varying rules across Europe. These include digital and self-service products like:

• Computers, operating systems and smartphones – the hardware and software people use to access digital content
• Self-service terminals – ATMs, ticketing machines, check-in kiosks, payment terminals and similar devices
• Telecom and media equipment – e.g. digital TV services and set-top boxes, telephony services and related devices
• Online services – from e-commerce websites and marketplaces to social media, news sites, and video streaming platform
• Banking and transport services – online banking platforms, consumer banking services, as well as digital passenger transport information and booking services
• E-books and digital content – e-book files and dedicated reading software.

In practice, if your business offers an app, website or interactive device that consumers use, accessibility requirements will likely apply. The law emphasizes providing multi-sensory access – for instance, alternatives for both audio and visual content – and user interfaces that can be operated by people with varying abilities. The overarching principle is to “design with accessibility in mind” from the start, rather than retrofit as an afterthought.

Compliance standards: WCAG 2.1 AA and EN 301 549

How do you ensure your website or app is accessible under the EAA? In technical terms, the Act aligns with well-established accessibility standards. EN 301 549 is the EU’s harmonised standard for ICT accessibility, and it incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 at the AA level. In fact, designing to WCAG 2.1 AA is widely considered essential for web and mobile content to meet the EAA requirements.
While the legislation itself doesn’t list specific technical checklists, conforming to WCAG 2.1 AA provides a “gold standard” benchmark and gives a presumption of conformity under the law. This means ensuring features like text alternatives for images, captions for video/audio, proper heading structures, keyboard navigation support, sufficient colour contrast, and so on, as detailed in WCAG. Many businesses will recognise these as the same guidelines already expected of public sector websites in the EU (under the separate Web Accessibility Directive). Now, similar expectations will extend to private-sector digital products and services as well.
It’s important to note that meeting these standards isn’t just about avoiding penalties – it’s about making your digital content usable by as many people as possible. An accessible site or application improves the experience for all users, not only those with disabilities, by adhering to good design principles like clarity, consistency, and device compatibility.

Enforcement and penalties for non-compliance

The European Accessibility Act has real teeth. EU member states are responsible for enforcement, and in Ireland the Act is implemented via the Accessibility Requirements (Products and Services) Regulations 2023, coming into effect on 28 June 2025. Regulators have been given powers to monitor and ensure compliance. For example, Ireland’s Competition and Consumer Protection Commission will act as a market surveillance authority for products, and other regulators (such as media or banking regulators) will oversee services in their sectors.
Critically, the law comes with significant penalties. In Ireland, failure to comply with the EAA can lead to a summary fine up to €5,000 (and/or 6 months imprisonment), and for more serious offenses tried on indictment, fines up to €60,000 or up to 18 months in prison (or both) for responsible individuals. Company directors and officers can be held personally liable for accessibility breaches. – a clear sign that accessibility is being taken as seriously as other compliance areas.
Beyond these direct penalties, non-compliance can trigger other consequences. Regulators may issue orders to stop selling or offering non-conforming products/services until issues are fixed. Private lawsuits are also a risk: under the Irish regulations, individual consumers (potentially backed by advocacy groups) can bring legal action against non-compliant businesses in court. This means enforcement isn’t only top-down – it can be driven bottom-up by customers asserting their rights. The reputational damage from being called out for poor accessibility can be severe, leading to negative publicity and loss of trust. In competitive terms, if your rivals embrace accessibility and you lag behind, you risk both legal trouble and losing market share as users gravitate towards more inclusive options.

The clock is ticking: from 28 June 2025 onward, any new product or service in scope must comply, and existing ones will need to be upgraded if they undergo substantial updates. (There are some limited exceptions – for instance, legacy self-service kiosks installed before 2025 can remain until end-of-life, and services can use older products until 2030 if a retrofit would fundamentally alter them. – but these are narrow and require documented justification.) The safest course for any business is to assume the rules apply and act accordingly, rather than hoping for an exemption.

