Banner image with the text 'The EAA is making usability and profitability a priority' on a pink background surrounded by an EU flag, a wireframe icon and a smartphone icon and an accessibility progress icon

The European Accessibility Act is making usability (and profitability) a priority

The European Accessibility Act (EAA) isn’t just another piece of accessibility legislation—it’s a crossroads.

Take one path and you’re focused on accessibility audits. Take the other, and you’re making a broader commitment to both accessibility and usability. In fact, the term “usable” is written right into the background and intent behind the EAA regulations.

Recital 50 of the EAA advocates for a “design for all” approach. In practical terms, this means “the design of products, environments, programmes and services to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.”

Kate Kalcevich
Head of Accessibility Innovation

The European Accessibility Act is making usability (and profitability) a priority

The European Accessibility Act (EAA) isn’t just another piece of accessibility legislation—it’s a crossroads.

Take one path and you’re focused on accessibility audits. Take the other, and you’re making a broader commitment to both accessibility and usability. In fact, the term “usable” is written right into the background and intent behind the EAA regulations.

Recital 50 of the EAA advocates for a “design for all” approach. In practical terms, this means “the design of products, environments, programmes and services to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.”

Kate Kalcevich
Head of Accessibility Innovation

The $13 trillion upside of doing the right thing

Approaching accessibility through a usability lens makes it easier for people with disabilities to navigate and complete tasks. It also happens to be good for business.

People with disabilities influence more than $13 trillion dollars in global spending power. And as more users of digital products age into disabilities, like hearing loss, low vision, and memory challenges, that influence continues to grow.

Leaning into the “design for all” spirit of the EAA regulations doesn’t require throwing out all your existing processes. Rather, it’s an opportunity to re-evaluate how you approach accessible research and design.

Accessibility standards still have a place

Following standards helps teams set a baseline for compatibility with tools that people with disabilities use. Automated accessibility testing tools can be a useful first pass to catch simple accessibility errors in digital products. While standards compliance is a great starting point, it doesn’t always lead to usable outcomes.

Testing with people with disabilities adds critical context

There’s a big benefit to including people with disabilities in product design, development and QA cycles. Their insights reveal whether accessibility efforts are actually successful in making an experience usable for everyone.

Testing for compliance only

Testing for compliance can confirm whether images have alt text, but doesn’t assess its effectiveness.

A woman wearing glasses with orange lenses is smiling and holding a cane in her hand. Her hair is in a long braid and she wears a teal shirt.

Alt text: Smiling woman

Testing for usability

By testing with people, you can uncover whether an image’s alt text is meaningful and useful.

A woman wearing glasses with orange lenses is smiling and holding a cane in her hand. Her hair is in a long braid and she wears a teal shirt.

Alt text: A woman wearing glasses with orange lenses is smiling and holding a cane in her hand. Her hair is in a long braid and she wears a teal shirt.

Did you know?

Meaningful and descriptive alt text also fuels the discoverability of your content by artificial intelligence crawlers, which is an important factor in online growth.

Compliance

Testing for compliance can confirm whether images have alt text, but does not assess its effectiveness.

A woman wearing glasses with orange lenses is smiling and holding a cane in her hand. Her hair is in a long braid and she wears a teal shirt.

Alt text: Smiling woman

Usability

By testing with people, you can uncover whether an image’s alt text is meaningful and useful.

A woman wearing glasses with orange lenses is smiling and holding a cane in her hand. Her hair is in a long braid and she wears a teal shirt.

Alt text: A smiling woman wearing glasses with orange lenses. Her hair is in a long braid and she wears a teal shirt.

Did you know?

Meaningful and descriptive alt text also fuels the discoverability of your content by artificial intelligence crawlers, which is an important factor in online growth.

Mobile apps are a great place to start

EAA 2025 doesn’t require all apps to be accessible. However, there are many apps that fall under the products or services specifically named in the legislation. Here are a few examples:

  • A banking app on a smartphone is subject to EAA accessibility requirements because payment services are included

  • Retail apps fall under the ecommerce products and services category

  • An app for booking flights falls under services related to air, bus, rail and passenger ships

Who needs to adhere to the EAA?

