Unlock the potential of the EAA
Amber Knabl
Senior Manager, Accessibility Strategy
Unlock the potential of the EAA
The European Accessibility Act (EAA) deadline on June 28, 2025 was a rest stop, not the final stop.
Since the EAA directive was officially adopted in 2019, companies have focused on preparing for enforcement. For many, this involved foundational activities like reviewing in-scope services, refining accessibility statements, conducting accessibility compliance audits and gap analyses, updating component libraries to meet WCAG standards, and documenting clear roadmaps for long-term compliance. but nothing beyond.
UX design, research and product teams are now celebrating their accomplishments. And they absolutely deserve the kudos for all the work they did to get here.
These same companies know the focus on accessibility will be ongoing. Many are leaning into transparency around what they intend to do to keep improving accessibility UX. They’re facing the real work of managing accessibility through the day-to-day product lifecycle. And they are exploring ways to evolve their practices and grow through inclusive digital experiences.
If you’ve found your way to this article, chances are your teams are, too.
Amber Knabl
Senior Manager, Accessibility Strategy
From meeting standards to driving real change: here’s what we’ll cover
This article will explore how UX research, design, and product development teams can move from EAA accessibility compliance checklists to long-term strategies where accessibility becomes a key part of how they operate and lead. Here’s what’s inside:
What early EAA enforcement reveals about risk and readiness
Good intentions for accessibility compliance don’t necessarily translate into proper implementation. For organizations still unsure how to sustainably embed accessibility into their products, the risks of inaction are no longer hypothetical: they’re in the news.
In France, ApiDV and Droit Pluriel are associations that advocate for the rights of the visually impaired and blind. On July 7, 2025, supported by the legal collective Intérêt à Agir, these organizations formally notified four companies of the digital inaccessibility of their services. The companies have been notified to make their online services fully accessible to people with disabilities by September 1, 2025.
Elsewhere in the EU, a partially blind user filed a formal complaint against a Dutch travel platform after encountering significant screen reader issues during the booking process. The case has triggered legal proceedings under the EAA. The platform is now facing regulatory scrutiny, potential fines, and reputational fallout.
These early EAA enforcement cases highlight the uncertainty around who the directive applies to and how to interpret national-level requirements.
Where compliance meets legal complexity
While the EAA outlines functional requirements, it doesn’t include technical standards for web accessibility because they are included in Directive (EU) 2016/2102 known as the Web Accessibility Directive. The technical standard included in that directive is EN 301 549 (PDF) which references the Web Content Accessibility Guidelines (WCAG). However, WCAG is just one of many frameworks companies can use.
The technical standards are paired with national requirements that differ by country. Every country in the EU is responsible for monitoring their own jurisdiction and empowered to impose unique requirements and fines. For example:
Design for All offers a practical path forward
Recital 50 of the EAA advocates a Design for All approach, stressing the “systematic removal and prevention of barriers” as a way to help people with disabilities gain equal access to products, environments, programmes, and services.
While Recital 50 sets the Design for All vision, there are formal standards that can help bring it to life. For example, EN 17161 outlines ways to integrate Design for All into strategies, policies, and processes from the very start—focusing on removing barriers and supporting interoperability with assistive technologies, without prescribing specific technical designs.
Yet many organizations still default to EN 301 549 for accessibility compliance under EAA, the harmonized standard that drives checklist-based accessibility. Following only EN 301 549 might help you pass technical checks today but lead to failure over time because accessibility isn’t embedded into your design, governance, or continuous improvement efforts.
In contrast, using EN 17161 and EN 301 549 together gives you broad EAA coverage. You’ll build products that meet technical standards while building an organization that’s capable of sustaining accessibility for the long term. And the standards landscape isn’t standing still. Revised harmonized standards are expected to be published in September 2025. These should align more closely with the EAA itself, giving organizations that follow them a clearer, more official path to demonstrating conformity.
Pairing compliance coverage with stronger governance gives you a solid foundation for digital product usability. But how do you turn that foundation into everyday practice? Embedding sustained accessibility into team workflows is easier than you might think.
Three accessibility best practices to embed in your processes
Accessibility becomes embedded into everyday work through practical approaches. We’ll explore three below.
1. Accessibility training is foundational
Your teams need practical know-how to confidently and consistently prioritize accessibility in product design and development. The obvious solution is accessibility training, but traditional methods too often fall short.
Actionable accessibility training
Traditional accessibility training
You could build your own impactful internal accessibility training with enough time and budget, but there are turnkey solutions available that fit the bill. For example, Fable Upskill offers custom training designed to create a culture of accessibility through education.
2. Engaging people with disabilities is critical
Gathering ongoing usability feedback from people with disabilities provides knowledge and inspiration to design, build, and deliver more inclusive products.
This isn’t an all-or-nothing activity. Testing prototypes and products with people with disabilities even 20% of the time is a great start. You can continue to build up the capability at a pace that makes sense for your organization.
Checklist audits can verify if an approach was taken.
User testing reveals whether accessibility efforts were actually successful.
Here are some different approaches teams are taking:
Voices still linger when they aren’t in the room
Even if you’re not ready to fully co-design with people with disabilities, including them at different stages helps your teams build up a baseline of empathy and awareness. This ingrains accessibility thinking into key processes.
For example, after meeting with a keyboard-only user, a product designer will approach a new project thinking, “Can someone navigate this entire flow without a mouse? Will they know where they are on the page at all times? Have I made the interactive elements easy to reach and operate?”
Understanding more about the lived experiences of people who use assistive technologies changes how you think about product design. And that shifts accessibility from an afterthought or compliance checkbox to something you consider early and often.
3. Practical ways to embed accessibility into workflows
Accessibility is a team sport. People across the organization play a role in prioritizing product usability for all—from UX researchers to UI/UX designers to product developers and QA testers.
We do know that treating accessibility as an EAA compliance checkpoint at the end of product development is a recipe for costly rework and remediation. Since 67% of accessibility issues originate in design, product design teams play a massive role in setting their organizations up for long-term success.
Do the same accessibility principles apply to agile workflows?
Yes. Just as accessibility is built into every stage of the product lifecycle, it can be planned and scoped into every agile sprint too. Here are some ideas to get you started:
- Add accessibility acceptance criteria to user stories.
- Include accessibility tasks in sprint planning.
- Include accessibility improvements in the backlog to ensure they are prioritized.
- Raise accessibility blockers in daily standups.
- In retrospectives always ask: “Did we consider accessibility early enough this sprint?”
Move from EAA checklists to inclusive digital experiences
Meeting the European Accessibility Act requirements will help your company avoid litigation and penalties. But true success requires moving from compliance checklists to long-term strategies that embed accessibility into your operations and culture.
Taking this approach not only demonstrates your commitment to EAA’s Design for All guiding principle; it sets you apart from the competition by building digital products that are more usable for everyone. It’s a real business opportunity to build trust and loyalty with the 101 million (or 1 in 4) people with disabilities in the EU—and the even larger circle of friends, family, and acquaintances they influence.
We’ve seen this approach work time and again at Fable. We know that the organizations that will succeed in this new phase of EAA are the ones who embed inclusion into their product development cycle and partner directly with people with disabilities. We’ve observed companies unlock growth when they treat accessibility as a driver of innovation rather than a box to check.
Book a call with one of our experts to explore how you can approach the real work of evolving your product design and development practices in a Design for All world.