The term ‘digital accessibility’ probably needs no introduction, but just in case: it is the practice of designing and implementing technology so that it is accessible and usable by all people, regardless of their abilities or disabilities. This includes adapting websites, mobile applications, software and other digital interfaces so that they can be used by people with different types of disability – visual, auditory, motor, as well as neurodiverse, older adults or those with temporary limitations.
We strongly believe that technology should support the full participation of all members of society in public, educational and professional life. Digital accessibility contributes to the creation of a more inclusive society in which everyone can actively participate.
European Accessibility Act: What’s it about?
Purpose of the Act
The European Accessibility Act (EAA) aims to ensure that products and services in the European Union (EU) are accessible to people with different types of disability. The Act was adopted in 2019 and its provisions are to be fully implemented by 28 June 2025. The main objectives of the EAA are:
- Harmonise accessibility rules across the EU to facilitate the exchange of services across borders and reduce barriers related to different national rules.
- Improve the accessibility of products and services, thus enabling a more inclusive society and facilitating independent living for people with disabilities.
Scope of regulation
The EAA covers a wide range of products and services, including:
- Computer hardware and software: computers, smartphones, operating systems.
- E-commerce services: online shops, shopping platforms.
- Transport services: ticket machines, self-service kiosks at airports.
- Banking services: ATMs, payment terminals.
- Public services: websites and mobile applications of public institutions, e-books and their readers.
The EAA covers a wide range of products, including both public and private companies.
Full implementation should take place by 28 June 2025
Requirements & Deadlines
EU Member States must adapt their regulations to the requirements of the EAA and publish them by June 2022. Full implementation should take place by 28 June 2025. The EAA sets out accessibility requirements for products and services that must be met by the deadlines.
Read more: How will the new Accessibility Act (EAA) affect your business?
Digital Accessibility Act – exemptions and transition periods
Businesses can continue to use existing products, such as computer hardware, payment terminals or other devices that were in use before 28 June 2025, until 2030. This will allow time for any necessary changes to be made, but it is a temporary solution and does not exempt businesses from full compliance.
Service contracts entered into before 28 June 2025 will be allowed to continue for up to five years, after which they will have to comply with the new requirements. This means that after this period, all services and products must be fully compliant with the EAA, regardless of previous agreements.
Self-service terminals, such as ticket machines or self-service kiosks at airports and in shops, can be used until the end of their “economic life”, but no longer than 20 years. Many of these terminals are already outdated and do not meet modern accessibility standards and may need to be replaced sooner than planned.
Certain exemptions may apply to micro-enterprises, which employ fewer than 10 people and have an annual turnover of less than €2 million. Micro-enterprises may be exempted from some requirements, making it easier for them to adapt to the new rules without incurring excessive costs.
Accessibility law – what does it really mean for your business?
Adapting public sector mobile applications and services
In the past, accessibility was often overlooked by both design and development teams. There has also been a lack of guidelines and regulations to specify such requirements. As a result, many older applications do not meet today’s accessibility standards. Problems often arise at the level of HTML structure or the use of appropriate colour contrast. Sometimes there is a lack of support for screen readers or a lack of consideration for users’ individual browser settings. There is a lack of proper keyboard navigation, focus indicators, or information about dynamically appearing elements. All this means that people with disabilities face significant barriers to using digital products, sometimes making it impossible.
The introduction of the European Accessibility Act (EAA) means that companies will have to adapt their products and services to the new accessibility requirements. Older applications and services that do not meet current standards will have to undergo significant technical changes to ensure accessibility for all users.
Can some outdated features be retained?
No, no outdated functionality should be maintained. All elements of applications and services must be adapted to the requirements of the EAA. If only some of the functionality of your company’s application or platform is outdated, it still needs to be updated to meet accessibility standards. Failure to comply can result in financial penalties and loss of customer confidence.
For Polish companies and entrepreneurs, this means taking decisive action to adapt their products and services to accessibility standards. Although this may be costly, it will bring long-term benefits in the form of a larger customer base, improved reputation and regulatory compliance.
The social impact
of digital accessibility
In 2022, around 27% of the European Union population aged 16 and over will report having some limitations in performing daily activities due to various disabilities. This means that more than a quarter of adults in the EU experience difficulties related to disability.
The EAA aims to improve the quality of life for these people, as well as for older people, parents with young children and others with functional limitations, whether permanent or temporary. Technology should support the full participation of all members of society in public, educational and professional life.
Digital accessibility allows people with disabilities to use technology on an equal basis with others, increasing their independence and quality of life. For example, a blind person can use a mobile banking application thanks to assistive technologies such as screen readers. The difficulties faced by people with disabilities can vary widely:
- Parents with young children: Digital accessibility can make life much easier for parents with young children. For example, websites and mobile applications that are easy to navigate and use can help parents complete everyday tasks such as shopping online, scheduling medical appointments or using banking services quickly and efficiently, even when they are busy or on the go.
