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Graphic showing the map of France colored in the French flag (blue, white, red) with a universal accessibility symbol in the center. To the right, the Quertum logo appears above the title: "French Accessibility Act: Uncovering the RGAA law", on a dark blue and purple gradient background with light green geometric lines.

EU Accessibility Act in France: Uncovering the RGAA

Written by Kateryna Klynovska on . Posted in EEA.

In our previous articles, we examined EU Accessibility Act in Poland and Germany have implemented the European Accessibility Act (EAA) or RGAA in French. France, however, starts from a different place – one of leadership. Long before the EAA, French law had already set clear rules for accessibility. The EAA does not reinvent the wheel in France, but it does tighten enforcement, expand scope, and clarify obligations for private sectors.

In this article, we break down how the EAA is being applied in France, and what this means for companies operating locally or across borders. 

France’s Accessibility Evolution: From Early Laws to the EAA

France has been a pioneer in accessibility regulation, starting with Law No. 2005-102 (Montchamp Law), and continuing through the RGAA (Référentiel Général d’Amélioration de l’Accessibilité). Here is why the implementation of the EAA builds on this strong base, but brings in sharper penalties, broader private-sector coverage, and stricter expectations around proof of compliance. 

When it comes to digital accessibility, France didn’t wait for the European Accessibility Act (EAA) to take action. For nearly two decades, the country has been building a legal and technical framework to ensure that websites, apps, and digital documents work for everyone — including people with disabilities.

It All Started in 2005

France passed its landmark Law No. 2005‑102 (“Loi pour l’égalité des droits et des chances”), a sweeping anti-discrimination law that made digital accessibility mandatory for public-sector websites. This law laid the foundation for what would become one of Europe’s most mature national accessibility strategies.

Enter the RGAA — A Practical Accessibility Rulebook

To turn legal principles into action, France created the RGAA (Référentiel Général d’Amélioration de l’Accessibilité) — a national technical standard that adapts WCAG guidelines into concrete testing rules. Over the years, the RGAA has evolved through several versions, staying aligned with EN 301 549 and WCAG 2.1 standards.

Since 2016, France has also required accessibility statements on public websites and mobile apps, along with regular audits and a clear process for user feedback.

2019: Aligning with the EU Web Accessibility Directive

France was ahead of the curve when the EU Web Accessibility Directive came into force. Through Decree No. 2019‑768, the country reinforced its obligations for public bodies and certain private-sector services like banks and transport. The RGAA remained the go-to standard for demonstrating compliance.

2023–2025: The EAA Expands the Playing Field

With the European Accessibility Act (EAA) now in effect, France has broadened its scope. Decree No. 2023‑931 transposes the EAA into national law, extending accessibility obligations to:

  • E-commerce platforms
  • Banking and payment services
  • Transport apps and ticketing systems
  • Consumer hardware and software interfaces
  • Digital documentation and product info

This marks a shift from “just public sector” to a fully digital economy model — where most businesses will need to prove their services are usable by all.

What French Accessibility Act Requires in 2025?

Businesses must now prepare not just for WCAG 2.1 or EN 301 549 compliance, but for a French interpretation of these standards – codified in domestic law and enforced across multiple sectors. 

France’s implementation adds structure and legal force to accessibility expectations, so companies must ensure that:

  • Digital content follows WCAG 2.1 Level AA and EN 301 549

For PDFs, this means tagging content structures (headings, lists, tables), setting reading order, and ensuring compatibility with screen readers like NVDA or JAWS.

  • Products and services function with assistive technologies like screen readers, voice recognition software, and screen magnifiers
  • Accessibility statements, testing results, and feedback mechanisms are made publicly available
  • Online documentation is accessible and linked clearly from physical products
  • Compliance documentation is maintained in accessible way (technical files, conformity declarations)

Your PDF manuals, onboarding guides, or financial statements must not only be accessible but provably so — through technical files or audit reports.

  • Labels, instructions, and UIs are legible and perceivable for users with disabilities 

These requirements apply to both consumer-facing and B2B products and services, with a particular focus on e-commerce, banking, insurance, utilities, transport, and telecommunications.

