What's New in the European Accessibility Act (EAA) That WCAG 2.2 Doesn't Cover?
The European Accessibility Act (EAA) is poised to transform digital and physical accessibility across the European Union. While many organizations are already familiar with the Web Content Accessibility Guidelines (WCAG) 2.2, the EAA brings a broader legal mandate and expanded scope that WCAG doesn’t cover. So, what exactly is new in the EAA, and how does it go beyond WCAG?
Let’s break it down.
🌐 WCAG 2.2: Great for the Web, But Not the Whole Picture
WCAG 2.2 is a technical standard developed by the W3C to make web content more accessible to people with disabilities. It focuses on principles like perceivability, operability, understandability, and robustness (POUR). It’s widely adopted and forms the basis of many digital accessibility policies around the world.
However, WCAG is not a law, and it only applies to digital content—websites, documents, apps—not physical products or end-to-end services.
🚀 EAA: Accessibility With Legal Power
The European Accessibility Act, which must be implemented by EU member states by June 28, 2025, is a legally binding directive. It’s designed to ensure accessibility across a wide range of products and services—not just websites.
Key difference?
EAA is about full-service accessibility across digital, physical, and communication touchpoints.
🔍 EAA vs WCAG 2.2: What’s New?
Here’s what the EAA introduces that WCAG 2.2 does not:
1. Wider Scope: Includes Hardware and Services
EAA applies to a much broader set of industries and technologies, including:
ATMs, ticket machines, check-in kiosks
Smartphones, tablets, e-readers
Transport booking systems
Online banking and e-commerce
E-books and reading software
WCAG focuses primarily on web content and doesn’t cover physical products.
2. Legal Compliance and Penalties
While WCAG is advisory unless legislated, EAA is enforceable by law. Failure to comply can result in:
Fines
Market withdrawal
Reputational damage
In other words: EAA has teeth.
3. Product Lifecycle Accessibility
The EAA mandates accessibility not just at the design or user interface level, but across the entire lifecycle:
Design and manufacturing
Instructions and packaging
Support and servicing
WCAG doesn't address any of this.
4. Accessible Communication
The EAA requires that:
All service-related communication (billing, contracts, customer support) must be accessible.
Communication must support multiple formats (e.g., braille, large print, audio).
WCAG only touches on content-level alternatives—not service communication infrastructure.
5. Interoperability With Assistive Technologies
EAA mandates that products and services must work with existing assistive tools—screen readers, braille displays, hearing aids, and more.
WCAG assumes assistive tech use but does not demand technical interoperability.
6. Service Journey Accessibility
EAA considers the entire user journey, especially for services like:
Buying a train ticket
Booking online travel
Accessing an e-book
Completing a bank transaction
This end-to-end experience must be accessible—including hardware, software, and human interaction.
WCAG is focused on web/app screens, not full-service flows.
🧾 Summary Table: EAA vs WCAG 2.2
| Feature/Requirement | European Accessibility Act (EAA) | WCAG 2.2 |
|---|---|---|
| Hardware accessibility (kiosks, devices) | ✅ | ❌ |
| Legally enforceable with penalties | ✅ | ❌ |
| Product lifecycle inclusion | ✅ | ❌ |
| Customer support and communication accessibility | ✅ | ❌ |
| Assistive technology interoperability | ✅ | ❌ |
| Covers mobile/web UX | ✅ | ✅ |
| E-commerce, transport, banking services | ✅ | ❌ |
🛠 What Standards Does EAA Reference?
The EAA refers to the EN 301 549 standard, which includes WCAG (currently WCAG 2.1 AA) but expands on it with technical requirements for:
Software
Hardware
Documentation
Support services
This makes EN 301 549 the go-to benchmark for EAA compliance, especially in the digital domain.
📅 What’s the Deadline?
Businesses offering products or services in the EU must be compliant by June 28, 2025. That includes:
Public and private sector organizations
E-commerce sites and apps
Publishers and hardware providers
🧩 Final Thoughts
While WCAG 2.2 is essential for digital accessibility, the European Accessibility Act elevates the stakes. It moves accessibility from a “nice-to-have” technical practice to a legal requirement that spans digital, physical, and communicative domains.
If your organization operates in the EU—or even serves EU citizens—now’s the time to audit not just your website, but your entire service chain for accessibility.
Need help preparing for EAA?
Let me know in comments if you want a checklist, gap analysis between WCAG and EAA.
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