European Accessibility Act (EAA) 2025:
Ce que ça change pour votre site web

The European Accessibility Act is the most significant digital accessibility regulation ever enacted in Europe. Adopted as EU Directive 2019/882, it requires a wide range of products and digital services to be accessible to people with disabilities. For website owners, this means meeting specific technical standards — including requirements for image alt text that many sites currently fail.

This isn't a future concern. The EAA's compliance deadline for digital services was June 28, 2025. If your business operates in the EU or sells to EU consumers, you need to understand your obligations now. The regulation affects e-commerce stores, banking and financial services, telecommunications, transport, e-books, and essentially any business-to-consumer digital service available to EU residents.

1. What is the European Accessibility Act?

The European Accessibility Act (EAA), officially Directive (EU) 2019/882, is a European Union directive that establishes common accessibility requirements for a range of products and services. It was adopted by the European Parliament in April 2019, and EU member states were required to transpose it into national law by June 28, 2022. The enforcement deadline — the date by which businesses must actually comply — was June 28, 2025.

The EAA's purpose is to harmonize accessibility standards across the EU. Before the EAA, each member state had its own accessibility rules (or no rules at all for the private sector), creating a patchwork that made it difficult for businesses to comply and for consumers to know their rights. The EAA replaces this patchwork with a single, clear standard that applies across all 27 EU member states plus the EEA countries (Norway, Iceland, Liechtenstein).

For digital services, the EAA references the European standard EN 301 549, which in turn is based on the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA. This means that if your website meets WCAG 2.1 AA, you're on the right path for EAA compliance. And one of the most fundamental WCAG requirements is providing text alternatives for non-text content — in other words, alt text for images.

2. Key Dates and Timeline

• April 2019 — EAA directive adopted by the European Parliament
• June 28, 2022 — Deadline for EU member states to transpose into national law
• June 28, 2025 — Compliance deadline for businesses. Products and services must meet accessibility requirements from this date.
• June 28, 2030 — Extended transition period for certain existing service contracts signed before June 2025

As of March 2025, we are past the compliance deadline. Businesses that have not yet made their digital services accessible are technically non-compliant and could face enforcement actions depending on their member state's implementation.

3. Who Must Comply? (Detailed Breakdown)

The EAA applies to businesses that provide specific products and services to consumers in the EU market. It does not matter where the business is headquartered — if you serve EU consumers, the EAA applies to you. Here is a detailed breakdown by sector:

E-commerce and online retail. Any online store that sells products or services to EU consumers must ensure their website is accessible. This includes product pages, checkout flows, customer account areas, and all images used to present products. This is the largest category of affected businesses and the one where image alt text has the most direct revenue impact, since product images without alt text are invisible to Google Shopping and AI search engines.

Banking and financial services. Online banking platforms, investment services, insurance websites, and payment service providers. Customers must be able to access account information, make transactions, and understand financial products without barriers.

Telecommunications. Websites and apps for phone, internet, and communication services. This includes service selection, contract management, and customer support portals.

Transport and travel. Airlines, rail operators, bus companies, and car-sharing services. Booking systems, timetables, and real-time information must be accessible.

E-books and digital publishing. E-book stores, digital newspapers, and online content platforms. This includes both the content delivery platform and the content itself.

Any B2C digital service. The EAA's scope is broad. If your digital service is available to EU consumers and falls within the defined categories, it must be accessible.

Exemptions

The EAA provides a limited exemption for micro-enterprises: businesses with fewer than 10 employees AND annual turnover or balance sheet total under €2 million. Both conditions must be met. If you have 8 employees but €3 million in revenue, you are NOT exempt. Additionally, businesses can claim a disproportionate burden exemption if compliance would fundamentally alter the nature of the product or service, or impose a disproportionate financial burden. However, this exemption is narrowly defined, must be documented, and is subject to review by national authorities. It is not a blanket excuse to avoid compliance.

4. What the EAA Requires for Images

The EAA doesn't mention alt text by name. Instead, it requires compliance with the European accessibility standard EN 301 549, which references WCAG 2.1 Level AA. Within WCAG, the relevant requirement is Success Criterion 1.1.1 (Non-text Content), which states:

"All non-text content that is presented to the user has a text alternative that serves the equivalent purpose, except for [specific situations like decorative images, CAPTCHAs, and purely sensory content]."