What are RGAA Exemptions?

France, like most EU countries, has adopted the microenterprise exemption provided in Article 4 of the EAA. This means that:

  • Businesses with fewer than 10 employees, and
  • Less than €2 million in annual turnover or balance sheet total are exempt from EAA obligations

However, public sector suppliers, service providers, and certain regulated industries may still need to comply, even if technically exempt, due to overlapping laws (e.g. RGAA or sectoral requirements).

How France’s Accessibility Act is Implemented?

France transposed the EAA through a coordinated set of laws, decrees, and orders throughout 2023:

Notably, French law avoids vague language: standards are named explicitly, and enforcement powers are clearly defined.

France’s Extra Requirements of RGAA You Need to Know About

France doesn’t stop just at aligning with the EAA. It adds layers of requirements under existing national frameworks:

  • The RGAA mandates manual audits, accessibility statements, and feedback tools for public websites and apps

Manual audits ensure the real-life accessible usability. That’s why it’s essential to choose the right partner team—one that doesn’t just run documents through tools like the PAC app, but also has proven experience in delivering true accessibility. The handcrafted approach ensures compliance not by ticking boxes on a checker screen, but by testing how people of diverse abilities actually interact with content—making accessibility both compliant and genuinely usable.

  • Even private companies must adopt WCAG-aligned standards when offering public-facing digital services
  • Periodic reporting and public disclosures are required for certain sectors

This layered approach means that simply meeting EAA minimums isn’t enough – local compliance expectations go deeper.

Harmonized Standards to Follow

French regulators reference the same harmonised standards recognised across the EU:

  • EN 301 549 – covers accessibility of ICT products and services
  • WCAG 2.1 AA – the benchmark for accessible web and mobile content

For Physical Products

  • Labels and manuals must support multisensory accessibility: font size, colour contrast, spacing, tactile elements
  • Information must be available in alternative formats and perceivable via vision, hearing, or touch

For Digital Documentation

  • PDFs, instructions, and online help must follow WCAG and be compatible with:
    • Screen readers (NVDA, JAWS)
    • Braille displays
    • Voice commands
    • Keyboard navigation

What are Deadlines and Penalties for RGAA Incompliance?

France’s EAA obligations will apply from 28 June 2025, in line with the EU-wide deadline. The law has been integrated through Law No. 2023-171, Ordonnance No. 2023-859, and Decree No. 2023-931, creating a multi-layered enforcement system.

Enforcement Bodies Rely on Sector Type

  • Market surveillance authorities will oversee products and services falling under the EAA
  • DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes) will handle consumer market compliance
  • DINUM continues to enforce the RGAA for public-sector digital services, which operates in parallel to EAA requirements

Penalties for RGAA Incomplinace

  • EAA-specific violations are generally treated as Class 5 offenses in France, with fines of up to €1,500 for individuals and €7,500 for organizations, repeatable for ongoing non-compliance

Additional Penalties under Montchamp Law

Under the long-standing Law No. 2005-102 (Montchamp Law), large private-sector companies (annual turnover ≥ €250 million) can face fines of €50,000 for non-compliance with accessibility obligations, plus €25,000 for missing required declarations or accessibility plans. These penalties can recur every six months until compliance is achieved.

⚠️ Fines of €50,000 can apply not only to inaccessible websites — but also to downloadable forms, onboarding documents, or PDF manuals used in public-facing services.

This dual framework means that EAA obligations in France are reinforced by existing national laws that already carry substantial penalties for certain organizations.

Why PDF Accessibility Matters in France’s Compliance Landscape

PDFs remain one of the most widely used formats for digital content — from financial disclosures to user manuals and application forms. Under the French EAA framework, inaccessible PDFs — recurring ones and templates — can be just as non-compliant as broken websites or inaccessible apps.