  • All governments and businesses operating within the European Union.
  • Organizations located outside of the EU that sell goods and services in the EU.

What products and services need to comply with the EAA?

  • Computers and operating systems
  • ATMs, ticketing and check-in machines
  • Smartphones
  • TV equipment related to digital television services
  • Audio-visual media services such as television broadcast and related consumer equipment
  • Services related to air, bus, rail and passenger ships
  • Banking services
  • E-books and e-commerce

Usability barriers are a widespread problem in apps

Many apps still fall into the trap of only passing compliance checks. We know this thanks to recent data from The State of Mobile App Accessibility Report by ArcTouch. The findings reveal that people with disabilities struggle with significant barriers when using common apps.

Let’s take a closer look at the findings.

First, some context. The State of Mobile App Accessibility Report assessed the accessibility of 50 leading apps across five industries—food/delivery, payments, fitness, shopping and streaming. Researchers collected quantitative data to uncover what’s broken in app experiences. They performed qualitative testing, leveraging the Fable platform, to understand how the broken experiences impact usability.

Each app’s performance was scored against 14 different accessibility attributes and given an App Accessibility Score out of a total possible of 100.

  • Failing: Score of <30
  • Poor: Score of 30-50
  • Fair: Score of 50-70
  • Good: Score of 70-85
  • Great: Score 85+

Basic accessibility features are missing from many apps

Across all 50 apps evaluated for support of four techniques and technologies used by people with disabilities, 72% of the user journeys included accessibility barriers that resulted in a Poor or Failing grade.

  • 9 apps received a Failing grade outright.
  • Only 2 of the 50 apps tested achieved a Great score.
  • Shopping apps received the lowest score of all industries in the report with a Poor Accessibility Score of 41. 6 of 10 shopping apps received a Poor or Failing rating, as did half of payment apps. Both shopping and payment apps fall under the updated EAA regulations.

Key accessibility issues in apps and how they affect usability

Report highlights Impact on usability
Over three quarters (77.8%) of screens had issues with proper labeling of name, role and value for on-screen elements.
  • Labels provide crucial information for assistive technologies, like screen readers.
  • Screen readers experienced a 90% failure rate across shopping apps and 50% in payment apps.
Many home screens immediately presented accessibility barriers.
  • When users can’t navigate the home screen of an app it’s difficult to successfully complete the intended task.
  • Even if other parts of your app are highly accessible, they’re less likely to land there. And if they find a competitor with a usable home screen you can lose them for good.
Lack of support for landscape and portrait device orientation. Payment apps had a 100% failure rate and shopping apps clocked in at 90%.
  • Users with low vision often rely on landscape orientation. Since it allows more horizontal space, text can appear larger and buttons are spaced out to reduce visual clutter. Landscape orientation also presents a better zoom experience.
  • For users with limited mobility, buttons and interactive elements are often larger and easier to use in landscape. Some users also mount their device in a fixed position and don’t have the ability to physically change the orientation.
Font scaling was the second-least supported assistive technology in the study.
Many apps that used the native accessibility tools built into iOS and Android still presented with issues like unlabeled icons and lack of dynamic font support. Native accessibility tools provide a solid foundation, but UX researchers and designers need to do usability testing to ensure people with disabilities can effectively use apps.

Key accessibility issues in apps and how they affect usability

Over three quarters (77.8%) of screens had issues with proper labeling of name, role and value for on-screen elements.

  • Labels provide crucial information for assistive technologies, like screen readers.
  • Screen readers experienced a 90% failure rate across shopping apps and 50% in payment apps.

Many home screens immediately presented accessibility barriers.

  • When users can’t navigate the home screen of an app it’s difficult to successfully complete the intended task.
  • Even if other parts of your app are highly accessible, they’re less likely to land there. And if they find a competitor with a usable home screen you can lose them for good.

Lack of support for landscape and portrait device orientation. Payment apps had a 100% failure rate and shopping apps clocked in at 90%.

  • Users with low vision often rely on landscape orientation. Since it allows more horizontal space, text can appear larger and buttons are spaced out to reduce visual clutter. Landscape orientation also presents a better zoom experience.
  • For users with limited mobility, buttons and interactive elements are often larger and easier to use in landscape. Some users also mount their device in a fixed position and don’t have the ability to physically change the orientation.