In practical terms, this means the following for your website images:

• Every informative image must have descriptive alt text that conveys the same information a sighted user would get from looking at the image. For product images, this means describing the product. For infographics, this means conveying the data or key takeaway. For editorial images, this means describing the scene or content.
• Decorative images must have empty alt attributes (alt="") to signal that screen readers should skip them. An image without any alt attribute at all is different from one with an empty alt attribute — the former is a WCAG violation, the latter is correct practice.
• Complex images need extended descriptions. Charts, graphs, infographics, and diagrams that contain detailed information should have both concise alt text (summarizing the key insight) and an extended description available through a long description link, caption, or adjacent text.
• Image-based controls need functional alt text. If an image serves as a button, link, or interactive element, its alt text must describe the action or destination, not the visual appearance. A magnifying glass icon used as a search button should have alt="Search", not alt="magnifying glass icon".
• CAPTCHAs must provide alternatives. If you use image-based CAPTCHAs, you must provide alternative methods (audio CAPTCHAs, logic puzzles, or other accessible alternatives).

5. WCAG 2.1 Level AA: The Technical Standard

WCAG 2.1 Level AA is the technical standard that the EAA effectively requires. It's organized around four principles, often remembered by the acronym POUR: Perceivable, Operable, Understandable, and Robust. Image alt text falls under the first principle — Perceivable — which requires that all information and user interface components be presentable to users in ways they can perceive.

Beyond alt text (SC 1.1.1), several other WCAG criteria affect images on your website. Success Criterion 1.4.5 requires that text is used rather than images of text wherever possible (except for logos). SC 1.4.11 requires sufficient contrast for graphical elements. And SC 1.3.1 requires that the information structure conveyed through visual presentation is also available programmatically — meaning that if an image conveys a relationship or hierarchy, that information must be available in text form as well.

For most website owners, the practical priority is clear: get alt text on every informative image first. This addresses the most common and impactful accessibility issue. Then address the secondary criteria as part of a broader accessibility improvement plan.

6. Penalties and Enforcement by Country

Each EU member state defines its own enforcement mechanisms and penalties for EAA violations. The directive requires penalties to be "effective, proportionate, and dissuasive," but the specifics vary significantly across countries.

Germany has implemented the EAA through its Barrierefreiheitsstärkungsgesetz (BFSG). The Federal Network Agency (Bundesnetzagentur) is responsible for enforcement. Penalties can include fines of up to €100,000 for serious violations, and products/services can be ordered off the market.

France transposed the EAA into its existing accessibility framework. The ARCOM (Authority de regulation de la communication audiovisuelle et digital) handles enforcement. France has a history of active accessibility enforcement, and penalties can include fines and mandatory remediation orders.

Netherlands designated the Authority for Consumers and Markets (ACM) for enforcement, with the ability to issue fines and binding instructions to non-compliant businesses.

Across all member states, the common enforcement mechanisms include: administrative fines (proportionate to the severity and duration of the violation), mandatory corrective actions (fix your site within a deadline), market restrictions (preventing non-compliant services from being offered in the EU), and public disclosure of non-compliance (reputational damage).

Additionally, the EAA gives individuals the right to file complaints with national authorities if they encounter inaccessible services. Consumer organizations can also take action on behalf of affected individuals. This means enforcement won't rely solely on government audits — your customers can trigger enforcement directly.

7. How to Audit Your Site for Image Accessibility

Before you can fix accessibility issues, you need to identify them. Here's a step-by-step audit process for image accessibility:

Step 1: Automated scan. Use a tool like Screaming Frog (free for up to 500 URLs), WAVE Web Accessibility Evaluation Tool (free browser extension), or axe DevTools (free browser extension) to crawl your site and identify all images with missing or empty alt text. Screaming Frog can export a complete list of every image and its alt text, making it easy to spot gaps.

