It’s important to recognise at the outset that businesses which operate solely within the UK are not directly subject to the European Accessibility Act (EAA), EAA.
While the UK is no longer a member of the European Union (EU), the EAA however still carries important implications for UK businesses, particularly those who operate in, or provide goods or services to the EU, or have plans to do so.
Roughly 16 million people in the UK have a disability. These include, but are not limited to:
- Visual impairments (blindness, low vision, colour blindness).
- Hearing impairments (deafness, hard of hearing).
- Motor disabilities (dyspraxia, limb difference, limited fine motor control, paralysis).
- Cognitive and learning disabilities (autism, dyslexia, attention deficit disorders).
Businesses with fewer than 10 employees and an annual turnover below €2 million are defined as “micro-enterprises” and are exempt from the service requirements, but not product requirements, under the EAA. This means that while they may not need to meet specific service accessibility standards like website or customer service accessibility, they still need to ensure their products, like e-books or software, comply with accessibility requirements.
In addition, if meeting the EAA requirements would impose a “disproportionate burden” on a business, and if it can demonstrate that compliance is not reasonably possible, an exception may apply. Be aware that a business can obviously move from having nine employees to ten very quickly, and there is no grace period available for micro-enterprises transitioning in this way.
Scope:
- The EAA applies to digital services and products such as websites, mobile applications, e-books, e-commerce platforms, ATMs, ticketing machines, computers, smartphones, banking services, and transport systems.
- Business with 10 or more employees or a turnover exceeding €2 million are required to comply fully with the EEA.
- The EEA applies to any business that trades in the EU or has headquarters outside the EU (for example in the UK) but is supplying goods and/or services within the EU.
Standards:
- The EEA mandates conformance with the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA, which are the internationally recognised standard for digital accessibility.
- In the UK, the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 require public sector websites and mobile applications to conform to WCAG. This means websites must be perceivable, operable, understandable, and robust for all users, including those with disabilities.
Timing:
- The EAA came in to force on 28 June 2025, though it only applies to new digital products or services.
- Pre-existing products/services that were on the market or in use before 28 June 2025 have until 28 June 2030 before they need to be removed or made compliant.
Penalties:
- Non-compliance could result in substantial financial penalties, including fines of up to €20 million or 4% of global annual turnover. Of course there is also a risk of reputational damage.
For UK Businesses Operating in the EU
UK companies that sell products or provide services to EU consumers must comply with the EAA, regardless of where the business is physically located. This includes:
- E-commerce platforms targeting EU customers.
- Mobile and web applications accessible in EU territories.
- Financial, transport, and communication services used by EU citizens.
- Hardware and software marketed in EU member states.
Even if a company is headquartered in the UK, it is still legally responsible for complying with the EAA if it engages with EU consumers.
For UK Businesses Operating Solely in the UK
Businesses operating only within the UK are not subject to the EAA. The UK currently relies on the Equality Act 2010, which requires “reasonable adjustments” for people with disabilities but does not specify technical standards like the EAA does.
Conclusion
The EEA is not part of UK law, but it directly affects UK businesses engaging with EU markets. It also potentially offers a blueprint for businesses seeking to future-proof their digital presence. As global standards converge and awareness increases, UK legislation may, over time, follow the EU’s lead.
Businesses that act now will be ahead of the curve and less likely to have to do things at the last-minute.
Clearly, in terms of optional compliance, what a business can do is going to be dictated to by their resources, however all UK businesses should be aware they do already have a duty to make reasonable adjustments under the Equality Act 2010.