Font scaling was the second-least supported assistive technology in the SOMAA study.

Many apps that used the native accessibility tools built into iOS and Android still presented with issues like unlabeled icons and lack of dynamic font support who was the first one.

  • Native accessibility tools provide a solid foundation, but UX researchers and designers need to do usability testing to ensure people with disabilities can effectively use apps.

App accessibility bright spots

The report did uncover some encouraging signs of progress in mobile app accessibility:

  • Streaming apps received the highest accessibility score of all industries included. That said, the score is only 60 (Fair). People with disabilities could use fewer “fair” experiences and more slick usable experiences.
  • 70.6% of payment app screens have all elements focusable for screen readers. Since a mere third of home screens in these apps were found to provide a Good or Great experience, many people with disabilities would likely abandon the experience before they have a chance to get to the good/great stuff.

There is still lots of work to do to make more apps accessible in a meaningful way. The question is how to best get started.

Three ways to create digital products that are usable for all

Many design leaders have been diligently complying with accessibility standards with the understanding that it’s enough. Others know that accessibility efforts could be amped up, but they’re unsure how to balance the changes required along with all the other priorities. Others still aren’t clear on what they gain by focusing on usability over compliance.

The upcoming European Accessibility Act deadline presents a huge opportunity for all. It’s a chance to stretch beyond compliance and create repeatable processes for delivering enjoyable, usable digital experiences for every customer—including people with disabilities.

If you’re ready to embrace EAA 2025’s “design for all” mandate, here are three changes to make:

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1. Get feedback from the people with lived experience

Collecting real-world feedback from people with disabilities at regular intervals in your product development cycle is invaluable. You might be surprised at the power of people to uncover common usability challenges that automated accessibility testing tools simply can’t surface.

Ideally, you want access to a diverse community of people with disabilities using a wide range of technologies. A platform like Fable can also speed time to results by letting you skip recruitment, collect user feedback fast and tap into accessibility subject matter expertise.

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2. Publish your commitments…and progress

Accessibility statements provide a way to share your organization’s commitment to achieving accessibility goals. They may also be a requirement for some organizations under the European Accessibility Act.

You can increase transparency by also sharing your progress towards stated goals by committing to continual measurement. Accessibility metrics are more important than ever as organizations want to connect initiatives to outcomes.

Users of your digital experiences have many different goals. Task completion rates help you identify whether users successfully complete tasks or run into blockers.

You may be familiar with the System Usability Scale (SUS) for measuring the perceived usability of a digital experience. The Accessible Usability Scale (AUS) is a quick, reliable, and standardized way to measure perceived accessibility of a product. It does this by tracking usability trends over time and comparing them against industry benchmarks.

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3. Get the tools, skills and processes in place to succeed

If you don’t have in-house accessibility expertise you can use targeted training to build this muscle with your team. One note of caution: make sure any training you’re considering isn’t solely centered on understanding compliance.

Creating a usability mindset requires training that builds practical skills, like how to actually build accessible forms that different assistive technologies can navigate with ease. You can also explore more advanced approaches, like role-based modules with accessibility guidance specific to various product team members or guidance on how to conduct research most effectively with people with disabilities.

EAA regulations are about user experience, not just compliance

Directives in the European Accessibility Act become enforceable on June 28, 2025. This will impact many organizations, including those that don’t physically operate in the EU. Any company that offers products and services to EU residents must comply with the legislation.

On paper, it’s easy to quantify the consequences of non-compliance with EAA regulations. Penalties are clearly set out according to the national laws of each EU Member State.

In reality, it’s more challenging to precisely calculate what a lack of digital usability will cost organizations. What is clear is that businesses take a big hit when customers who can’t navigate products shift their loyalty to more accessible experiences (and share their negative brand perceptions with friends and family).

We already have the technology and tools to make digital experiences more usable for all. Design business leaders who are preparing their teams to comply with EAA regulations are in the perfect position to explore how these new approaches can fit into existing product development lifecycles.

Create exceptional product experiences

Uncover how accessibility for people with disabilities makes your products better for everyone.

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