Step 2: Manual review of key pages. Automated tools can find missing alt text but can't judge quality. Manually review your highest-traffic pages, product pages, and landing pages to ensure the alt text is actually descriptive and helpful, not just present. Check that product images include product names, that informational graphics convey their message, and that decorative images use empty alt correctly.

Step 3: Screen reader testing. Navigate your key pages using a screen reader (NVDA on Windows is free, VoiceOver is built into Mac). Listen to how your images are described. Does the experience make sense without seeing the screen? This is the most revealing test — it shows you exactly what a visually impaired user experiences on your site.

Step 4: Document your findings. Create a spreadsheet listing every image with issues: the URL, the current alt text (if any), and the recommended action (add alt text, improve alt text, or mark as decorative). This becomes your remediation plan and also serves as documentation of your compliance efforts — which is important if you ever face an enforcement inquiry.

8. How to Fix Your Site in 5 Minutes

For WordPress sites, the fastest path from non-compliant to compliant is:

1. Install SightSEO from the WordPress plugin directory. It takes 30 seconds to install and activate.
2. Create a free account at sightseo.com and get your license key. You receive 25 free credits immediately, no credit card required.
3. Enter your license key in SightSEO → Settings. Click "Verify" to confirm the connection.
4. Run Bulk Generate from SightSEO → Bulk. Select "Images missing alt text" and click Generate. The plugin processes all images without alt text, generating descriptive, WCAG-compliant descriptions for each one.
5. Enable auto-generate for future uploads. Every new image you add to WordPress will automatically receive alt text within seconds of upload.

SightSEO generates alt text that follows WCAG 2.1 Level AA guidelines by default: natural language descriptions, appropriate length for screen readers (80-150 characters), meaningful content that conveys the image's purpose, and proper handling of product images with names and context. The generated text is stored in WordPress's standard alt text field, so it remains even if you later deactivate the plugin.

For larger sites requiring more credits, plans start at $49/year for 1,200 images. For a site with 5,000+ images, the Gold plan ($489/year for 24,000 credits) provides the most cost-effective bulk processing. View all plans at sightseo.com/pricing.

9. EAA vs ADA: Complete Comparison

If your business serves both European and American customers, you need to understand both the EAA and the Americans with Disabilities Act (ADA). While they share the same goal — making digital services accessible — they differ significantly in approach, scope, and enforcement.

The practical takeaway: if you meet WCAG 2.1 Level AA, you're well positioned for both the EAA and ADA. The technical requirements are essentially the same. The difference is in how they're enforced — the EAA through regulatory authorities and fines, the ADA through private lawsuits. Both create real financial risk for non-compliant businesses.

10. Frequently Asked Questions

Does the EAA apply to websites outside the EU?

Yes, if those websites provide services to EU consumers. A US-based e-commerce store that ships to EU countries must comply with the EAA for its EU-facing services. The regulation applies based on where the consumers are, not where the business is headquartered.

What if I only have a few images without alt text?

Every informative image without alt text is a WCAG 2.1 violation. There is no minimum threshold — even one missing alt text on an informative image means you're not fully compliant. That said, enforcement is likely to focus on systemic issues rather than individual oversights. The important thing is to demonstrate a systematic approach to accessibility, including automated tools that ensure new content is accessible by default.

Is the EAA retroactive?

Yes and no. The EAA applies to all services offered after June 28, 2025. If your website existed before that date and continues to operate, it must comply. There is a limited transition period until June 28, 2030, for certain service contracts signed before the directive took effect, but this applies to the contract terms, not to the website itself. Your website should be accessible now.

Can I use automated tools for EAA compliance?

Absolutely. The EAA doesn't specify how you achieve compliance, only that you achieve it. Using AI-powered tools like SightSEO to automatically generate descriptive alt text is a perfectly valid — and efficient — approach. The key is that the resulting alt text must be meaningful, accurate, and serve the equivalent purpose as the image itself. SightSEO's AI vision models produce descriptions that meet WCAG 2.1 requirements by default.

What about images in PDFs and documents?

The EAA's accessibility requirements extend to documents provided as part of a digital service. If your website offers downloadable PDFs, brochures, or reports, the images within those documents also need alt text. This is a commonly overlooked area — many businesses have hundreds of legacy PDFs without any accessibility features.