EAA Compliance Checklist (2026): What Your Website Must Do

The European Accessibility Act (EAA) has been mandatory since 28 June 2025 for many businesses that sell products and services to consumers in the EU. If that includes you, accessibility is no longer a nice-to-have — it's a legal obligation. This checklist walks through what to do, in order, so you can find the gaps and start closing them.

Honest note up front: no checklist (and no automated tool) can guarantee legal compliance. This is an audit aid to help you get most of the way and document your work. For high-risk situations, pair it with a manual accessibility review and, where needed, legal advice.

Step 1 — Confirm whether you're in scope

The EAA targets businesses offering specified products and services to EU consumers — including e-commerce, banking, e-books, ticketing, and many digital services. Microenterprises providing services may have partial relief, but the rules and thresholds vary, so don't assume you're exempt. Work through this first:

Do you sell goods or services online to consumers in any EU member state?
Does your offering fall into a covered category (e-commerce, banking, transport, e-books, etc.)?
Are you above the microenterprise threshold for the relevant obligation?

If you answer "yes" to the first two, treat yourself as in scope until you've confirmed otherwise. Scope and exemptions are transposed into national law differently across the EU — verify against your member state's implementation. See our EAA deadline and penalties guide for who must act and what enforcement can look like.

Step 2 — Adopt WCAG 2.2 AA as your target

The EAA points to harmonised standards that, in practice, track the Web Content Accessibility Guidelines. Aim for WCAG 2.2 Level AA — it's the current benchmark and it covers the earlier 2.0 and 2.1 criteria too. Building to AA gives you a defensible, recognised target rather than a vague "make it accessible" goal.

Step 3 — Run an automated scan to find the obvious failures

Start by catching the issues a machine can reliably detect: missing image alternatives, low colour contrast, form fields without labels, empty links and buttons, missing page language, and broken landmark/heading structure. An automated scan won't find everything, but it clears the high-volume, easy-to-miss problems fast.

You can free scanner (coming soon) with WCAGwise — it runs entirely in your browser using the axe-core engine and lists issues worst-first with the exact WCAG criterion for each.

Step 4 — Do the manual checks automation can't

Automated tools catch only a portion of WCAG criteria. The rest needs a human. At minimum, test:

Keyboard only — can you reach and operate every control with Tab, Enter, Space, and arrow keys, with a visible focus indicator?
Screen reader — does each page make sense read aloud (NVDA, VoiceOver, or JAWS)?
Meaningful alt text — do images convey the right information, not just "image123.png"?
Logical reading and focus order — does content follow a sensible sequence?
Forms and errors — are labels, instructions, and error messages clear and programmatically associated?
Zoom and reflow — does the page stay usable at 200% zoom and on small screens?
Media — captions for video, transcripts for audio.

For more on the line between automated and manual testing, see is my website WCAG 2.2 AA compliant?

Step 5 — Prioritise and fix worst-first

Sort findings by severity and user impact, not by how easy they are to fix. Blocking issues — a checkout you can't complete with a keyboard, an unlabeled critical form, contrast that makes text unreadable — come first. Tackle critical and serious issues, then moderate, then minor.

Step 6 — Document conformance and accessibility support

The EAA expects businesses to be able to demonstrate accessibility, not just claim it. Keep a record of what you tested, what you found, what you fixed, and what's outstanding. Many organisations publish an accessibility statement describing their conformance level and how to report problems. A structured report makes this far easier.

WCAGwise Pro turns a scan into a branded, client-ready PDF with WCAG 2.2 AA + EAA mapping, severity ranking, and plain-language remediation notes — the kind of deliverable agencies hand to clients. See the Pro report option.

Step 7 — Re-test and keep it from regressing

Accessibility decays as sites change. Re-scan after every significant release, bake accessibility into your design and QA process, and re-run manual checks periodically. Compliance is a habit, not a one-time project.

Quick checklist recap

Confirm whether you're in scope under the EAA.
Set WCAG 2.2 AA as your target standard.
Run an automated scan to clear the obvious failures.
Do the manual checks (keyboard, screen reader, alt text, forms, zoom, media).
Fix worst-first by severity and user impact.
Document what you tested, fixed, and have left.
Re-test on every release and prevent regressions.

Start with a free scan

The fastest way to begin is to see where you stand today. Free scanner (coming soon) with WCAGwise, then export an EAA-mapped report when you need to prove the work. Remember: it's an audit aid, not a legal guarantee of compliance.

European Accessibility Act compliance checklist (2026)