Here’s where businesses often miss the mark:

  • Visual-only scans with no semantic tags
  • Missing alternative text for diagrams or infographics
  • Incorrect reading order for screen readers
  • Lack of keyboard navigation support

At Quertum, we specialize in auditing, fixing, and validating PDF documents for compliance under WCAG 2.1, EN 301 549, and RGAA 4.1 — helping you avoid fines and protect your brand.

Summary

France’s EAA implementation builds on one of Europe’s most established accessibility frameworks. Businesses must meet both the EU directive’s core requirements and long-standing national obligations under the Montchamp Law and RGAA. This results in broader scope, clearer rules, and a stronger enforcement model. Penalties range from €1,500 for standard violations to €50,000 for large companies, with recurring fines for ongoing non-compliance. Accessibility is not new in France, it is a deeply rooted legal expectation that requires early preparation and continuous compliance.

Graphic showing the Quertum logo, the title ‘German Accessibility Act: What Business Can Expect from BFSG?’, and a silhouette of Germany in black, red, and yellow with an accessibility symbol in the center, set against a dark blue gradient background with green outlined shapes.

EU Accessibility Act in Germany: What Business Can Expect from BFSG?

Written by Kateryna Klynovska on . Posted in EEA.

In our previous article, we explored the main pillars and risks of non-compliance with the European Accessibility Act (Directive 2019/882). Now, let’s turn to Germany — where the Accessibility Act becomes national law under the Barrierefreiheitsstärkungsgesetz (BFSG).

Germany’s national implementation of the EAA came into force on 28 June 2025. The BFSG law is designed to bring key products and services in line with accessibility standards, without expanding beyond the EU baseline like Poland does. While it follows the directive closely, the German Act introduces specific rules around exemptions, enforcement, and transitional periods that businesses should pay attention to.

What Sets the German Act Apart? 

Germany has largely aligned its implementation with the requirements of the EU Accessibility Act, introducing specific provisions around enforcement and transitional rules. The national law closely mirrors the directive’s scope and technical standards, relying on WCAG 2.1 Level AA and EN 301 549 as key accessibility benchmarks. The BFSG applies to a defined list of consumer-facing products and services, particularly in the digital, banking, telecom, and retail sectors.

What Products and Services should Be Accessible under German Accessibility Act?

The BFSG applies to a wide range of products and digital services offered to consumers. These include:

Products covered:

  1. Consumer computer hardware and operating systems
  2. Self-service terminals:
    • Payment terminals, ATMs, ticketing and check-in machines
    • Interactive terminals (excluding those integrated into vehicles or transport systems)
  3. Consumer telecom and media devices with interactive or computing capabilities
  4. E-book readers

Services covered:

  1. Consumer telecommunications services (excluding machine-to-machine transmission)
  2. Elements of passenger transport (air, bus, rail, waterborne), excluding local/regional services
  3. Websites and mobile apps
  4. E-tickets and real-time travel information (via interactive screens in the EU)
  5. Interactive self-service terminals for transport services (within the EU)
  6. Consumer banking services
  7. E-books and related software
  8. E-commerce platforms and services

The law applies to both manufacturers of the listed products and service providers offering them to consumers in the EU market, whether operating within Germany or serving German consumers cross-border. It focuses on areas where digital accessibility has the most direct consumer impact, particularly in everyday commercial transactions and public-facing technologies.

How the European Accessibility Act Affects Businesses in Germany?

Germany’s BFSG transposes the EAA almost directly and not beyond, introducing harmonized technical standards but tailoring its rules for enforcement and timelines. For businesses in banking, insurance, telecom, public sector, e-commerce, and transport, this means:

  • All digital content must meet WCAG 2.1 AA accessibility criteria (including accessible PDFs).
  • Products and services must function seamlessly with assistive technologies.
  • Physical product labels and instructions must meet defined legibility standards.
  • Online documentation must be publicly accessible and in an accessible format.
  • Businesses must be able to demonstrate compliance efforts through technical documentation, testing reports, and accessibility declarations.

What are Exemptions for German Accessibility Act?

