One year of the EAA: What’s changed, what’s coming, and what to do next

This blog is an adaptation of a blog by Matthew Luken, Senior Vice President and Chief Architect at our partner Deque.

Regulators have begun enforcing the EAA

One year after the EAA came into effect, regulators now assume compliance. Whereas enforcement previously may have seemed theoretical or abstract, that is no longer the case. Enforcement is now taking place throughout Europe.

As early as December 2025, we saw signs of enforcement. And this month, following a court case, a major supermarket chain in France was given six months to comply with the regulations, under threat of daily fines.

Monitoring bodies across Europe are expanding the scope and scale of their activities. Poland, Sweden, Ireland, and the Netherlands, among others, have all announced plans for more extensive oversight in the spring and summer of 2026. The Netherlands Authority for Consumers and Markets (NL-ACM), for example, has begun visiting companies to communicate the results, set expectations, and showcase people with disabilities who use assistive technology to help raise awareness.

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Download Deque's report 'The EAA at one year'

This is what EAA enforcement looks like

It is also becoming increasingly clear how regulators select their targets. Signs of noncompliance in one area are being treated as an indicator of potential noncompliance in other areas. And organizations that failed to submit the required non-conformance reports, or that have submitted reports deemed weak or inadequate, are being moved to the front of the audit queue.

When monitoring bodies contact an organization, they follow a deliberate sequence (whether it begins with a complaint or with their own monitoring obligation). First, automated scanning and validation of non-conformance; then, outreach; and finally, escalating scrutiny for organizations that do not respond, including more frequent communication, possible on-site visits, and ultimately the possibility of formal sanctions. In Austria, financial penalties can be imposed by the authority without the need for litigation.

In addition to their individual efforts, supervisory authorities also collaborate with one another. In May 2026, supervisors from the Netherlands, Sweden, Germany, Austria, Ireland, and other countries met in Norway independently and on their own initiative. They compared their approaches and shared best practices. They are investing in the necessary capacity to carry out these efforts. Germany has appointed approximately 70 auditors, and the Netherlands has also recruited accessibility specialists.

Common accessibility issues in businesses

Although enforcement efforts are gaining momentum, most organizations are not yet operationally ready. Deque’s collaboration with its clients across Europe consistently reveals that legal, compliance, and product teams operate in silos. With legal teams lacking the technical expertise in accessibility needed to properly assess risks. As a result, risk levels are either unknown or significantly underestimated. Many organizations are still waiting for formal complaints or a formal notice from a regulatory authority before taking action. And those organizations that do receive complaints often lack a defined process for responding to them.

Monitoring bodies themselves point to similar problems. Specific signs they have identified as indicators of concern include missing, weak, or unreasonable accessibility plans; inadequate reporting of known issues; repeated consumer complaints; unclear improvement plans; and limited evidence of progress.

These are surmountable challenges. In fact, the organizations that have made the most progress often start from precisely this starting point.

Three steps you should take now

To ensure that Deque provides its clients with the strategic guidance they need, it maintains regular contact with regulatory authorities throughout the EU. Based on what these authorities have directly communicated to Deque about what they’re looking for, we’ve identified three concrete steps that are crucial for organizations:

• Step one: Gain insight into current risks. This involves assessing the customer journey against the EN 301 549 standard, not just the WCAG guidelines.
• Step two: Establish a documented accessibility program. This involves having a published roadmap and a clear plan to demonstrate compliance.
• Step three: Establish internal structures. This involves ensuring coordination among the legal, compliance, and product teams; setting up a process for handling complaints as they arise; and ensuring that the organization can collaborate constructively with a regulatory authority.

These are just a few of the key specific areas that regulators focus on when assessing whether an organization is making reasonable progress.

How to ensure EAA compliance

As we enter the second year of the EAA, the focus is truly on progress. The EAA oversight system is now active and will only continue to scale up.

The organizations most likely to succeed are those that can report on known issues and demonstrate progress. They have a documented accessibility program. Their legal, compliance, and product teams are aligned. And when a regulatory agency contacts them, they know how to respond and can provide a thorough and complete picture.

Reaching this level is a journey from vulnerable and uncertain to confident and prepared. If your organization is still in the first category, now is the time to take action. Have you already reached the ‘confident and prepared’ stage? Then your company and customers will reap the benefits of your compliance with the EAA’s accessibility requirements—such as reduced financial and legal risks, a larger market share, and a better brand reputation.

We’ll conclude with two simple predictions and one important lesson. Prediction one is that there will be more accessibility lawsuits. Many, in fact. Prediction two is that compliance will actually become easier, not harder. Now that the EAA has been in effect for a year, there are fewer unknowns. And there are more resources, tools, and ways to get the support and results your organization needs.

It’s essential to take action now and implement the right measures. Fortunately, the sooner you

Acting now is essential. And deliberate action is required. Fortunately, the sooner your organization gets started, the more options you’ll have. If you’re ready to take the next step, our specialists are here to help.