Web Accessibility: The EAA and WCAG 2.2

What changed in June 2025

The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. It covers many products and services sold to consumers in the EU, including online shops, banking, e-books, transport ticketing and communication services.

It also applies to companies outside the EU that sell to EU consumers. Microenterprises that provide services, with fewer than 10 staff and annual turnover or balance sheet of no more than €2 million, are exempt. Each EU country sets its own penalties.

Which standard to follow

The Act points to the European standard EN 301 549, which is built on WCAG 2.1 level AA. WCAG 2.2, published by the W3C in October 2023, adds nine new success criteria on top of 2.1, so meeting 2.2 AA also covers 2.1 AA.

Outside Europe, the picture is similar. In the US, courts have applied the ADA to websites, and the Department of Justice's 2024 rule for state and local governments uses WCAG 2.1 AA. Building to WCAG 2.2 AA is the practical target almost everywhere.

The fixes that matter most

Most problems we find on audits come from the same short list:

• Text contrast that is too low, especially light grey on white.
• Pages that can't be used with a keyboard, or hide where the focus is.
• Images without useful alt text, and icon buttons without a label.
• Form fields without labels, and error messages that don't say what to fix.
• Headings used for styling instead of structure.
• Meaning shown by color alone, such as a red border as the only sign of an error.
• Videos without captions.

What WCAG 2.2 adds

Several of the new criteria affect everyday interface design:

• Focus not obscured: sticky headers and cookie banners must not cover the focused element.
• Target size: buttons and links at least 24 × 24 CSS pixels, or with enough space around them.
• Dragging movements: anything done by dragging can also be done with a single click or tap.
• Accessible authentication: no puzzles or memory tests to log in; allow paste and password managers.
• Consistent help and redundant entry: help in the same place on every page, and no typing the same information twice.

Why overlay widgets don't fix it

One-line plugins that promise instant compliance add a toolbar on top of the page, but they don't change the underlying code. Screen reader users often find them get in the way. Real accessibility is built into the design and the code.

Where to start

Run an automated check with Lighthouse or axe; it catches part of the problems quickly. Then test by hand: use the site with only a keyboard, try a screen reader on your key pages, and zoom to 200%. Fix the issues in your design system, not page by page, so every new page starts accessible. Finally, publish an accessibility statement that says what you meet and how people can report a problem.