How to get started with compliance with the EAA

3-part series on The European Accessibility Act (EAA)

• Part 1: Introduction to the EAA
• Part 2: Top 10 questions about the EAA
• Part 3: How to get started with compliance with the EAA

The European Accessibility Act (EAA) is a legislative measure requiring all 27 EU member states to incorporate its provisions into their national laws, with enforcement set to begin on 28 June 2025. This directive (2019/882) seeks to enhance the accessibility of products and services for individuals with disabilities and older adults across the European Union.

1. Hire an Accessibility Specialist

When you're getting started, accessibility can seem overwhelming and complicated. Bring in an Accessibility specialist to guide you through the process — and keep them!

Multiple job postings have been making the rounds lately and they're all temporary positions. Accessibility is more than a compliance effort with the latest legislation, it's about continuously creating inclusive experiences for your customers.

Accessibility should NOT be a temporary project to comply with the EAA. It should be an ongoing effort and an integral part of your processes.

In-house Accessibility specialist(s)

The benefit of hiring in-house Accessibility specialist(s) is that accessibility becomes an integral part of the daily workflow and is embedded into the process, ensuring a stronger focus and smoother collaboration with the team.

What to look for when recruiting for an in-house Accessibility specialist (not limited to):

1. At least one Accessibility qualification from a trusted institution, for example, IAAP, W3C or Deque University
2. Solid knowledge of the Web Content Accessibility Guidelines (WCAG)
3. Experience with Assistive Technologies such as screen readers
4. Experience testing website accessibility with screen readers, colour contrast analysers, keyboards, accessibility browser extensions, and developer tools.
5. Knowledgable on Voluntary Product Accessibility Templates (VPATs) and Accessibility Conformance Reports (ACR)
6. Solid knowledge of Web Accessibility Initiative – Accessible Rich Internet Applications (WAI-ARIA) (Required for a technical accessibility role)

External Accessibility consultancies

The benefits of hiring an external Accessibility consultancy include a wide range of services such as function-specific team training (for designers and developers), comprehensive audits, and usability testing with disabled users. You can also combine the expertise of an in-house Accessibility specialist with the broader support of an external consultancy for a more holistic approach.

Here is a list of established Accessibility and Inclusive Design consultancies:

1. Deque Systems
2. Fable
3. Intopia
4. Level Access
5. Nomensa

2. Understand the EAA

Together with your Accessibility specialist, familiarise yourself with the EAA’s requirements and how they impact your product or service.

While an Accessibility specialist is knowledgeable in legislation and standards, they aren't legal experts in digital laws. For complex or unclear issues, consulting a legal professional is recommended. Many external consultancies have in-house legal experts who can guide in these areas.

3. Conduct an audit

The Accessibility specialist will perform an audit of your product or service based on WCAG 2.2 level AA to assess its current accessibility status. This process involves using automated tools, manual testing, and usability tests with disabled users to ensure thorough evaluation.

The outcome of the audit will provide a detailed list of issues based on severity:

1. Critical - prevent users from completing key tasks (blockers)
2. High - does not prevent users from completing tasks but significantly affects the usability
3. Medium - impacts the usability but users can use workarounds
4. Low - does not significantly affect usability but needs to be addressed for full compliance

Other factors that can impact the priorities in the list are:

• Alignment with WCAG conformance levels (level A, AA and AAA)
• Frequency of occurrence
• Technical complexity
• Legal risk

4. Develop a roadmap & implement

Based on the audit results, collaborate with the Accessibility specialist, product, and technical teams to develop a roadmap for addressing accessibility issues.

The Accessibility specialist can explain the issues in detail to the teams, advise on how to these group issues for implementation and focus on low-effort and high-impact issues.

Thorough testing is essential to ensure that these issues are correctly resolved. This can be achieved through a combination of automated tools and manual testing, involving both the Accessibility specialist and the Quality Assurance testers.

5. Create an Accessibility Conformance Report (ACR)

After the audit, the Accessibility specialist will prepare an Accessibility Conformance Report (ACR) using a Voluntary Product Accessibility Template (VPAT).

This online document will be integrated into your product and will serve as a demonstration of compliance. It will include contact details for the Accessibility representatives and outline plans for improving the product and ensuring future compliance, especially in cases of partial compliance at the time of the report.

6. Focus on the future

Accessibility is not a one-off project aimed at achieving temporary compliance. If you're regularly releasing new features or services in your product, there's a possibility you might introduce new accessibility issues along the way.

Instead, accessibility should be viewed as an ongoing commitment in your product development process. Each phase plays a crucial role:

1. Research & discovery - Ensure that your research efforts are inclusive by involving disabled users.
2. Ideation & Design - Use accessibility plug-ins and an Accessibility design checklist to guide designs
3. Development & implementation - Follow W3C and WAI-ARIA guidelines to ensure elements are correctly coded—no shortcuts! Include accessibility requirements in your Definition of Done (DoD).
4. Testing & Evaluation - Conduct continuous audits to assess and maintain accessibility.
5. Build an inclusive team - Actively recruit team members with disabilities to bring diverse perspectives to the table.

7. Foster a culture of inclusivity

Ensure your team is well-informed about accessibility best practices and the significance of continuous compliance. Regular training sessions, workshops, and resources can help foster a culture of inclusivity, empowering everyone to contribute to making your products and services accessible to all. Encourage open discussions about accessibility challenges and solutions, so your team can collaboratively work towards creating a more inclusive environment.

Useful links

Trusted Accessibility courses and training:

• Digital Accessibility Foundations Free Online Course (free)
• Deque University (paid)
• Level Access Academy and training (paid)

Established Accessibility consultancies:

• Deque Systems
• Fable
• Intopia
• Level Access
• Nomensa

European Accessibility guidelines and standards:

• Web Content Accessibility Guidelines (WCAG)
• Web Accessibility Initiative – Accessible Rich Internet Applications (WAI-ARIA)
• Web Accessibility Directive (WAD)
• The European Accessibility Act (EAA)
• European technical standard EN 301 549

Disclaimer: I am not a legal expert and cannot provide legal advice on the European Accessibility Act (EAA). The information in this article is intended to be informative only. Consult with your legal team or a legal professional who specialises in digital legislation for detailed guidance.