European Union Member States have had three years to adopt EEA provisions into their own national laws. On June 28, 2025, enforcement of these requirements begins.
We tell you what you need to know about the EEA’s requirements so you can provide great user experience to your audiences of all abilities. Build long-term trust with your commitment to accessibility standards.
Who has to comply with the European Accessibility Act?
The EAA identifies five categories of economic operators that must meet its requirements.
- Manufacturers: Individuals or businesses that market products under their own name or trademark that they either manufacture or have designed and manufactured.
- Authorized representatives: EU-based individuals or businesses authorized through a written agreement to act on behalf of a manufacturer for specific tasks.
- Importers: Individuals or businesses within the EU responsible for placing products from outside the EU onto the EU market for the first time.
- Distributors: Individuals or businesses making products available for distribution, consumption, or use in the EU but are not the manufacturer or importer.
- Service providers: Individuals or businesses offering services to consumers within the EU market.
The EAA has partial exemptions for microenterprises, defined as businesses with fewer than 10 employees AND annual turnover not exceeding EUR 2 million OR and annual balance sheet total not exceeding EUR 2 million.
What do accessibility requirements mean for businesses?
Most digital products and services, including websites and apps, must be accessible to users of all abilities. Businesses need to adopt standardized accessibility requirements in their eligible products and platforms, including in user interface design and digital content delivery.
The scope of accessibility requirements includes visual, auditory, motor, and cognitive disability considerations.
What are the accessibility requirements for consent management?
Accessibility must include all user interactions, which can include consent interfaces like cookie banners. Consent management must be user-friendly via screen readers, with keyboard-only navigation, and other accessibility aids.
Information about data collection and processing, as well as consent choices, must be clear and easily understandable.
Failure to make consent mechanisms accessible risks GDPR violations for invalid consent, illegal discrimination against individuals with disability, and excluding individuals, resulting in loss of their trust and engagement.
What do businesses need to do to be EAA-compliant?
Businesses need to ensure that they are using a consent management platform (CMP) that is updated to current accessibility standards under the EAA. The most recent version of the Web Content Accessibility Guidelines (WCAG) 2.2 meets these standards.
Learn more about web and app accessibility and inclusive design with our WCAG 2.2 guide.
Examples of poor accessibility user experience
Visual design
Poor visual design creates barriers for users with low vision, color blindness, and some motor impairments. Examples include presenting low contrast banners, interactive elements like buttons that are too small or difficult to distinguish from the background, or only using colors to distinguish among options.
Lack of keyboard accessibility
A consent banner that cannot be navigated only using a keyboard, e.g. Tab, Enter, and arrow keys, creates barriers for users relying on assistive technologies or who cannot use a mouse.
Lack of screen reader compatibility
A consent banner that lacks appropriate Accessible Rich Internet Applications (ARIA) labels, role attributes, or alternative text will be incomprehensible or invisible to screen reader users. E.g. a “close” icon that’s just an X with no accessible label won’t be interpreted correctly, making it impossible for visually impaired users to dismiss the banner.
Complex language or confusing choices
Data processing information or consent choices that are vague or use legal jargon or technical language can be difficult to understand. They can prevent users from determining what is being requested and what their options are. If a user doesn’t understand what they might be consenting to, they cannot make informed consent choices.
No Focus Trap or Improper Modal Handling
A consent banner that is modal — a dialog that requires interaction before proceeding — but doesn’t trap focus within it enables users navigating via keyboard or screen reader to tab away to other parts of the site before making a consent choice. This violates both accessibility and valid consent principles.
Important: Customized consent banners need additional accessibility checks, as Usercentrics’ products’ WCAG 2.2 certification only includes pre-defined banner templates.
Tools to test customized consent banners for accessibility
There are a wide variety of tools to enable testing of websites and apps, including consent banners. These are a couple of sources, but we recommend finding tools that best enable you to meet EAA standards.
Web Accessibility Evaluation Tools List from the Web Accessibility Initiative (WAI) provides a variety of tools for automated or manual testing of accessibility on web pages and apps, including both free and paid options.
Usercentrics Consent Management Platforms are certified for the requirements of the current WCAG 2.2 AA guidelines. See our WCAG statement.