Under Article 4(4) of the European Accessibility Act, the BFSG excludes several areas from its scope:

  • Products and services designed solely for professional or business-to-business use — not intended for consumer markets.
  • The built environment connected to services, such as physical buildings or facilities, which remains outside the BFSG’s remit.
  • Urban, suburban, and regional public transport services — although some elements still fall under accessibility obligations. For example, self-service terminals for ticketing or check-in must comply, while the associated websites and mobile apps are usually regulated under the Public Sector Web Accessibility Directive (2016/2102).

The BFSG also avoids certain broader equality objectives found in other German laws, such as specific protections for women with disabilities or the expanded anti-discrimination grounds listed in § 1 of the General Act on Equal Treatment (AGG).

Exemption for Microenterprises

Microenterprises — defined as having fewer than 10 employees and an annual turnover or balance sheet total under €2 million — are exempt from the BFSG’s mandatory requirements.

This exemption narrows the law’s reach for the smallest businesses, while leaving SMEs and large enterprises fully accountable for compliance.

Controlled Exemptions for Legacy Systems and Contracts

Germany has also introduced targeted transitional provisions to avoid immediate disruption:

  • Service contracts signed before 28 June 2025 can continue without modification until they end, but no later than 27 June 2030.
  • Self-service terminals (e.g., ATMs, ticket machines, kiosks) installed before 28 June 2025 may remain in operation for up to 15 years from installation, provided they met applicable standards at the time.
  • Existing devices and software are not subject to retroactive changes — but any new deployment after June 2025 must meet BFSG requirements immediately.

These measures create phased compliance pressure: companies have more time to address older assets, but cannot delay upgrades indefinitely.

Considerations for Medical and Digital Health Products

Medical devices themselves are generally excluded from the BFSG. However, exceptions apply if:

  • The device’s software is accessed via a covered product, such as a smartphone or tablet.
  • An online platform sells medical devices or provides related services directly to consumers — such as registration, appointment booking, or e-commerce transactions.

In these cases, the digital interface must meet BFSG accessibility requirements.

Other Notable Exemptions

The BFSG also recognises situations where accessibility obligations do not apply, including:

  • Third-party content not funded, developed, or controlled by the economic operator.
  • Certain local and regional public transport services, unless other German or EU laws impose accessibility requirements.
  • Medical devices, unless accessed through a covered consumer-facing interface, in which case the interface must still comply.

Disclosure Rules for Digital and Physical Accessibility

While the BFSG mandates accessibility, it references “essential requirements” in EU law and harmonized standards rather than prescribing every technical detail.The BFSG applies to a wide range of products and digital services offered to consumers. Two standards are central for proving compliance:

  • EN 301 549 – Harmonized European ICT accessibility standard.
  • WCAG 2.1 AA – International benchmark for digital accessibility, incorporated into EN 301 549.

These standards define measurable requirements for:

For Physical Products:

  • Labels and instructions must have adequate font size, colour contrast, and spacing.
  • Information must be available in multiple sensory forms — supporting users with visual, auditory, or cognitive disabilities.

For Digital Documentation (including PDFs):

  • Documentation must be available online in accessible PDF format meeting WCAG and EN 301 549.
  • The link (URL) to the accessible version must be clearly printed on packaging or product materials.
  • Content must be fully compatible with assistive technologies such as:
    • Screen readers (JAWS, NVDA)
    • Braille displays
    • AAC (Alternative and Augmentative Communication) systems

What are Penalties for BFSG Incompliance?

Germany has introduced clear enforcement mechanisms. Non-compliance can result in administrative fines of up to €100,000, as well as potential market restrictions or product bans. Enforcement will be overseen by designated national authorities – such as market surveillance bodies and state-level regulators (Länder) – who may monitor compliance and act on violations under general fair trading rules.

Businesses should also be aware that failure to comply could invite legal challenges or reputational risks, especially in sectors with high public visibility.

What is a Transitional Periods for Accessibility Act in Germany?

