EAA for UK Businesses — Do You Need to Comply? 2026
„Does the European Accessibility Act apply to UK businesses?" That's a question many UK business owners ask since Brexit. The answer is yes — but only if you trade in the EU.
In this guide, we'll explain what the EAA is, who it applies to, and what UK businesses need to do to comply.
📌 Quick Answer — EAA for UK Businesses
The European Accessibility Act (EAA) is an EU law that requires businesses to make their products and services accessible. It applies to UK businesses that offer goods or services in the EU. The EAA requires compliance with EN 301 549 (WCAG 2.1 Level AA). UK businesses that only serve UK customers are not covered by the EAA but must comply with the Equality Act 2010.
✅ Test your website for EAA compliance
Use the free UK ADA checker to scan your website against WCAG 2.2 Level AA (higher than EAA).
Free UK Checker →What is the EAA?
The European Accessibility Act (EAA) is an EU law that requires businesses to make their products and services accessible to people with disabilities. The EAA came into force on 28 June 2025.
The EAA applies to:
- E-commerce websites and mobile apps
- Banking services and financial portals
- Transport services (booking systems for flights, trains, buses)
- Telecommunications services
- E-book platforms and reading apps
- Self-service terminals (ATMs, ticket machines)
📊 EAA — Key Facts
- In force since: 28 June 2025
- Technical standard: EN 301 549 (WCAG 2.1 Level AA)
- Applies to: Businesses offering goods or services in the EU
- Applies to UK businesses? Yes, if trading in the EU
- Penalties: Up to €900,000 or 4% of annual turnover
Does the EAA apply to UK businesses?
Yes — but only if you trade in the EU.
When does the EAA apply to UK businesses?
1. You sell goods to EU customers
If your UK business sells physical or digital products to customers in the EU, the EAA applies to your website.
2. You provide services to EU customers
If your UK business provides services (banking, transport, telecoms, e-books) to EU customers, the EAA applies.
3. You have an EU presence
If your UK business has a physical presence in the EU (e.g., office, warehouse), the EAA applies.
4. You target EU customers
If your website is targeted at EU customers (e.g., language, currency, marketing), the EAA applies.
When does the EAA NOT apply to UK businesses?
- You only serve UK customers — if you don't trade in the EU, the EAA does not apply
- You are a micro-enterprise — fewer than 10 employees and less than €2 million turnover
- Your products/services are not covered — some products and services are exempt
⚠️ Important — You must still comply with UK law
Even if the EAA does not apply to you, you must still comply with the Equality Act 2010. The Equality Act applies to all UK businesses that provide services to the public, regardless of size.
If you comply with the Equality Act (WCAG 2.2 AA), you are also compliant with the EAA (WCAG 2.1 AA) because WCAG 2.2 AA is more comprehensive.
EAA vs UK Equality Act — What's the difference?
| Feature | EAA | Equality Act 2010 |
|---|---|---|
| Region | 🇪🇺 EU | 🇬🇧 UK |
| In force since | 28 June 2025 | 1 October 2010 |
| Technical standard | EN 301 549 (WCAG 2.1 AA) | WCAG 2.2 AA (EHRC recommendation) |
| Applies to UK businesses | ✅ Only if trading in EU | ✅ All UK businesses |
| Penalties | €900,000 or 4% of turnover | Unlimited compensation |
| Exemptions | Micro-enterprises, disproportionate burden | Disproportionate burden |
EAA vs PSBAR — What's the difference?
| Feature | EAA | PSBAR 2018 |
|---|---|---|
| Region | 🇪🇺 EU | 🇬🇧 UK |
| Applies to | All businesses trading in EU | UK public sector only |
| Technical standard | EN 301 549 (WCAG 2.1 AA) | WCAG 2.2 Level AA |
| Accessibility statement | ✅ Required | ✅ Required |
What do UK businesses need to do for EAA compliance?
Step 1: Check if the EAA applies to you
Determine if you offer goods or services to EU customers.
Step 2: Scan your website
Use the free UK ADA checker to scan your website against WCAG 2.2 Level AA (which is higher than EAA requirements).
Step 3: Fix all violations
Follow the recommendations in the report to fix all violations.
Step 4: Publish an accessibility statement
Publish an accessibility statement on your website (required under the EAA).
Step 5: Monitor and update
Monitor your website regularly and update your accessibility statement at least once a year.
What are the exemptions for UK businesses?
1. Micro-enterprises
Businesses with fewer than 10 employees and less than €2 million turnover are exempt from the EAA.
2. Disproportionate burden
If compliance would be a disproportionate burden, you may be exempt. You must assess and document this.
3. Products and services not covered
Some products and services are not covered by the EAA (e.g., military products, some medical devices).
What are the penalties for EAA non-compliance?
Penalties for EAA non-compliance can be significant:
1. Financial penalties
Up to €900,000 or 4% of annual turnover (whichever is higher).
2. Trading restrictions
Your products and services could be banned from the EU market.
3. Reputational damage
Non-compliance can lead to negative publicity and loss of customers.
4. Legal costs
Defending an EAA case can be expensive.
One scan — Multiple laws
Here's the good news: one accessibility scan can help you comply with multiple laws:
- Equality Act 2010 — WCAG 2.2 AA recommended
- PSBAR 2018 — WCAG 2.2 AA required (public sector)
- EAA — EN 301 549 (WCAG 2.1 AA) required (EU trading)
- ADA (USA) — WCAG 2.1 AA required (US trading)
WCAG 2.2 Level AA is the highest common standard. If you comply with WCAG 2.2 AA, you comply with all these laws.
Frequently Asked Questions — EAA for UK Businesses
Yes — but only if you trade in the EU. If you offer goods or services to EU customers, the EAA applies to your UK business.
The EAA requires compliance with EN 301 549, which is based on WCAG 2.1 Level AA.
The EAA is an EU law that applies if you trade in the EU. The Equality Act 2010 is a UK law that applies to all UK service providers. Both require accessible websites.
Yes. If you comply with WCAG 2.2 Level AA, you comply with the EAA (WCAG 2.1 AA), Equality Act (WCAG 2.2 AA recommended), PSBAR (WCAG 2.2 AA required), and ADA (WCAG 2.1 AA required).
Penalties include up to €900,000 or 4% of annual turnover, trading restrictions, reputational damage, and legal costs.
🔍 Test your website for EAA and UK compliance
Free UK ADA checker — no registration required.
Free UK Checker →Internal links — UK Accessibility Resources
- 🇬🇧 Free UK Accessibility Checker
- ⚖️ Equality Act 2010 — Complete Guide
- 🇪🇺 EAA — Complete Guide
- ⚖️ ADA — Complete Guide
- 📖 Equality Act 2010 — Blog #1
- 📖 PSBAR — Blog #2
- 📖 Equality Act vs ADA — Blog #3
- 📖 WCAG 2.2 AA — Blog #4
- 📖 Public vs Private — Blog #5
- 📖 Reasonable Adjustments — Blog #6
- 📖 Accessibility Statement — Blog #7
- 📖 Disproportionate Burden — Blog #8
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