EAA vs Equality Act 2010 — What's the Difference? 2026

„Is the EAA the same as the UK Equality Act?" That's a question many UK business owners ask when they hear about the new European Accessibility Act.

In this guide, we'll compare the EAA (European Accessibility Act) and the UK Equality Act 2010. We'll explain the differences, similarities, and what they mean for your UK business.

What is the EAA?

The European Accessibility Act (EAA) is an EU law that came into force on 28 June 2025. It requires businesses to make their products and services accessible to people with disabilities.

The EAA applies to UK businesses that offer goods or services in the EU. The technical standard is EN 301 549 (based on WCAG 2.1 Level AA).

Key features of the EAA:

• Region: EU (27 member states)
• In force since: 28 June 2025
• Technical standard: EN 301 549 (WCAG 2.1 Level AA)
• Applies to UK businesses: Yes, if trading in the EU
• Penalties: Up to €900,000 or 4% of annual turnover
• Exemptions: Micro-enterprises (<10 employees, €2M turnover)

What is the Equality Act 2010?

The Equality Act 2010 is the UK's main anti-discrimination law. It applies to all service providers in the UK, including websites.

The Equality Act requires service providers to make reasonable adjustments for disabled people. The EHRC recommends WCAG 2.2 Level AA as the technical standard.

Key features of the Equality Act:

• Region: United Kingdom
• In force since: 1 October 2010
• Technical standard: WCAG 2.2 Level AA (EHRC recommendation)
• Applies to UK businesses: Yes, all UK businesses
• Penalties: Unlimited compensation, EHRC enforcement
• Exemptions: Disproportionate burden

EAA vs Equality Act — Direct Comparison

Key Differences Explained

1. Technical Standard

The EAA uses EN 301 549 (based on WCAG 2.1 Level AA). The Equality Act recommends WCAG 2.2 Level AA. WCAG 2.2 adds 9 new success criteria compared to WCAG 2.1, focusing on mobile accessibility, cognitive accessibility, and user privacy.

2. Applicability

The EAA applies to UK businesses only if they trade in the EU. The Equality Act applies to all UK businesses, regardless of where they trade.

3. Penalties

The EAA has fixed penalties: up to €900,000 or 4% of annual turnover. The Equality Act has unlimited compensation in discrimination claims.

4. Exemptions

The EAA has a micro-enterprise exemption (<10 employees, <€2M turnover). The Equality Act does not have a specific exemption for micro-enterprises, only a disproportionate burden exemption.

5. Accessibility Statement

The EAA requires an accessibility statement for all covered businesses. The Equality Act only requires an accessibility statement for public sector bodies (under PSBAR 2018).

Similarities Between the Laws

Despite the differences, both laws have important similarities:

• ✅ Both require accessible websites — websites are covered by both laws
• ✅ Both use WCAG as the standard — WCAG 2.2 vs 2.1 is the only difference
• ✅ Both protect disabled people — visual, auditory, motor, cognitive
• ✅ Both have similar exemptions — disproportionate/undue burden
• ✅ Both are enforced by government bodies — EHRC vs EU authorities

Which law applies to your UK business?

Here's a quick guide to determine which laws apply:

1. UK business serving UK customers only

Equality Act 2010 applies. You must make reasonable adjustments for disabled users. EAA does not apply.

2. UK business serving UK + EU customers

Both laws apply. You must comply with both the Equality Act and the EAA.

3. UK business serving EU customers only

EAA applies (if you trade in the EU). You must also comply with the Equality Act if you have UK customers.

4. UK public sector body

Equality Act + PSBAR 2018 apply. EAA applies if you offer public services in the EU.

How to comply with both laws

Step 1: Use a free accessibility checker

Use the free UK ADA checker to scan your website against WCAG 2.2 Level AA (the higher standard).

Step 2: Fix all violations

Follow the recommendations in the report to fix all accessibility violations.

Step 3: Publish an accessibility statement

Publish an accessibility statement on your website (required for EAA, recommended for Equality Act).

Step 4: Document everything

Document all tests and improvements. This serves as evidence for both UK and EU enforcement bodies.

Frequently Asked Questions — EAA vs Equality Act

Internal links — UK Accessibility Resources