Why accessibility matters for UX and business success

Ensuring compliance with the EAA is not just a legal duty – it’s also good business and good design practice. There’s a common misconception that accessibility limits creativity or the results are bland, stripped-back UI, but the opposite is true. Designing with accessibility in mind leads to smarter, more intuitive experiences for everyone. Accessible design is not about doing less. it’s about doing better,clearer typography, better contrast, responsive layouts, and content that’s usable by all. It elevates design, rather than constraining it. Here are key reasons why focusing on accessibility will benefit your organisation beyond simply avoiding fines:

• Reach a larger audience (Inclusivity) – By designing for accessibility, you make your digital services usable by the 100+ million consumers in the EU with disabilities or long-term impairments. For example, over 1.1 million people in Ireland (22% of the population) reported in the 2022 census that they have at least one long-lasting condition or difficulty. Across Europe, roughly 1 in 5 people have some form of disability. Inclusive design means these potential customers can access your website or app, whereas otherwise you might be unintentionally turning away a huge segment of the market. In short, accessibility can directly expand your customer base and boost your bottom line.
• Better UX for everyone – Many accessibility best practices align with general user experience improvements. Clean, well-structured content with clear navigation, high contrast visuals, and captioned media doesn’t only help users with disabilities; it tends to make the experience smoother for all users (including those on mobile devices or in low-bandwidth conditions). An accessible design often improves overall usability and customer satisfaction, which can differentiate your brand. Think of features like zoomable text, clear error messages, or keyboard shortcuts – these benefit users with disabilities and can be conveniences for others too.
• SEO and discoverability – There is a known overlap between accessibility and search engine optimisation (SEO). Practices such as providing alternative text for images, using proper HTML semantics, and ensuring a site loads efficiently all contribute to better accessibility and higher search rankings. Search engines favor websites that are fast, well-structured, and user-friendly – which are exactly the outcomes of following standards like WCAG. By making your site accessible, you may see improvements in organic search performance and broader reach. Companies that have invested in accessibility often report improved SEO and customer loyalty as side benefits.

“Accessible websites are not only better for users, they’re better for search engines too. Many of the principles behind accessibility — such as clear structure, alternative text and fast load times — align with SEO best practices. At Matrix, we see accessibility as part of a holistic strategy that improves visibility, usability and long-term performance.”
— Srdjan Nikolic, Senior SEO Specialist, Matrix Internet

• Legal risk mitigation and reputation – As discussed, non-compliance poses legal risks – from fines and enforcement actions to lawsuits. Beyond the financial hit, being flagged for poor accessibility can damage your brand’s reputation. In the age of social awareness, customers and stakeholders expect companies to be inclusive. An accessibility failure could be publicised by consumer groups or on social media, painting your business as neglecting people with disabilities. Conversely, proactively championing accessibility bolsters your brand image as socially responsible and future-oriented. It’s part of good corporate citizenship today. In some cases, competitors might even use accessibility (or lack thereof) as a differentiator – so you don’t want to be on the wrong side of that comparison. Embracing accessibility now helps you avoid legal pitfalls and demonstrates a commitment to equality that can strengthen customer trust.

Making your digital products accessible results in a win–win: you comply with the law and deliver a superior, inclusive user experience. The EAA is essentially enforcing what UX professionals have long advocated – that designing with diverse users in mind leads to better outcomes all around.

How to prepare for the EAA: an action plan

With the 2025 deadline upon us, every organisation should take concrete steps to ensure their websites, apps, and other digital systems meet the required standards. Here is an action plan to guide your preparation:

