On June 28, 2025, a European Union directive is going to change digital accessibility across the globe for the better. Are you prepared?
The EU’s focus on ensuring digital accessibility for all of its members’ citizens regardless of ability culminates this June when the European Accessibility Act (EAA) goes into full effect. If you haven’t heard of this EU directive, you’re probably not alone. Despite the fact that it will affect any business that has a digital footprint in any EU country, whether based in the EU or not, it’s not being as widely talked about as it should be.
With an estimated 1.3 billion people – that’s 1 in 6 globally – who experience a significant disability, many of us encounter difficulties with digital technologies. Beginning in 2011, the EU has been establishing directives that set a universal standard of digital accessibility for all.
The act covers a variety of products and services, from computers and operating systems to ticketing and check-in machines – as well as websites. It’s easy to think that the EAA doesn’t apply to your brand if you don’t participate in e-commerce, but unfortunately that’s not a safe assumption to make.
“The EAA presents a clear message that digital accessibility can no longer be an afterthought,” says Peter Kelly, SVP and Managing Director of TravelDesk, a global programmatic digital advertiser. “Advertising needs to evolve with accessibility in mind. Travel brands risk losing valuable visitors, hurting their brand reputation and facing compliance issues, whether they’re based in the EU market or not. By embracing accessibility now, businesses and organizations are future-proofing themselves and showing every consumer that they matter.”
Because of the broad language of the directive, any business with a website that could be accessed by a citizen of the EU will be held to the EAA’s standards of online accessibility, enforceable by individual EU member countries. The EAA also instructs that EU members must provide a way for individual EU consumers to take action to ensure compliance, whether that action is under national law before the courts or with administrative bodies. And with the EAA being a directive, this means that each country within the EU has adopted its own rules, regulations and repercussions.
So what does this all mean?
If it’s possible that European eyes are going to see your website, you’d be leaving yourself vulnerable to penalties by not complying with the strictest EU member legislation. And those risks include:
Fines (In Italy, businesses can be fined up to 5% of their previous year’s income.)
Prison sentences (Ireland’s law allows sentencing of up to 18 months.)
Removal from the European market
Exclusion from the procurement process
Without a precedent for how EU countries are going to be actively enforcing their EAA legislation, businesses based in the EU and internationally face uncertain, but potentially severe, consequences for noncompliance.
“As time passes and the EAA directive is enforced, we will have a better understanding of how individual EU countries and jurisdictions are applying these standards and which efforts meet – or fail to meet – the EAA standards,” says Maureen Moeder, In-House Counsel at MMGY Global. “Until we have a better sense of how the EAA will be applied, the only thing we can say for certain is that brands that fail to take any steps to ensure accessibility are putting themselves at risk.”
While there are some exemptions for small businesses and those who would bear a disproportionate burden to enact the legislated regulations, the spirit of the EAA speaks to a broader ideal: That everyone, regardless of ability, should be able to access digital properties whether they’re using adaptive technologies or not.
“As we strive to create exceptional user experiences for travelers, we have to be considerate and hospitable to all travelers,” says Robert Patterson, SVP of Marketing Technology at MMGY. “With a large aging demographic and more individuals experiencing mobility or accessibility challenges, making your brand accessible is both the right thing to do for travelers and for your travel brand.”
The EAA directive focuses on four main principles to determine compliance: Are the efforts to ensure accessibility perceivable, operable, understandable and robust? The vagueness allows for individual EU countries to interpret this broadly or specifically, which means that as of yet, we don’t quite know how they will evaluate for compliance.
And while you may think that installing an accessibility widget or plugin on your website will be enough – you might be the 1 in 4 who discovers via lawsuit that it’s not. According to UsableNet, a company specializing in digital accessibility, more than a quarter of the accessibility lawsuits in the U.S. alone were against companies using accessibility widgets as a way to comply with the Americans with Disabilities Act, which is not nearly as comprehensive as the EAA.
“Brands should prioritize accessibility throughout the entire process, from the initial concept to the final delivery,” says Brendan Carpenter, Senior Front-End Developer and accessibility expert at MMGY. “Although it is possible to rectify a product or site, doing so is often a lengthy and time-consuming process. Moreover, it can be significantly more costly due to the additional time required. In many cases, certain features or aspects of the project may need to be rebuilt or discarded entirely if they are found to be inaccessible.”
Despite there being many automated accessibility testing systems out there, even these solutions aren’t foolproof. “While automated accessibility testing continues to advance, human testing remains essential, as it is impossible to detect issues such as tab order, keyboard usability, screen reader effectiveness and other critical factors with complete certainty through automation alone,” says Brendan. “Here at MMGY, we employ both automated tools and manual testing to ensure that our projects are fully accessible to all users, regardless of ability.”
With the June 28, 2025, EAA enactment date looming, travel brands around the world need to ask themselves, “Is my website EAA compliant?”
Want more information? Reach out to Robert Patterson at [email protected].
