DOMAIN:ACCESSIBILITY:EAA_REQUIREMENTS¶
OWNER: julian ALSO_USED_BY: alexander, floris, floor, antje UPDATED: 2026-03-26 SCOPE: European Accessibility Act — legal obligations, scope, deadlines, penalties, developer vs client responsibility REGULATION: Directive (EU) 2019/882 TECHNICAL_STANDARD: EN 301 549 v3.2.1 (v4.1.1 with WCAG 2.2 expected 2026)
EAA:OVERVIEW¶
WHAT: the European Accessibility Act is an EU directive requiring accessibility for consumer-facing products and services STATUS: enforceable since June 28, 2025 — this is NOT upcoming, it is NOW active law TYPE: directive (not regulation) — each EU member state transposed into national law by June 2022 CONSEQUENCE: penalties and enforcement mechanisms vary by member state EXTRATERRITORIAL: applies to ANY business placing covered products/services on the EU market, including non-EU companies
CRITICAL: GE builds SaaS for EU-based SME clients — every client project is in scope unless the client qualifies for microenterprise exemption
EAA:COVERED_PRODUCTS_AND_SERVICES¶
DIGITAL_SERVICES (directly relevant to GE)¶
SERVICE: e-commerce websites and mobile applications SERVICE: banking and financial service interfaces SERVICE: telecommunications services SERVICE: e-books and e-reader applications SERVICE: audio-visual media services SERVICE: transport services (ticketing, check-in, real-time travel information) SERVICE: all SaaS accessible to EU consumers (B2C and B2B with end users)
HARDWARE_PRODUCTS (less relevant but may apply to client projects)¶
PRODUCT: computers and operating systems PRODUCT: ATMs, ticketing machines, check-in machines PRODUCT: smartphones and tablets PRODUCT: e-readers PRODUCT: consumer terminal equipment for telephony and audiovisual media
SCOPE_TEST¶
ASK: does the product or service fall into one of the above categories? ASK: does it serve EU consumers (even indirectly)? ASK: is the client a microenterprise? (see exemption below) IF all three are YES/YES/NO THEN the EAA applies
EAA:MICROENTERPRISE_EXEMPTION¶
DEFINITION: fewer than 10 employees AND annual turnover below EUR 2 million CRITICAL: both conditions must be met — a company with 8 employees and EUR 5M turnover is NOT exempt WARNING: most Dutch SME clients do NOT qualify for this exemption WARNING: even exempt microenterprises must comply if they receive public funding for the product
ASSESSMENT_RULE: julian verifies client exemption status during project onboarding ASSESSMENT_RULE: if client claims exemption, request KVK extract to verify headcount and turnover ASSESSMENT_RULE: document exemption status in project compliance file
EAA:COMPLIANCE_DEADLINES¶
NEW_PRODUCTS_AND_SERVICES¶
DEADLINE: June 28, 2025 — must comply from day one STATUS: ACTIVE — all GE projects launched after this date must be accessible APPLIES_TO: any new website, app, or SaaS product placed on the EU market
EXISTING_SERVICES¶
DEADLINE: June 28, 2030 — transitional period for services already on the market before June 2025 NOTE: "already on the market" means the service was live and available to consumers before June 28, 2025 WARNING: modifications to existing services may trigger immediate compliance requirement WARNING: the 2030 deadline does NOT mean "do nothing until 2030" — regulators expect demonstrable progress
GE_POLICY¶
RULE: all new GE projects comply from day one — no transitional period reliance RULE: client projects with existing services get accessibility roadmap in first sprint RULE: julian reviews every project for EAA applicability during kickoff
EAA:TECHNICAL_STANDARD — EN 301 549¶
WHAT_IS_EN_301_549¶
DEFINITION: the harmonised European standard for ICT accessibility VERSION: currently v3.2.1, based on WCAG 2.1 Level AA UPCOMING: v4.1.1 will incorporate WCAG 2.2 — expected 2026 RELATIONSHIP: meeting EN 301 549 creates a "presumption of conformity" with the EAA
BEYOND_WCAG¶
CRITICAL: meeting WCAG 2.1 AA alone does NOT ensure EN 301 549 compliance