- Older adults: Older people often struggle to use digital technology because of vision or hearing problems. Features such as text magnification, contrast adjustment and screen reader support can make it easier for them to use online services, increasing their independence and quality of life.
- People with mobility impairments: Digital accessibility, including features such as keyboard navigation and voice control, can make it much easier for people with mobility impairments to use technology. This allows them to effectively use the Internet, mobile applications and other digital services without the need for a mouse or touch screen.
- Neurodiverse people: Digital accessibility is also critical for neurodiverse individuals, such as those with autism or ADHD. These individuals often have difficulty using overloaded interfaces with lots of animation and overly complex page structures. Designing simple and clear interfaces and simplifying the user path not only supports neurodiverse individuals, but is also beneficial for all users, especially in times when many people struggle with attention deficits. Simple interfaces help to improve concentration and reduce user fatigue.
Around 15-20% of the population in Europe may currently be digitally excluded due to a lack of digital accessibility in the public sphere.
Why should you care about digital accessibility in your organisation?
Some might say that “a humane approach isn’t everything”, and in this case, digital accessibility is also proving its worth. Although it can be costly to adapt older applications to new standards, there are many benefits.
According to available data, around 15-20% of the population in Europe may currently be digitally excluded due to a lack of digital accessibility in the public sphere. This means that millions of people have limited access to digital products and services, which is a huge loss for both these people and the businesses that could reach them with the right solutions.
It is also important to remember that accessibility requirements apply to all services provided by public bodies, including online services. Implementing accessibility requirements has a significant impact on search engine optimisation (SEO). Digital accessibility and SEO share common goals: improving the usability and accessibility of content for the widest possible audience. Improving accessibility simply increases the number of potential users and therefore customers for your business, which can lead to better conversion rates and sales. Ideally this could be up to 20% higher!
In addition, companies that invest in accessibility are perceived as being more socially responsible and caring for their customers, which has a positive impact on their image.
Harmonised rules make it easier for businesses to exchange products and services across borders within the EU, reducing the costs of adapting to different national requirements. A larger market for accessible products and services can lead to more competition and lower prices.
Consequences
of non-compliance
Organisations that do not comply with the requirements of the EAA may be subject to financial penalties. National Regulatory Authorities will enforce these rules and may impose fines for non-compliance. The level of fines will depend on the seriousness of the breach and its impact on users with disabilities.
As this law is just coming into force in Europe, we can take some examples from the United States, where digital accessibility regulations have been in place for about 30 years. In the US, penalties for non-compliance with accessibility regulations can be up to $55,000 for the first violation and $110,000 for each subsequent violation. Some more “impressive” examples below.
Examples of Penalties for Violations of the Accessibility Act
- National Federation of the Blind v. Target Corporation: Target Corporation paid $6 million for failing to make its website accessible to blind people in violation of California state law and the ADA. The company also had to monitor the accessibility of its website for three years and train its development team.
- National Association of the Deaf v Netflix: Netflix had to pay $755,000 for failing to provide captioning for its video content in violation of the ADA. The company agreed to caption its entire library within two years.
- Juan Carlos Gil v. Winn-Dixie: Winn-Dixie had to spend $250,000 to bring its website up to WCAG 2.0 AA standards and provide annual accessibility training for its employees.
Failure to comply with the EAA therefore carries financial and legal risks. Businesses should invest in durable and effective accessibility solutions to avoid penalties. Investing in accessibility is not only about meeting legal requirements, but also about contributing to a more inclusive society.
Using workarounds
An example of ‘getting around’ the rules is the use of ‘accessibility overlays’, which are tools (plugins) that can be added to a website or web application to quickly improve its accessibility without making significant changes to the code. They act as an extra layer that changes the way content is displayed, for example by adding options to change contrast, enlarge text or activate a screen reader.
While overlays may seem like a quick and easy solution, they often fail to address fundamental accessibility issues, such as the lack of proper labelling for forms or poor structuring of content. They can also cause conflicts with other scripts on the site and affect its functionality.
The use of such workarounds does not meet the requirements of the EAA and can lead to additional legal problems. Overlays are often criticised for being insufficiently effective in improving accessibility and may be considered inadequate by regulators. Paradoxically, they can actually make a product less accessible.
Our responsibility
It is important for us to emphasise that at a time when most companies and institutions are moving their services online, digital accessibility should be treated as a fundamental human right, not an additional feature. Ensuring accessibility is simply an act of respect for the dignity of every human being.
