Digital accessibility is now a legal requirement in Europe with the gradual implementation of the European Accessibility Act (EAA). Adopted in 2019 and applicable since June 2025 for new products and services, this regulatory framework aims to harmonize accessibility requirements across the European Union, using the Web Content Accessibility Guidelines (WCAG) as its technical reference. While the EAA sets binding legal obligations, the WCAG remain a voluntary international standard—though widely adopted for their rigor and effectiveness.
This article provides a comparative analysis of both frameworks, highlighting their specificities, complementarities, and the key steps for successful compliance. The challenge: to transform accessibility into a performance lever while avoiding legal, reputational, and strategic risks.
The EAA: a demanding and structuring European regulatory framework
A binding legal text based on WCAG
The EAA is a European directive adopted in 2019, which came into force in June 2025 for new products and services, and will apply to existing products and services by 2030. It requires EU member states to harmonize their digital accessibility requirements, based on WCAG 2.1 level AA criteria (not 2.2, which remains optional for now). Contrary to popular belief, the EAA leaves little room for interpretation: it mandates strict compliance with WCAG for covered products and services, with penalties for non-compliance.
This directive is part of a broader social inclusion initiative, in line with the United Nations Convention on the Rights of Persons with Disabilities. Its goal is clear: to ensure that digital products and services are accessible to all, without discrimination, regardless of disability (visual, auditory, motor, or cognitive). It also introduces monitoring bodiesresponsible for verifying and sanctioning non-compliance, and applies to both European companies and foreign companies operating in the EU.
A broad scope and extended responsibilities
The EAA covers a wide range of digital products and services, including:
- interactive terminals (ATMs, payment kiosks, ticket machines)
- online banking services and their mobile applications
- e-commerce platforms
- applications for transport, audiovisual media, or public services
- software and e-books
Every actor in the value chain manufacturers, importers, distributors, and service providers is responsible for the compliance of the products or services they bring to market. For example, a payment terminal manufacturer must integrate features such as screen reader compatibility or voice commands, while a banking service provider must ensure that its mobile app meets accessibility criteria, such as keyboard navigation or color contrast.
A results-oriented approach with clear constraints
The EAA defines functional objectives rather than technical methods, but these objectives are directly inspired by WCAG (level AA). In practice, this means organizations must comply with WCAG criteria to meet the directive’s requirements. Disproportionate burden—often cited as a possible exemption—is in fact strictly regulated and only applies in exceptional contexts requiring a complete overhaul of the product or service.
It is also crucial to note that compliance must be documented and justified, with an accessibility statement published for each relevant product or service. Companies have until June 28, 2030 to bring existing products and services into compliance, but new products and services must already comply with the EAA as of June 2025.
WCAG: an international technical standard for measurable accessibility
A global reference, voluntary but essential
The Web Content Accessibility Guidelines (WCAG), developed by the W3C, are the international standard for making digital content accessible. While not legally binding in themselves, they are widely adopted—and often made mandatory—by national legislation. In France, for example, the RGAA adopts WCAG 2.1 (level AA) criteria, as does the RAWeb in Luxembourg or BITV 2.0 in Germany.
The WCAG are built around four fundamental principles:
- perceivable: information must be presented in an accessible way (e.g. text alternatives for images)
- operable: interfaces must be usable by all (e.g. keyboard navigation)
- understandable: information and interfaces must be clear and logical
- robust: content must be reliably interpreted by assistive technologies
A progressive and evolving structure
The WCAG are organized into three compliance levels:
- level A: minimum requirements for basic accessibility
- level AA: recommended minimum standard (and often required by national regulations)
- level AAA: optimal accessibility, difficult to achieve for some content
WCAG 2.2, published in October 2023, introduces nine new or modified criteria compared to version 2.1, primarily focused on mobile navigation and touch interaction. Contrary to popular belief, cognitive accessibility is not a separate criterion in WCAG 2.2, but is addressed transversally, particularly through requirements for clarity and simplicity of interfaces.
An operational framework to meet EAA requirements
Although the EAA does not explicitly mention the WCAG, the two frameworks are inseparable. In practice, compliance with WCAG—especially level AA—is the most effective method for meeting EAA requirements, as they provide the concrete technical criteria needed to achieve the directive’s functional objectives. For example:
- for a website, WCAG criteria related to text alternatives, color contrast, or compatibility with assistive technologies help meet EAA requirements
- for a mobile application, criteria for keyboard navigation, touch target sizes, or audio descriptions are essential
The WCAG thus offer an operational roadmap, whether the company is subject to the EAA or voluntarily committed to digital inclusion. Their adoption reduces the risk of non-compliance, broadens audience reach, and strengthens reputation in terms of social responsibility.