The EAA Directive and the new digital accessibility requirements are a must. How to avoid fines? 12 practical tips.

What is the EAA Directive and who does it apply to?

Consequences of ignoring the new requirements

The new obligations are not just a “paper” requirement. Failure to implement them risks high financial penalties and exclusion from public procurement, as well as a loss of customer trust.
Looking at it from the other side… if you implement the new digital accessibility requirements, you will not only protect your business from penalties. You will also open yourself up to millions of new customers – including those with disabilities or seniors, and build a positive brand image.

How to prepare for the EAA Directive? We have prepared 12 practical tips.

1. Conduct a compliance audit with the EAA Directive and WCAG 2.2 standard

Start with an in-depth analysis: check the condition of your website, online store, or application. Use tools such as Google Lighthouse, WAVE, Axe DevTools, and conduct manual tests (e.g. operating the website using only a keyboard, or how screen readers work). This will help you identify the biggest barriers for people with disabilities or seniors.

And if you need the support of experts who will guide you through the entire process “from A to Z”…Contact us via a simple form on the website. We provide you with an audit, implementations, and long-term support in the field of digital accessibility and the implementation of standards regarding the “EAA Directive”.

2. Adjust the structure and appearance of the website to WCAG 2.2 standards

From June 28, 2025, all new and existing solutions must comply with WCAG 2.2 at the AA level. This might sound technical, but in reality, it boils down to a few key areas that have a real impact on user experience. Below you will find a detailed overview of the most important changes you need to make.

Text and background color contrast – let everything be legible

What is it about?
Contrast is the difference in brightness between the text and its background. If it is too low, people with low vision, color perception disorders (e.g. color blindness) or simply seniors will not be able to read the content.

What do you need to do?

• Standard text: Must have a contrast ratio of at least 4.5:1 against the background.
• Large text: (Over 18 points or 14 points with bold font) – here the requirement is more lenient and amounts to 3:1.
• Graphical elements and interface: Buttons, icons, or form field borders must also have a contrast ratio of at least 3:1 against the surroundings to be clearly visible.

How to check it?

• Test elements in different modes (e.g. dark/light mode) so that no user has problems with legibility.
• Use free online tools such as WebAIM Contrast Checker or Adobe Color. Just paste the color codes for the text and background, and the tool will immediately show you if you meet the standards.

Add alternative descriptions (alt text) to images – tell what is in the picture

What is it about?
Blind people use screen readers that read the page content aloud. When such a reader encounters an image, it reads its alternative text (the so-called alt attribute). Without it, the user has no idea what the graphic depicts – whether it is a product photo, an important chart, or just a decorative element.

What do you need to do?

• Every image that carries information must have a short but informative description in the alt attribute. Think about it: “how would I describe this image to someone over the phone?”.
• Example: Instead of alt=”photo123″ write alt=”A man in a suit sitting at a desk working on a laptop”.
• If the image is purely decorative and brings no content, the alt attribute should be left empty (alt=””). Thanks to this, screen readers will skip it, without cluttering the message.

Take care of the logical structure of headings – create a table of contents for the page

What is it about?
Headings (H1, H2, H3, etc.) create a hierarchical content structure. For screen reader users, they act like a table of contents – allowing them to quickly jump between sections and orient themselves in the site architecture. For Google algorithms, it is in turn crucial information about what is most important in your article.

What do you need to do?

• Use only one H1 heading on each subpage – this is the main title, e.g. a product name or an article title.
• Maintain hierarchy: H1 should be followed by H2 (main sections), and within them H3 (subsections), etc. Never skip levels, e.g. from H2 to H4.
• Do not use headings to style text. If you want to make something bold or larger, use CSS styles for this, not heading tags.
• Lists and tables: Must be marked with appropriate HTML tags (<ul>, <table>) to ensure their comprehensibility.

Create clear labels for links, buttons, and forms</h3   >

What is it about?
Users need to know what will happen before they click. Vague messages like “Click here” or “More” are useless, especially when a screen reader extracts a list of just links. The same applies to forms – the user needs to know what data to enter in each field.

What do you need to do?

• • Every button should have a clear description of its action (e.g. “Send” instead of “OK”, “Add to cart” instead of “More”).
  • Form labels: Every field (<input>) must be connected to its label (<label>). This way, clicking the label activates the field, and screen readers correctly announce what to enter (e.g. “Name, edit field”).
  • Error messages: Must be clear and precisely indicate where and why the error occurred (e.g. “The ‘E-mail address’ field is required” instead of a generic “Form error”).
  • Forms must signal an error unambiguously with a description/icon/text message.

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Navigation accessible via keyboard

What is it about?
Not everyone uses a mouse. People with motor disabilities, but also advanced users (so-called power users), navigate websites exclusively using the keyboard (mainly the Tab key).

What do you need to do?

• Check it yourself: Try to go through your entire website from the menu, through the buttons, to the contact form – using only the Tab key to move forward, Shift+Tab to go back and Enter to activate links/buttons.
• Visible focus: It must always be visible which element is currently active. Most often it is a standard outline added by the browser. Make sure your programmers haven’t hidden it (outline: none; in CSS is a common mistake). The focus must be clear and contrasting, e.g. through highlighting.
• Avoid “keyboard traps”: The user must not get stuck in any element (e.g. in a pop-up window) without being able to leave it using the keyboard.

Correct operation for screen readers

What is it about?
Modern websites are full of interactive elements: drop-down menus (accordions), photo carousels, modal windows. If they are not properly coded, for a screen reader they are just a collection of random elements.