ADDITIONAL: Chapter 5 — closed functionality (kiosks, embedded systems without assistive tech) ADDITIONAL: Chapter 6 — ICT with two-way voice communication (VoIP, video calling, real-time text) ADDITIONAL: Chapter 7 — ICT with video capabilities (captions, audio description, player controls) ADDITIONAL: Chapter 8 — hardware accessibility ADDITIONAL: Chapter 9 — web accessibility (maps to WCAG 2.1 AA) ADDITIONAL: Chapter 10 — non-web documents (PDFs, office documents) ADDITIONAL: Chapter 11 — software accessibility (native apps, platform accessibility services) ADDITIONAL: Chapter 12 — documentation and support services ADDITIONAL: Chapter 13 — ICT providing relay or emergency service access ADDITIONAL: Clause 4 — functional performance statements (without vision, limited vision, without hearing, limited manipulation, limited reach, minimise photosensitive seizure triggers)
GE_RELEVANT_CHAPTERS¶
PRIMARY: Chapter 9 (web) — every web project PRIMARY: Chapter 11 (software) — iOS/native app projects PRIMARY: Chapter 12 (documentation/support) — help systems, user manuals SECONDARY: Chapter 10 (documents) — if project generates PDFs or exports SECONDARY: Chapter 7 (video) — if project includes media playback
EAA:PENALTIES¶
EU_FRAMEWORK¶
RANGE: up to EUR 100,000 or 4% of annual revenue (varies by member state) ENFORCEMENT: national enforcement authorities (NEAs) in each member state MECHANISMS: enforcement notices, corrective orders, market access restrictions, fines, criminal charges
MEMBER_STATE_EXAMPLES¶
GERMANY: fines up to EUR 50,000 for non-compliant products IRELAND: directors may face up to 6 months imprisonment for persistent non-compliance NETHERLANDS: ACM (Autoriteit Consument & Markt) enforces — fines and corrective orders FRANCE: fines up to EUR 50,000 per infringement, public naming SPAIN: fines ranging EUR 301 to EUR 1,000,000 depending on severity
ENFORCEMENT_APPROACH¶
REALITY: regulators look for demonstrable good faith — documented, ongoing progress REALITY: "perfection on day one" is NOT expected — systematic approach IS expected REALITY: complaint-driven enforcement is most common in early years RISK: disability advocacy organizations actively file complaints — this is not theoretical RISK: competitors can report non-compliance as unfair market advantage
EAA:RESPONSIBILITY_SPLIT — GE vs CLIENT¶
GE_AS_DEVELOPER¶
RESPONSIBLE_FOR: building accessible code that meets EN 301 549 RESPONSIBLE_FOR: documenting accessibility decisions and known limitations RESPONSIBLE_FOR: providing accessibility testing reports RESPONSIBLE_FOR: flagging when client content or requirements would violate accessibility standards RESPONSIBLE_FOR: training clients on accessible content management NOT_RESPONSIBLE_FOR: client's ongoing content accessibility (after handover) NOT_RESPONSIBLE_FOR: client's organizational compliance measures (training, monitoring)
CLIENT_AS_SERVICE_PROVIDER¶
RESPONSIBLE_FOR: maintaining accessibility of content they publish RESPONSIBLE_FOR: organizational compliance (staff training, accessibility policy) RESPONSIBLE_FOR: monitoring ongoing accessibility RESPONSIBLE_FOR: handling consumer complaints about accessibility RESPONSIBLE_FOR: claiming disproportionate burden exemption (if applicable) RESPONSIBLE_FOR: reporting to national enforcement authority (if required)
CONTRACT_IMPLICATIONS¶
RULE: eric includes accessibility clause in every GE client contract RULE: clause specifies GE delivers to EN 301 549 standard RULE: clause specifies client responsibility for content accessibility post-handover RULE: clause specifies GE provides accessibility testing report at each delivery milestone RULE: clause specifies GE is NOT liable for client-authored content that fails accessibility
EAA:DOCUMENTATION_REQUIREMENTS¶
CONFORMITY_ASSESSMENT¶
REQUIREMENT: technical documentation demonstrating how product/service meets accessibility requirements REQUIREMENT: documentation must be kept for 5 years after product/service last placed on market REQUIREMENT: documentation must be provided to national authorities on request
WHAT_GE_DELIVERS¶