As technology providers, we believe it is our duty to understand and empathise with the needs of people with disabilities so that we can design solutions that work for everyone. An important element of this is involving users with disabilities in the design and testing of technology, so that their perspectives and experiences are considered from the outset. We believe that good solutions are those that are naturally inclusive, without the need for special ‘modes’ or ‘options’.
Putting digital accessibility into practice
Companies should now work intensively on the full implementation of the European Accessibility Act (EAA) regulations to avoid problems and sanctions in the future. This implementation includes training teams, implementing accessibility tools across the company’s digital platforms, and continuously monitoring compliance. However, the first step should be an audit of your company’s current solutions.
Accessibility in UX and UI design
Key aspects to focus on:
- Colour contrast and text size: Ensure proper contrast between text and background, and adjust text sizes to be readable by people with visual impairments. Tools such as WAVE can help assess colour contrast.
- Simple and clear navigation: Simplify user paths and design intuitive interfaces that are easy to understand and use. Users should be able to navigate the site quickly and easily, which increases accessibility.
- Universal design patterns: Use well-known and universal design patterns that are intuitive and familiar to users. This helps reduce barriers to entry and makes technology easier to use for people with different disabilities.
Code compliant with Web Content Accessibility Guidelines (WCAG)
There are many benefits to writing code to standards, and this is particularly important in the context of accessibility. Following WCAG in the development process includes education, awareness, auditing, coding practices, proper use of ARIA attributes, keyboard accessibility, labelled forms, semantic HTML tags, and ongoing testing and maintenance. The use of best practices, such as the correct use of HTML semantics, helps to avoid many accessibility problems. For example, correctly tagging headers, lists, and other structural elements makes pages more readable for screen readers and other assistive technologies.
Benefits of this approach:
- Ease of adaptation: Well-written code is easier to update and adapt to new accessibility requirements. This means lower costs and less time to implement changes.
- Future proofing: Standards-conformant code ages better, making it more resilient to future technological and regulatory changes.
- Cost-effective: Investing in an experienced development team that writes standards-compliant code from the outset brings long-term savings. Fixing neglected code structures can be more expensive than writing them from scratch.
For practical tips on implementing accessibility, read “How to implement WCAG requirements in your organisation?”
A humane approach to digital accessibility is more than meeting legal requirements and business strategy. It is a commitment to creating technology that respects the dignity and rights of users, promotes equality and inclusion, and is designed with empathy and understanding for the diverse needs of all people. With this approach, we can build a society where everyone has equal opportunities to participate in digital life.
As for the business aspect, we write more about this in the article “How the new Accessibility Act (EAA) impacts your business?”
Sources of the data
- EUR-Lex Directive 2019/882
- European Parliament – European Accessibility Act
- European Accessibility Act 2025: A Comprehensive Guide – digitalstrategy.ie
- Deque – European Accessibility Act: Top 20 Key Questions Answered
- Employment, Social Affairs & Inclusion – European Commission
- Population with disability – Statistics Explained
- Craig Abbott – European Accessibility Act: Article 32, and why it sucks
Authors
Aneta Węsławska – UX/UI Designer
For the past 6 years, she has been with SYZYGY Warsaw, where she focuses on designing web and mobile interfaces and creating Design Systems. For the last 2 years, she has been working on mobile applications for Lufthansa Group. In her work, she combines creativity with data-driven insights and a deep understanding of technology. She strives to demonstrate that solving end-user problems often leads to achieving clients’ business goals. Recently, she has been intensively deepening her knowledge of digital product accessibility. She has also been a mentor in the last two editions of the Dare IT program in the UI Design path.
Klaudia Brzywcy-Nosowicz – Frontend Solution Architect
Although she has a medical background, Klaudia discovered a passion for creating digital products. She focuses on user interface programming and advisory support for the Kyocera web platform, which serves dozens of markets. She works daily with JavaScript and React. Her current tasks also include ongoing performance improvement and auditing of applications, as well as actions aimed at optimizing Core Web Vitals metrics.
She believes that the ability to conduct scientific research greatly aids in making informed development and technology-related decisions. Understanding client needs and delivering high-quality software are of utmost importance to her. Klaudia is always eager to answer questions and explain complex technical terminology, making business decision-making easier for those less familiar with technology.
Ensure Accessibility
Would you like to learn more about how the new accessibility regulations might impact your business? Or perhaps you need support in implementing WCAG standards in your digital services?
Get in touch with us to:
- Understand how the EAA could affect your business
- Receive guidance on implementing WCAG requirements
- Consult on the digital accessibility of your products and services
Fill out the form below, and we will get back to you with tailored solutions that meet your needs. Ensure accessibility and boost your business’s competitiveness in the market.