The BFSG enters into force on 28 June 2025, with the following transitional arrangements:

  • Existing service contracts signed before 28 June 2025 can remain unchanged until they end, but no later than 27 June 2030, including streaming subscriptions and similar services
  • Service providers may continue using older products, such as tablets, smartphones or e-book readers, that were lawfully in use before 28 June 2025, until 27 June 2030
  • Self-service terminals installed before 28 June 2025 may remain in use for up to 15 years from their installation date, provided they complied with the rules in force at the time

For example, a telecom provider offering self-service kiosks for SIM registration installed in 2022 can continue using them until 2030, while a new installation after 2025 must meet accessibility requirements from day one. Similarly, online service contracts signed before June 2025 need not be retroactively updated for compliance.

These transitional measures are intended to give businesses time to phase in upgrades without disrupting service continuity.

How Quertum supports your Accessibility Journey and Compliance with EAA?

Navigating accessibility requirements under the European Accessibility Act (EAA) doesn’t have to be overwhelming. Quertum helps you make sense of technical standards like WCAG, PDF/UA, and EN 301 549 — and puts them into action, across your real-world documents and systems.

Whether you’re in banking, insurance, telecom, or the public sector, we help ensure your communication channels are compliant, user-friendly, and ready for the new legal landscape in Germany and across the EU.

With Quertum, you get:

✅ Document audits you can act on
We don’t just flag issues — we tell you what they mean and how to fix them. From PDF templates to legacy systems, we identify the gaps and help you close them fast.

✅ Accessibility retrofitting that fits your stack
We integrate with your existing Document Management Systems & Customer Communication Management systems and your workflows — no need to rebuild from scratch.

✅ Compliance that scales with your DMS & CCM
Accessibility is not a one-time project. We help you set up repeatable, scalable processes to ensure ongoing compliance — across teams, channels, and output.

From legal interpretations to tech implementation, our cross-functional team supports you in translating regulations into practical solutions — without the jargon. Start your accessibility journey with confidence.

Summary

Germany’s implementation of the European Accessibility Act offers clarity and consistency, staying faithful to the original directive while acknowledging industry realities through exemptions and phase-ins. For businesses operating in Germany or serving German consumers, the upcoming enforcement date presents both a legal obligation and an opportunity to embed accessibility into product design, customer experiences, and digital infrastructure.

Taking action now means not just avoiding penalties, but building more inclusive services that meet evolving customer expectations.

Next steps for businesses:

  • Audit your current digital products and services
  • Identify contracts, platforms, and hardware in use before June 2025
  • Begin planning for technical upgrades, staff training, and documentation
  • Monitor upcoming guidance from German authorities

EU Accessibility Act in Poland: Details Business Should Know

Written by Kateryna Klynovska on . Posted in EEA.

The European Accessibility Act (EAA) is reshaping how businesses in Europe design and deliver digital services. In our previous article, we shared the main pillars and risks of being incompliant with the European Accessibility Act. Let’s go beyond the common European directive and dive deeper with state-centred approaches.

In this article, we share all you need to know to operate in an EAA-compliant way in Poland, despite being a local or global company.

How European Accessibility Act Affects Poland Business?

Poland’s national implementation of the European Accessibility Act (Directive 2019/882) goes well beyond the EU baseline — introducing stricter obligations, more detailed formatting rules, and a robust enforcement framework. Businesses operating in Poland must prepare not only for compliance with the directive, but also with a more prescriptive and locally integrated legal environment.

What EAA or PAD (Polski Akt Dostępności) in Poland Requires?

  • Digital content must comply with WCAG 2.1 AA (e.g., readable PDFs, accessible websites)
  • Products and services must work with assistive technologies
  • Clear labelling and instructions with adequate font size, spacing, and contrast
  • Online documentation must be publicly available and accessible
  • Businesses must show evidence of accessibility efforts (technical documentation, testing, declarations)

Exemption for Microenterprises

While the EU directive gives Member States the option to exempt microenterprises, Poland applies this exemption across the board. 

This means:

  • Businesses with fewer than 10 employees;
  • Either less than €2 million in turnover or balance sheet total.

This narrows the scope considerably for very small businesses, while placing greater responsibility on SMEs and large enterprises. 