DELIVERABLE: accessibility conformance report (ACR) per EN 301 549 DELIVERABLE: VPAT (Voluntary Product Accessibility Template) — EU edition DELIVERABLE: automated test results (axe-core, Lighthouse) DELIVERABLE: manual testing summary (keyboard, screen reader, visual) DELIVERABLE: known limitations and remediation roadmap DELIVERABLE: accessibility statement for client's website (template provided)
ACCESSIBILITY_STATEMENT¶
MANDATORY: must be published on accessible page of the service CONTENTS: conformance status (full, partial, non-conformant) CONTENTS: non-accessible content and reasons CONTENTS: date of assessment CONTENTS: assessment method (self-evaluation, external audit, automated + manual) CONTENTS: feedback mechanism for users to report barriers CONTENTS: link to national enforcement authority
EAA:DISPROPORTIONATE_BURDEN¶
WHAT_IT_IS¶
DEFINITION: exemption from specific requirements when compliance would impose undue financial or organizational hardship WARNING: this is NOT a blanket exemption — it applies per requirement, not per product WARNING: must be documented and justified — regulators will audit WARNING: even with exemption, must maximize accessibility where possible
ASSESSMENT_CRITERIA¶
FACTOR: net cost of compliance vs financial resources of the organization FACTOR: estimated benefits for persons with disabilities FACTOR: frequency and duration of use of the product/service FACTOR: size and resources of the economic operator
GE_POSITION¶
RULE: GE never claims disproportionate burden on behalf of clients RULE: if client requests disproportionate burden claim, julian advises but client must document and file RULE: GE builds accessible by default — disproportionate burden should never be needed for GE-built products
EAA:GE_COMPLIANCE_WORKFLOW¶
PROJECT_KICKOFF¶
STEP: julian reviews project scope for EAA applicability STEP: julian verifies client exemption status (microenterprise check) STEP: julian documents applicable EN 301 549 chapters in project compliance file STEP: alexander incorporates accessibility requirements into DESIGN.md
DURING_DEVELOPMENT¶
STEP: automated accessibility tests run in CI (axe-core, pa11y) STEP: developers follow component-patterns.md for accessible implementations STEP: antje runs manual testing per sprint (keyboard, screen reader) STEP: julian reviews accessibility issues weekly
PRE_RELEASE¶
STEP: full accessibility audit (automated + manual + screen reader) STEP: julian produces conformance report STEP: julian drafts accessibility statement for client's service STEP: remediation of critical issues before release STEP: known limitations documented with remediation timeline
POST_RELEASE¶
STEP: client receives accessibility documentation package STEP: client briefed on content accessibility responsibilities STEP: quarterly accessibility monitoring (if support contract active)
EAA:AGENT_INSTRUCTIONS¶
FOR julian: - you are the compliance owner for EAA across all GE projects - verify EAA applicability at every project kickoff - produce conformance reports at every delivery milestone - track EN 301 549 version updates — when v4.1.1 drops, update all GE standards - coordinate with alexander on design accessibility, antje on testing
FOR alexander: - every DESIGN.md must include accessibility requirements - color contrast ratios must be specified in design tokens - touch target sizes must be specified (minimum 24x24 CSS pixels) - focus indicators must be designed, not left to browser defaults
FOR floris, floor: - implement to EN 301 549 Chapter 9 (web) or Chapter 11 (software) - automated accessibility tests must pass before PR merge - see component-patterns.md for implementation patterns
FOR antje: - test against EN 301 549, not just WCAG - include screen reader testing in every sprint - document test results in standardized format for julian's conformance report
READ_ALSO: domains/accessibility/wcag-2-2.md, domains/accessibility/testing-methodology.md, domains/eu-regulation/index.md, domains/compliance-frameworks/index.md