Is Your Business Ready for the European Accessibility Act? Use This Checklist

European Accessibility Act Checklist for businesses: a practical list to check whether your products and services meet EU accessibility requirements and what to do next. Read this if you supply digital services, physical products or public-facing kiosks in the EU.

What the European Accessibility Act is, briefly

The European Accessibility Act is an EU directive setting harmonised accessibility requirements for certain products and services. It was adopted in 2019. Member states had a deadline to transpose the directive and the rules begin to apply across the EU from a common application date. Check your national implementing law and get legal advice for exact obligations.

How to use this European Accessibility Act checklist

Work through the checklist below in order. Start with scope and governance, then audit what you already sell or publish. Use the remediation and testing steps to create an action plan with dates and owners. Keep records of decisions, tests and fixes.

Scope and mapping

• List every product and service you offer to customers in the EU, including digital goods, hardware and combined offerings.
• Include online stores, mobile apps, downloadable files, e-books, ticketing, banking interfaces, kiosks, ATMs, transport booking systems, and smart devices where applicable.
• Mark whether each offering is developed internally, bought from a supplier, or delivered by a third party.

Governance and policy

• Assign a named accessibility owner with authority to make product decisions.
• Create a short accessibility policy that sets minimum standards and the remediation process.
• Embed accessibility requirements into procurement rules and vendor contracts.

Audit: what to check now

Run an initial audit to identify the biggest gaps. Combine automated tools with manual checks and user testing.

• Automated scans for websites and apps to find obvious markup and contrast issues.
• Manual review using keyboard-only navigation and a screen reader for core user journeys.
• Hardware checks for physical controls, tactile indicators and alternative access routes.
• Review documentation and support channels for accessible formats and response processes.

Practical tools and standards to use

• Use a recognised web accessibility standard such as WCAG 2.1 Level AA where your national law or guidance refers to it.
• Run Lighthouse, axe or similar automated checks, but do not rely on them alone.

Risk-based remediation plan

Prioritise fixes that affect safety and core transactions first. Create sprints of work with clear acceptance criteria.

1. Identify high-impact journeys, for example checkout, ticket purchase or login.
2. List defects that block these journeys for assistive technology users.
3. Estimate time and cost to fix each defect and assign an owner and deadline.
4. Track fixes in your usual issue tracker and mark accessibility tickets clearly.

Design and development requirements

• Require accessible components and patterns in your design system. Include keyboard focus styles and visible labels.
• Demand semantic markup, ARIA only where necessary, and avoid using ARIA to replace proper HTML elements.
• Set performance and compatibility targets for assistive technologies and older devices.

Procurement and third parties

• Update procurement templates to include specific accessibility clauses and test criteria.
• Ask suppliers for evidence: test reports, accessibility statements and remediation roadmaps.
• Do not accept a vendor promise without verifiable test results and a timeline for unresolved issues.

Testing with people who use assistive technology

User testing is essential. Automated tools find code problems but not usability failures. Pay people who use screen readers and alternative input methods for realistic testing.

• Recruit testers who match real user groups for each product or service.
• Test full end-to-end journeys, not single pages. Include payments, authentication and form submission.
• Record findings and use them to refine acceptance criteria for fixes.

Accessibility statement and complaints process

• Publish a clear accessibility statement that covers the scope of what you have tested and what remains to be fixed.
• Provide a simple way for customers to report accessibility problems and set response SLAs.
• Log complaints and outcomes to demonstrate ongoing compliance effort.

Training and internal change

• Run role-specific training: developers learn accessible coding, product managers learn acceptance criteria, support teams learn how to handle requests for alternative formats.
• Include accessibility checks in design reviews and code reviews.

Record keeping and monitoring

• Keep an accessibility register with audit dates, test reports and remediation status for each item in scope.
• Schedule periodic re-tests, at least annually or after major releases.
• Use metrics such as number of unresolved critical defects and time to remediate.

Timeline and project plan checklist

Phase	Key tasks	Who
Weeks 0 to 4	Scope mapping, appoint owner, initial audit	Product owner, accessibility lead
Weeks 4 to 12	Create remediation backlog, begin fixes on high-impact journeys	Dev teams, designers
Ongoing	User testing, procurement updates, publish statement, monitoring	Cross-functional team

Costing and resourcing

Estimate both one-off remediation costs and ongoing resourcing. Small remediation tasks can be quick; large legacy systems may need phased work. Track spend against the remediation backlog to keep stakeholders informed.

Common mistakes businesses make

• Assuming automated testing is enough. It finds code errors but not real user problems.
• Only fixing the website and ignoring native apps and hardware interfaces.
• Accepting vendor claims without test evidence or a remediation plan.
• Leaving accessibility to a single developer rather than embedding it in product processes.

Two practical angles many guides miss

How to prioritise fixes in one page

Score each defect by impact, frequency and fix effort. Focus on defects that block transactions or cause loss of service for assistive technology users. Use the score to decide which items go into the next sprint.

Example: applying the checklist to an online shop

• Scope: catalogue pages, product pages, cart, checkout, account area, emails.
• Audit: automated scan for all product pages, manual checkout test using a screen reader and keyboard only.
• Remediate: fixes for form labels, error messages, focus order and keyboard access to the cart.
• Test: recruit three users for a full purchase journey, log issues and close critical items before release.
• Publish: update the accessibility statement and add a clear contact for reporting issues.

Simple decision checklist: do these apply to you?

• Do you sell products or provide services to customers in the EU?
• Do you operate public-facing digital services, kiosks, banking interfaces or consumer hardware?
• Are your suppliers or partners handling customer-facing interfaces on your behalf?

If you answered yes to any of these, treat the European Accessibility Act checklist as relevant and begin the steps above. For legal certainty, consult national guidance or counsel.

Next practical steps

• Do a 30-minute scope review with product and legal teams using the mapping section.
• Schedule an initial audit and budget a small pilot user test.
• Update procurement documents to include accessibility clauses before your next vendor renewal.

Keep records of your decisions and tests. Accessibility is ongoing work. Use this checklist to turn legal risk into a deliverable project with owners, dates and measurable results.