Controlled Exemptions for Mapping and Navigation

While the EU directive allows certain exemptions for mapping and navigation systems, the Polish Act narrows these significantly. 

Interactive maps and geoportals are only exempt if:

  • The data present is already available in a digitally accessible format, and
  • The service complies with Poland’s separate Digital Accessibility Act (2019), which governs public sector websites and apps.

This layered approach ensures that accessibility gaps aren’t created through overly broad expectations. The relevant provisions are found in Article 4(2)(a).

Other Exemptions 

The Act also outlines specific cases where accessibility obligations do not apply. These include:

  • Third-party content not funded, developed, or controlled by the economic operator;
  • Public transport services and local administrative services at the municipal, metropolitan, county, and county-municipal levels, unless otherwise required under other Polish or EU regulations.

These limited exemptions recognize practical constraints while maintaining the overall intent of the law — ensuring accessibility is the rule, not the exception.

Disclosure Rules for Physical and Digital Accessibility

The Polish Accessibility Act does more than require accessibility — it defines how accessibility must be implemented. However, it stops short of listing exact technical specifications. Instead, it refers broadly to “essential accessibility requirements defined in EU law and harmonized standards.”

To navigate this ambiguity, we recommend aligning with the two primary standards recognized across the EU for demonstrating compliance:

  • EN 301 549 – the harmonized European standard for ICT accessibility
  • WCAG 2.1 – the global benchmark for digital content accessibility (incorporated within EN 301 549)

These standards outline specific, testable criteria across both physical and digital domains:

For Physical Products

  • Labels and instructions must meet defined criteria for font size, color contrast, and text spacing, ensuring legibility for users with visual impairments.
  • Information must be perceivable through multiple sensory channels, supporting accessibility for people with visual, auditory, or cognitive disabilities.

For Digital Documentation

  • Documentation must be made available online in an accessible format, compliant with WCAG and EN 301 549.
  • The web address (URL) for this digital content must be clearly printed on the physical product or its packaging.
  • All content must be compatible with assistive technologies, including:
    • Screen readers (e.g., NVDA, JAWS)
    • Braille displays
    • Alternative and Augmentative Communication (AAC) systems

By proactively meeting these harmonized standards, organizations can demonstrate good-faith compliance with the Polish Accessibility Act and reduce their exposure to regulatory risk.

Tightly Defined Legal Terms

Where the EU directive leaves room for interpretation, the Polish legislation introduces precise legal definitions for key accessibility terms. These include: 

  • User interface accessibility – ensuring digital tools are operable, understandable, and robust for all users
  • Real-time communication – defined to include voice, video, and text channels that enable seamless, synchronous interaction 
  • Alternative and Augmentative Communication (AAC) – explicitly referenced, supporting individuals with speech or language impairments
  • Interoperability with assistive technologies – a requirement for ensuring systems work across platforms and devices, not just within proprietary environments

This increased specificity supports legal certainty and simplifies implementation for both product developers and compliance teams.

Multi-Institutional Enforcement Model

Enforcement in Poland will not rely on a single regulator. Instead, it is distributed across multiple institutions to ensure cross-sector compliance:

  • The Ministry of Regional Development serves as the coordinating body
  • PFRON (State Fund for Rehabilitation of Disabled Persons) supports monitoring and expertise
  • Local governments and universities are involved in outreach and technical assistance
  • NGOs focused on accessibility provide oversight and advocacy
  • Customs and market surveillance authorities handle inspections and enforcement in import/export and retail contexts
A visual diagram showing key institutions involved in enforcing the European Accessibility Act (EAA) in Poland. At the center, an icon of a police officer and a person stands beneath a security gate, symbolizing oversight. Surrounding them are five labeled segments: "Ministry of Regional Development" (oversees and coordinates enforcement nationally), "PFRON" (provides technical expertise and disability insights), "Local Governments and Universities" (implement EAA principles locally), "NGOs" (act as watchdogs and user advocates), "Customs and Market Surveillance" (ensure market compliance). Each segment includes a corresponding icon. Background is a gradient of dark blue and purple.

