Advice on the Digital
Accessibility Act

New European Accessibility Act

On 28 June 2025, the European Accessibility Act (EAA) entered into force. This law requires organisations to make digital products and services such as websites, apps, payment terminals, and digital documents accessible to people with disabilities. Companies that fail to meet these accessibility requirements may face fines of up to € 900,000 per violation or even 1% of annual turnover.

For many businesses, digital accessibility is still a blind spot. At the same time, inspections are increasing at both national and European level. The obligations do not apply only to large organisations: SMEs that offer digital services often also fall within the scope of the EAA.

Our IT Audit & Risk Services team supports entrepreneurs by assessing whether they meet the legal requirements, offering advice, and providing guidance throughout the process.

How we support entrepreneurs in practice:

  • Information and interpretation of the legislation: what does the EAA mean for your organisation in concrete terms? We provide clear explanations tailored to your situation.
  • Development of an action plan and WCAG requirements: you receive a clear action plan and an overview of the applicable requirements (WCAG 2.1 Level A & Level AA) specific to your digital products.
  • Guidance and project management: we support you step by step on the road to compliance, including prioritisation, technical coordination, and planning.
  • Advice on pragmatic solutions: practical recommendations aligned with your budget, development capacity, and target audiences.
  • Preparation for future-proof compliance: we help your organisation meet today’s requirements and stay compliant as regulations evolve. This ensures you remain in control.

Digital Accessibility: what it means for businesses

Companies that fail to comply with the EAA after 28 June 2025 risk significant fines. In addition to reputational damage, regulators can impose penalties of up to € 900,000 per violation or even 1% of annual turnover, depending on the sector and type of infringement. This is a law to take seriously.

What exactly does the new law require? The EAA obliges companies to design digital products and services in a way that makes them accessible to people with disabilities. This includes requirements such as clear readability, navigation without a mouse, captions for videos, and understandable error messages.

There are some nuances and exceptions. The requirements currently apply to all new products and services launched after 28 June 2025, including websites, webshops, apps, and e-books. Existing services are subject to a transition period. Companies with fewer than 10 employees and less than €2 million in annual turnover are generally exempt, unless they provide public services or products of critical importance.

Key points of the European Accessibility Act (EAA):

  • Digital accessibility must be considered from the design stage.
  • Existing systems must be updated to meet the new requirements.
  • Digital products must comply with the Web Content Accessibility Guidelines (WCAG).
  • Non-compliance may result in fines.

Let the new legislation work for you

The EAA affects not only large organisations but also SMEs. As a director or business owner, it is wise to consider both the implications and the opportunities this legislation offers. With increasing national and European regulations on digital accessibility, it is important not only to comply with current standards but also to be prepared for future developments.

We understand that legislation can feel like a burden, but the EAA also presents real opportunities for SMEs. By making your products and services accessible to a wider audience, you can expand your reach and strengthen your market position. Customers and partners value companies that take inclusivity seriously, which directly contributes to customer satisfaction and loyalty. Early compliance with the EAA also makes your organisation more agile and future-proof: you stay ahead of new developments and avoid unexpected adaptation costs later.

Our Approach

We help your business identify necessary adjustments, advise on pragmatic solutions, and guide implementation. This ensures you are well-prepared for the EAA, leverage the opportunities of digitalisation and inclusivity, and minimise compliance and reputational risks.

We follow a structured four-phase approach:

1. Inventory and Kick-Off

  • Explanation of the legislation
  • Analysis of your digital assets
  • Assessment against WCAG guidelines

2. Action plan and standards framework

  • Define concrete actions
  • Provide insight into obligations, timelines, and impact

3. Determine next steps

  • Prioritisation and defining minimum and desired standards
  • Monitoring progress and supporting prioritisation

4. Optional: consolidation and follow-up

  • Post-implementation evaluation
  • Annual reassessment and advice on future changes

You will receive a compliance control framework based on WCAG 2.1, with your digital products and services assessed at Levels A and AA. This is followed by a report highlighting risks and recommendations, enabling you to take concrete next steps.

Benefits for Your Business

Companies that invest in digital accessibility now strengthen their services and build trust with customers, employees, and partners. Let the new legislation work for you. Our approach delivers:

  • Timely compliance with the EAA, avoiding fines, sanctions, or reputational damage
  • Digital products and services accessible to a broader audience
  • Demonstrated social responsibility and commitment to inclusivity
  • Enhanced customer experience, brand value, and competitive position
  • Proactive preparation for future digital legislation
  • Clear guidance and support, helping you navigate complex requirements

Want to know more about digital accessibility?

Would you like to know more about the new legislation and the requirements your digital products must meet? Leave your contact details here, and one of our advisors will get in touch with you.

drs. M.J. (Ries) van der Borst RA RE

director it audit & risk services

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