European Accessibility Act enforcement is coming. Here’s what you need to know

A hot topic in many of my recent client calls has been the legal updates and upcoming enforcement of the European Accessibility Act (EAA) in every member state of the European Union (EU). However, as is customary with intense legal requirements, it’s easy to miss what this enforcement means to your role in a company.

The EAA aims to standardize the accessibility of goods and services for people with disabilities by defining requirements for critical products and services (think computers, smartphones, digital tools) to be made more accessible and usable for all individuals, promoting inclusivity and equal access.

Road to the European Accessibility Act 

Chart detailing the timeline of the European Accessibility Act from inception to enforcement.

Don’t get lost in the endless blogs and directives about preparing theoretically with paid audits right before enactment. The clock is ticking, and being proactive is the only way to avoid hefty fines and penalties for non-compliance. Here are the major notes:

  • Any contracts created in the EU after 28 June 2025 must meet the accessibility requirements of the directive.
  • Each country enforcing the EAA must validate its enforcement every five years. It is not a one-time check.
  • Service contracts that did not legally require accessibility at the time of signing (before June 2025) do not need to be accessible until June 2030.

What does this mean for a VP of Product? 

As a senior executive overseeing product strategy and development, the VP of Product must ensure that the products and services they develop comply with the accessibility standards outlined in the European Accessibility Act. 

The VP of Product must work closely with product managers, designers, and engineers to incorporate accessibility features and improvements into the company’s offerings. The VP of Product will need to ensure that their product teams are adequately trained in accessibility best practices and understand the requirements outlined in the legislation. This may involve organizing workshops, hiring accessibility experts, or partnering with external consultants to build the necessary expertise.

VPs must stay informed about updates to accessibility regulations and ensure ongoing compliance with any changes through tracking metrics related to accessibility improvements, addressing user feedback, and providing regular updates to relevant authorities and stakeholders.


What project managers should do ASAP

If you are a product manager for a mobile application or website in the EU, there are five steps you need to do to comply with the EAA directive and each EU state’s law:

  1. Test against the European standards EN 301 549
  2.  Complete the EN 301 549 Voluntary Product Accessibility Template (VPAT) to have an Accessibility Conformance Report (ACR)
  3.  Form an action plan for remediation for the issues found by the ACR
  4.  Follow the action plan provided by the work in step 3 to reduce accessibility issues in your products; this can include training or 3rd party validation of fixes implemented.
  5.  Repeat the previous four steps as a continuous improvement for your product(s)

The main point: look at your digital assets and check their accessibility for users against the standards. Product managers, and VPs of product, all the way up to the C-suite, will be legally and financially responsible for ensuring continuous compliance with the EAA.