• Audit your digital assets – Begin with a comprehensive accessibility audit of all your customer-facing digital assets (websites, mobile applications, self-service kiosks, etc.). This audit should measure your current compliance against WCAG 2.1 AA / EN 301 549 criteria. Use a combination of automated testing tools and manual reviews by accessibility experts (including testing with assistive technologies like screen readers). The goal is to identify any barriers or gaps in your content and user interface. An audit will give you a clear baseline of what needs fixing most urgently.
• Plan and implement necessary fixes – Treat the findings of the audit as a project roadmap. Prioritise critical issues that would prevent users with disabilities from completing key tasks (for example, inability to use forms with a keyboard, or lack of alt text on important images). Develop a remediation plan with timelines and responsibilities. It’s wise to integrate these fixes into your development sprints or project plans as you would any other compliance or feature requirement. Aim to meet WCAG 2.1 AA success criteria across the board, since this level is essentially the expected standard under the EAA. This may involve updating your site’s code, redesigning certain components, adding accessibility features (like captions or transcripts for media), and improving content structure. If you have legacy platforms that are hard to update, consider whether an upgrade or replacement is needed to achieve compliance.
• Embed accessibility into design and development – Accessibility should not be a one-time retrofit; it needs to be an ongoing part of your workflow. Educate your design, UX, and development teams to “shift left” on accessibility – meaning consider accessible design from the earliest stages (wireframing, UX research, content planning) rather than trying to fix issues at the end. Establish internal guidelines or checklists for accessible design, and make it a standard practice to review new features for accessibility before launch. By building accessibility into your design system and development process, you not only comply with the law but also reduce long-term maintenance costs (fixing issues later is always more expensive). As an example, at Matrix Internet our approach to creative web design places accessibility as a foundational principle, ensuring that inclusivity and usability go hand-in-hand in every project.
• Train and equip your team – Ensure that everyone involved in creating digital content understands the importance of accessibility and knows how to do their part. Provide training sessions for designers on colour contrast and layouts, for developers on semantic HTML, ARIA roles, and testing with assistive tech, and for content authors on writing descriptive link text and ALT tags. Building an accessibility-aware culture is key to sustained compliance. You may also designate an accessibility champion or hire specialists to guide best practices. Additionally, plan for regular testing and monitoring – not just one-off. Periodically run accessibility scans and conduct user testing (including users with disabilities if possible) to catch regressions or new issues as your digital services evolve.
• Update documentation and accessibility statements – The EAA will require that you document your product’s accessibility features and compliance. Most likely, this means preparing an Accessibility Statement for your website/app that outlines its level of conformance, any known gaps, and a way for users to contact you with accessibility feedback. Many organisations in the EU are already familiar with this from public sector requirements. Make sure to update or create these statements by the deadline. Internally, also keep records of your compliance efforts (audit reports, fix logs, training materials) – this can demonstrate your due diligence if regulators or stakeholders request evidence. Having clear documentation and an up-to-date accessibility statement not only meets legal obligations but also signals transparency and commitment to users.

By following these steps, you’ll be well on your way to meeting the EAA requirements. Remember that accessibility compliance is an ongoing process, not a one-time project. After June 2025, continue to monitor changes in standards (for instance, WCAG 2.2 or 3.0 in the future) and user feedback to keep improving.

“At Matrix, we see accessibility not as a checkbox, but as a commitment to digital inclusivity for everyone. It’s more than compliance; it’s designing with empathy in mind. As a UX designer, I see it as a priority – something that’s included in the design process rather than an afterthought.” — Zahra Alboqub, UX Designer & Researcher at Matrix Internet

The European Accessibility Act represents a new era where accessible design is the default for digital products. For businesses across Europe, this is a call to action to elevate their UX by making it inclusive for all users. While the compliance deadline brings urgency, it’s helpful to view accessibility improvements as an investment that will pay off through a wider audience reach, improved user satisfaction, and a stronger brand reputation. By embracing accessibility now, you’re not only avoiding penalties – you’re future-proofing your services and affirming that every customer matters. The EAA makes digital inclusion a legal requirement, but it’s also a chance to demonstrate leadership and empathy in your industry. The takeaway is clear: accessibility isn’t just about meeting a standard, it’s a design mindset and business imperative going forward. Now is the time to act and ensure your digital presence is truly usable by everyone.

Let’s make the web a place where no user is left behind.