The European Accessibility Act
In force since 28 June 2025 across all 27 member states. E-commerce and many digital services must meet WCAG 2.1 AA.
European compliance
UX Psychology for Europe
Two European laws changed what a website is allowed to do, and both of them are about behaviour rather than technology. One requires your site to be usable by people with disabilities. The other bans designs that push people into decisions. I am an Industrial Psychologist who measures both, and who writes the fixes.
- EAA and DSA
- WCAG 2.1 AA
- MSc Psychology
- Writes the fixes
- Works across the EU
2025EAA in force
27Member states
WCAG 2.1AA required
6%DSA maximum fine
What changed
Two laws, and what each one asks of you
It applies wherever you are
The test is whether you sell to EU consumers, not where your company is registered. A UK, US or Pakistani business selling into the EU is inside it.
The DSA bans dark patterns
Confusing consent, aggressive pop-ups and misleading choice architecture are prohibited, with penalties up to 6% of global turnover.
Enforcement is not theoretical
The first accessibility lawsuits were filed in France, November 2025, other member states are acting through 2026, and DSA regulators have moved from warning letters to fines.
Accessibility is usability
Almost every WCAG failure is also a conversion failure. Text nobody can read outdoors and a form nobody can complete on a keyboard cost you customers before they cost you a fine.
Something to show a regulator
A written record of what was measured, when, and what was fixed. That document is worth having before anybody asks for it.
The detail
What the law actually says
The European Accessibility Act, in plain terms
It has applied since 28 June 2025 in all 27 EU member states. For websites the practical requirement is WCAG 2.1 AA, which is the established international standard for web accessibility.
The part most businesses get wrong is who it covers. It is not about where your company is registered. If you sell online to consumers in the EU, you are inside it — from London, from Denver, or from Karachi.
The microenterprise exemption, and why it is narrower than it sounds
Businesses with fewer than 10 staff and under €2 million turnover are exempt for services. Both conditions have to be true. Growing past either one moves you inside the law, and nothing tells you when that happens.
Fines are set by each member state and they vary widely: from around €60,000 in Ireland to roughly €900,000 in Sweden. The first lawsuits were filed in France, November 2025, with other member states following through 2026.
What actually has to change on a page
In practice, most of the work is a short list, and most sites fail the same handful of items:
- Text with enough contrast to read outdoors on a phone, not only on a designer's monitor
- Every meaningful image described for somebody who cannot see it
- Form fields with real labels, not placeholder text that vanishes when you type
- The whole checkout completable with a keyboard alone
- Headings that form a proper ladder, because that is how a screen reader navigates
- Anything dynamic — carts, filters, modals — announced properly rather than changing silently
Three of those are measured by the free tool on this site, and you can run it right now without paying or leaving an email.
The Digital Services Act and dark patterns
Separately from accessibility, the DSA prohibits deceptive design: consent flows built to be misread, pop-ups designed to be dismissed by accident, and choice architecture that pushes people rather than informs them. Penalties reach 6% of global turnover.
2026 is the year this stopped being advisory. Regulators have moved from warning letters to fines, and the most-cited consumer complaint of the period was brought by a coalition of consumer organisations across 21 countries against a single fast-fashion retailer for exactly these practices.
I have already published an audit of that retailer
One of the forty-seven brand psychology audits on this site takes Shein apart in full, including the mechanisms now at the centre of the complaint. It is free to read. It is also the clearest illustration I can offer of what this kind of analysis looks like before you commission any.
Why a psychologist rather than an accessibility auditor
An accessibility auditor checks the page against a standard, which is necessary and which good software does most of. What software cannot tell you is whether a compliant page is actually usable, or whether a persuasive technique has crossed into the territory the DSA now prohibits. Both of those are judgements about behaviour.
And the two problems overlap far more than people expect. Low contrast fails WCAG and it also loses customers. A form that cannot be completed by keyboard fails WCAG and it also loses the customer who simply found it awkward. Fixing accessibility properly is one of the few compliance jobs that pays for itself in conversions.
Where I can and cannot help
| Position | |
|---|---|
| English-language European markets | Yes — Ireland, the Netherlands, the Nordics, and English-language sites anywhere in the EU |
| Sites in German, French, Spanish, Italian | The measurable checks work in any language. The writing and the copy judgements need a native speaker, and I will say so |
| Legal advice on the EAA or DSA | No. I am not a lawyer. This is measurement and design, and for anything with legal consequence you want both |
| A compliance certificate | Does not exist. Anyone selling you one is selling you a document, not compliance |
| Written evidence of what was measured | Yes, and that is genuinely useful to have on file |
That last distinction matters. There is no such thing as being certified EAA-compliant, and vendors implying otherwise are describing their own paperwork. What exists is a page that meets the standard and a record showing how you know.
Three of the commonest accessibility failures — contrast, missing image descriptions and a broken heading structure — are in the free tool on this site. Run it on your own page before you talk to anybody.
Run the free audit toolWhat it costs
European engagements
Fixed price and fixed scope, in USD or EUR.
Accessibility check
$499 /site
Where you stand against WCAG 2.1 AA
- Key pages measured against the standard
- Failures ranked by how many people they affect
- Keyboard-only walkthrough of your checkout
- A written record with dates
- 7 working days
Accessibility and dark patterns
$999 /site
Both laws in one piece of work
- Everything in the accessibility check
- Consent flows and choice architecture reviewed against the DSA
- Anything sitting close to the line, named
- Conversion cost of each fix, not just the compliance cost
- 45-minute walkthrough call
- 10 working days
Audit and fix
$1,999 /project
Measured, then repaired
- Everything above
- The fixes written into your site
- Re-measured afterwards, with the evidence
- 30 days of follow-up questions
FAQs
European Questions
Does the EAA apply to me if I am not in the EU?
If you sell online to consumers in the EU, yes. The test is your customers, not your company registration. A business in the UK, the US or anywhere else selling into the EU is inside it.
What if I am a very small business?
There is an exemption for microenterprises providing services: fewer than 10 staff and under €2 million turnover. Both conditions have to hold. It is worth knowing that growing past either one moves you inside the law without anybody telling you.
Can you make me legally compliant?
I can measure your site against WCAG 2.1 AA, tell you exactly what fails, fix it, and give you a dated written record. I am not a lawyer and I will not pretend a report is a legal opinion. For anything with real exposure you want both.
Is there a certificate?
No, and be careful with anybody offering one. There is no EAA certification scheme. What exists is a site that meets the standard and evidence of how you know it does.
Do you work in languages other than English?
The measurable checks are language-independent and I run them on any site. Judgements about copy and tone need a native speaker, and on a German or French site I would say so rather than guess.
Will fixing accessibility hurt my design?
Almost never. Most of the work is contrast, labels, keyboard order and structure, none of which is visible to a sighted mouse user. Where it does change something visible, it is usually because the original was hard to read for everybody.
Two laws, one piece of work
Accessibility and dark patterns measured together, because they are the same page and the same visitor.