Guide
EAA vs ADA: selling in both the EU and US
Last updated: 29 June 2026
If you sell to customers on both sides of the Atlantic, you've probably wondered whether you need to do accessibility work twice — once for Europe's Accessibility Act and once for America's ADA. The reassuring answer: the two laws differ in scope and enforcement, but they converge on the same technical standard, so one well-done accessibility effort covers both. Here's how they compare. (General information, not legal advice.)
What each one is
- EAA (European Accessibility Act) — EU law (Directive 2019/882), mandatory since 28 June 2025 for many consumer products and services sold in the EU. Enforced by individual member states, each with its own penalties. See our EAA checklist.
- ADA (Americans with Disabilities Act) — US civil-rights law from 1990. It doesn't name websites, but the Department of Justice and many courts treat the sites of businesses as covered, and web-accessibility lawsuits are common. See our ADA guide.
How they differ
- Trigger: the EAA is proactive regulation with a hard date; ADA web obligations are driven more by litigation and DOJ position than a single web rulebook.
- Scope: the EAA enumerates specific products/services (e-commerce, banking, transport, e-books, etc.); the ADA's Title III applies broadly to "places of public accommodation."
- Enforcement: EAA penalties are set per EU member state; ADA exposure typically comes via private lawsuits and settlements in the US.
- Documentation culture: EU buyers may expect conformance to EN 301 549; US procurement often wants a VPAT (and Section 508 for government — see our 508 guide).
What they have in common (the important part)
Both effectively measure web accessibility against the Web Content Accessibility Guidelines at Level AA. The EAA leans on the European standard EN 301 549, which incorporates WCAG; US courts and the DOJ repeatedly reference WCAG AA. So the technical target is the same on both continents. (For the standard-vs-law relationship, see WCAG vs EAA.)
The practical takeaway
Don't run two accessibility programmes. Build and test to WCAG 2.2 AA once, document what you did, and you've covered the technical core of both the EAA and the ADA. Where they diverge is mostly paperwork and process — an accessibility statement for EU users, a VPAT for US procurement — not the underlying fixes.
Start with one scan
Since the target is shared, one audit serves both markets. Scan your site free with WCAGwise to find the WCAG 2.2 AA issues and exactly where they are, then do the manual checks. WCAGwise is an audit aid, not a legal guarantee — but it's the same WCAG yardstick both laws use.