Will your site be accessible on 28 June 2025?

The deadline for EU Member States to transpose the European Accessibility Act (EAA) into national law was 28 June 2022.

Three years later, on 28 June 2025, the directive will officially come into force.

What is the EAA ?

The EAA aims to improve the accessibility of products and services by harmonising regulations across the EU. It therefore applies to existing legislative frameworks specific to each Member State.

What is the aim of this European directive?

Helping the disabled and the elderly :

more accessible products and services at more competitive prices;
fewer barriers to access to transport, education and the labour market;
more career opportunities in accessibility-related sectors.

Offer the various companies present in Europe :

common rules to reduce compliance costs;
A more homogenous European market, facilitating cross-border trade;
more commercial outlets for their accessible products and services.

Technically speaking, what does digital accessibility mean?

The EAA requires compliance with clear technical standards to ensure optimum accessibility. These standards are :

EN 301 549: This is a legal standard in Europe, made mandatory in certain contexts by the European Accessibility Directive (2016/2102). It is based on the WCAG for the web, but adapts and supplements them to meet the EU’s legal and technical needs. It is not limited to digital aspects.

WCAG (2.1, 2.2): This is an international technical recommendation, not a law in itself. It focuses exclusively on web content, proposing precise criteria (such as colour contrasts, keyboard navigation, etc.) for three levels of compliance: A, AA and AAA.

The public sector is no longer the only one concerned

In France, public services have had to comply with strict digital accessibility requirements since 2005. European directives and WCAG standards have been transposed into the Référentiel Général d’Amélioration de l’Accessibilité (RGAA).

These services concern not only government departments and local authorities, but also general interest organisations (tourism, culture, etc.) and public service providers (public transport, energy and water supply, etc.).

Since 2019, this obligation has been extended to the private sector, including companies with an annual turnover of €250 million, as well as associations working to promote accessibility.

From June 2025, all companies involved in the products and services covered (see next point) will have to comply with these requirements, with the exception of those with fewer than 10 employees or generating less than €2 million in turnover.

In Belgium, the latest federal law on the subject (Law of 19 July 2018) lags behind European requirements and still only enshrines the accessibility of public service bodies’ websites and mobile apps.

What products and services are you targeting?

The EAA covers the products and services that have been identified as being the most important for people with disabilities, while also being the most likely to have different accessibility requirements from one EU country to another. These include:

Passenger transport: buses, trains, boats, planes.
Automatic ticket dispensers and ticketing machines.
Banking and telephone services.
E-commerce sites and other digital platforms.

What are the obligations?

In France, as in Belgium, companies must :

Ensure maximum accessibility of their digital content
Publish an accessibility statement, which must detail :

- the level of accessibility of the site or application ;

- the parts that are not accessible and alternative solutions ;

- planned improvements ;

- the accessibility testing method ;

- contacts for users experiencing accessibility problems.

France is also required to draw up and publish a multi-year plan and an annual action plan.

What are the penalties for non-compliance?

In France

Up to €50,000 fine per inaccessible digital contact point.

Up to an additional €25,000 if there is no declaration of accessibility, no multi-year plan and no action plan.

In Belgium

Sanctions are still under discussion

Elsewhere in Europe

The penalties can be even more severe. In Luxembourg, for example, the law provides for the possibility of banning non-compliant products/services, with penalties of up to €500,000, and €1 million in the event of a repeat offence.

What kind of support?

The companies concerned must now audit their products and services, train their teams and adapt their processes to comply with these requirements.

For some people, this date of 28 June 2025 represents no change in terms of existing accessibility obligations, but it does sound like a reminder that compliance is sometimes too long overdue.

For others, it’s high time to anticipate and plan for the changes that will be needed, and any postponement is likely to increase the cost.