EAA compliance checklist for websites and web shops

The European Accessibility Act has applied since 28 June 2025. This checklist turns the directive into a sequence of concrete tasks you can tick off — from scope check to ongoing monitoring. Print it, paste it into your ticket system, or work through it with the free scanner.

1. Confirm whether you are in scope

• Do you sell products or services to consumers in the EU through a website or app (e-commerce)? Then you are in scope — regardless of where your company is based.
• Do you offer consumer banking, e-books, passenger transport, telecoms or audiovisual media services? These are covered explicitly.
• Are you a micro-enterprise providing services (fewer than 10 employees and annual turnover or balance sheet ≤ €2M)? Then the service obligations do not apply to you — but products you sell still have to comply, and many B2B customers will ask for accessibility anyway.
• Note the transition: service contracts concluded before 28 June 2025 may continue unchanged until 28 June 2030 at the latest; new offers must comply now.

2. Know the technical benchmark

• The harmonised standard is EN 301 549, which incorporates WCAG 2.1 Level AA for web content and mobile apps.
• Meeting WCAG 2.1 AA gives you a presumption of conformity. Aiming at WCAG 2.2 AA is a sensible, low-cost step beyond it.
• Content and documents count too: PDFs, videos (captions), chat widgets and third-party checkout components are part of your service.

3. Run a baseline audit

• Run an automated WCAG scan of your key journeys: home, category, product, cart, checkout, account, contact, legal pages. FixRamp's scanner does this in a real browser with axe-core and lists each failing element with its CSS selector.
• Record the baseline score and export the timestamped report — it is your first piece of evidence.
• Add manual checks automation cannot do: keyboard-only walkthrough of the checkout, screen-reader spot check (NVDA/VoiceOver), zoom to 200%, meaningfulness of alt text, form error messages.

4. Fix in priority order

• Critical / serious first: keyboard traps, missing form labels, unlabelled buttons and links, colour contrast below 4.5:1, missing document language.
• Fix at the source — templates, design tokens, components — so the fix propagates to every page. Do not paper over problems with an overlay widget.
• Use generated fixes as a starting point, review them, apply them in your codebase, then re-scan to confirm each violation is gone.
• Brief third-party vendors (payment, chat, cookie banner) and ask for their accessibility conformance reports.

5. Publish an accessibility statement

• Required for services under Annex V of the directive: describe the service, how it meets the requirements, and how users can report barriers.
• Link it from the footer of every page. See how to write an accessibility statement; the generator drafts one from your scan results.

6. Document the effort

• Keep every audit report with date, scope, score and open issues. Market-surveillance authorities may request documentation showing how you assessed and achieved conformity.
• Keep a remediation log: issue → fix → verification date.
• Store vendor conformance statements alongside your own.

7. Set up a feedback channel

• Offer an accessible way (email and form at minimum) for users to report barriers, and commit to a response time.
• Treat reports as compliance signals — in Germany, competitors and consumer associations can act on them under unfair-competition law.

8. Monitor continuously

• Re-scan after every release; accessibility regresses with each new component, banner or campaign page.
• Automate it: the Scan API returns JSON you can wire into CI or a weekly job.
• Review the statement at least once a year and whenever the service changes materially.

What this checklist does not do

Automated tools detect only part of WCAG. Completing every item above demonstrates diligent compliance effort — the thing authorities and courts actually assess — but it is not a certification and not legal advice. For high-risk services (banking, transport), commission a manual expert audit in addition.

Legal reference: Directive (EU) 2019/882, Annex I (requirements) and Annex V (information on services).