What do you need to do?

• Inform about the state: The reader needs to know if a given element is expanded or collapsed, active or inactive. ARIA (Accessible Rich Internet Applications) attributes are used for this, e.g. aria-expanded=”true”.
• Logical reading order: The content read by the reader must make the same sense as the content seen on the screen. Ensure that the visual order of elements corresponds to their order in the HTML code.

• Test the website with popular screen readers (NVDA, JAWS, VoiceOver) to make sure all important content, messages, and descriptions (e.g. for form errors) are read.
• Avoid the so-called “invisible to readers”, such as hidden navigation links, unrecognizable graphics, or unlabeled buttons.

Responsiveness and accessibility on mobile devices

What is it about?
More and more users access the Internet on mobile devices. A website or application must be fully functional on smartphones and tablets – also for people with various disabilities.

What do you need to do?

• Use responsive design: content and interface elements adapt to the screen size, regardless of the device. Check if the website displays and operates correctly on smartphones and tablets.
• Clickable elements (e.g. buttons, links) cannot be too small or “too close to each other” – recommended minimum height/size: 44×44 px.
• Introduce the possibility of gesture navigation and support for accessibility features in Android/iOS systems (e.g. VoiceOver, TalkBack).
• Make sure that messages, menus, or pop-ups are easily legible and easy to close.

Translations and multilingualism

What is it about?
Each language version of your website should provide identical quality of digital accessibility – this means that all functions, content, and messages must be both understandable and easy to translate.

What do you need to do?

• Translate and adapt all captions, error messages, labels, and instructions to the user’s local language.
• Remember about alternative descriptions for graphics, which we wrote about in point 2 of this article (“alt text”) also in other language versions.
• Declare the language of the page using the lang attribute in the HTML code (e.g. <html lang=”en”> for the English version).

Multimedia – subtitles and audio description

What is it about?
Videos, podcasts, webinars, and other multimedia materials must be accessible to people with hearing and vision disabilities. This means the necessity to use subtitles (for the deaf and hard of hearing) and audio description (for the blind and visually impaired).

What do you need to do?

• Add subtitles to all video materials. Subtitles should include not only dialogue but also significant background sounds (e.g. “applause”, “dramatic music”, “street noise”).
• In the case of live broadcasts, provide live captions or make a recording with added subtitles available as soon as possible.
• Include a transcript for audio and video materials. A transcript is a textual record of everything that can be heard in the material. It makes it easier for people who cannot or do not want to use sound (e.g. in public places) to use the content.
• Audio description for videos – this is an additional voiceover description for blind people that translates what is happening on the screen, describes the action, facial expressions, scenery changes, gestures, etc. In practice, you can record your own audio track or add an alternative file to the player (most modern web players offer this option).
• Do not rely solely on automated tools. Automatic subtitle generation (e.g. by YouTube) is helpful, but often contains errors. Always verify and correct the generated subtitles.

Language accessibility

What is it about?
The EAA Directive imposes the obligation to publish an accessibility statement – a clear document informing to what extent the website meets digital accessibility requirements and allows users to report barriers.

What do you need to do?

• Prepare a readable accessibility statement, updating it with every significant change to the website.
• Make sure that the page with the declaration is easily accessible from every subpage (e.g. in the footer).
• Add a simple contact form or e-mail/phone number that users can use to report accessibility problems.

Training for the team

What is it about?
Digital accessibility is a team effort. Your technical team, editors, and designers must understand accessibility rules and apply them regularly.

What do you need to do?

• Organize training and workshops for the team – you can outsource them to external experts, e.g. Devqube.
• Introduce checklists and procedures to the content publication and implementation process.
• Regularly audit the website, and test changes not only with automated tools but also manually (e.g. using a keyboard or screen reader).

Remember: The EAA Directive and digital accessibility are not a revolution, just eliminating barriers

If you implement the above improvements – your website/application will not only meet legal requirements, but will actually become friendly to all users, which will translate into better reputation, higher reach, loyalty, and… better positions in Google.

You don’t have to fear a complete system rebuild. The key is to gradually introduce changes and be open to consultations with experts.

Do you have questions? Do you still feel that something is too difficult? Contact Devqube – we will guide you through the entire process, explain it in practice, conduct an audit, and prepare your website for the new regulations… for you.

Most common doubts and our answers:

Do I face penalties for non-compliance with the EAA Directive? Yes, for not taking the EAA requirements into account, you can receive a high fine and be excluded from a part of the market.

Do I have to implement everything at once? It is worth starting to introduce changes in stages as soon as possible – the sooner, the more competitive advantage you will gain.

What if I don’t have internal competencies to implement EAA guidelines? Use Devqube’s help – as an experienced technology partner, we will be happy to conduct an audit, plan the implementation, and conduct training for your team.

Do I have to inform users about this? Yes – placing an accessibility statement and a contact form is an obligation according to the EAA.

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Daria Szklarewicz

Projektantka UX/UI, specjalizująca się w tworzeniu intuicyjnych i użytecznych interfejsów dla aplikacji mobilnych oraz webowych. W swojej pracy biegle posługuje się narzędziami takimi jak Figma, Miro i Adobe XD, koncentrując się na całym procesie projektowym – od wireframe'ów po testy użyteczności. Szczególną wagę przykłada do dostępności cyfrowej, projektując zgodnie z wytycznymi WCAG. Stale rozwija swoje kompetencje, łącząc kreatywność z analitycznym podejściem do rozwiązywania problemów.

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