Monitoring begins in June 2026, following the mandatory compliance date of 28 June 2025.

Integration Across Over 10 Domestic Laws

To create a consistent and enforceable framework, Poland has embedded the a wide range of existing legislation, including: 

This cross-law integration makes accessibility a mandatory design principle — not a compliance afterthought. It introduces measurable expectations for both product and service delivery, reinforces risk exposure in regulated environments and aligns national policy with EU enforcement strategy. This integration supports systemic change and positions accessibility as a core requirement, not a side consideration.

Summary

Poland’s approach to accessibility is comprehensive and future-facing. For companies operating in Poland, or exporting to it, compliance with the Polish Accessibility Act requires more than checking boxes. It demands deliberate design choices, legal awareness, and operational readiness. Starting early will reduce risk and help businesses deliver inclusive experiences that meet both regulatory and customer expectations. 

Accessibility logo with human in the circle surrounded by EU yellow stars. All on planet background

European Accessibility Act Compliance by Sector: GDPR Lessons and What to Expect in 2025

Written by IT Administrator on . Posted in EEA, GDPR, Quertum News, Uncategorized.

When the GDPR came into force in 2018, companies had to adapt how they handled personal data. It set a new standard for privacy and introduced penalties that many businesses were unprepared for. Now, the European Accessibility Act (EAA) is following a similar trajectory – only this time, the focus is on accessibility.

The EAA takes full effect on June 28, 2025. The new Directive aims to ensure that digital products and services, such as websites, apps, documents, and ticketing systems, are accessible to people with disabilities across the EU. For many businesses, this will mean redesigning websites, rethinking digital communications, and ensuring that customer-facing services meet accessibility standards like WCAG and PDF/UA. The parallels to GDPR are clear: a sweeping EU regulation, broad applicability, and the potential for significant fines for non-compliance.

Yet few organizations have a clear plan in place to meet the upcoming requirements.

High-Exposure Sectors: Who Will Feel the EAA First?

Industries that rely heavily on digital customer interaction are the first in line. This includes finance, where online banking and digital onboarding are core to the customer journey; retail, where e-commerce platforms and checkout systems must be accessible by default; and transportation, where digital ticketing and self-check-in are now standard. Public services such as healthcare portals and government sites are also squarely within scope, especially given the public-sector accessibility precedents already in place.

In these sectors, the risks often take the shape of inaccessible platforms, customer documents, or service workflows, each of which may soon be considered a legal liability under national enforcement laws. 

What raises the stakes even further is visibility. The more essentially a service is to daily life, the more likely it is to be scrutinized, and the less tolerance regulators will have for inaccessible touchpoints.

One Directive, 27 Penalty Systems

Just like with the GDPR, the EAA leaves enforcement in the hands of EU Member States. This means companies must pay close attention to the specific penalties and compliance expectations in each country where they operate.

Some countries have already outlined substantial fines. In Spain, Ley 11/2023 introduces penalties of up to €1 million per infringement, explicitly covering electronic documents like PDFs. Germany’s Barrierefreiheitsstärkungsgesetz allows for fines of up to €500,000, and in severe cases, non-compliant digital products or services can even be removed from the market.

Elsewhere in the EU, the landscape remains just as serious. France imposes fines of up to €300,000, Czechia up to €400,000, and Hungary has set penalties as high as €1.26 million or 5% of annual net turnover. In Italy, fines can reach €40,000, or up to 5% of turnover under the Stanca Law for private entities.

Enforcement isn’t uniform, and that’s the point. While the EAA sets a harmonized baseline, the risks vary dramatically by jurisdiction. Businesses with operations or customers across multiple countries must be proactive in tracking national developments to avoid falling foul of country-specific enforcement actions. 

For a quick overview of the already established EAA penalties across EU markets, see the table below.

CountryFines
AustriaFines range up to EUR 80 000
CzechiaFines range up to EUR 400 000
FranceFines range up to EUR 300 000
GermanyFines range up to EUR 500 000
HungaryFines range up to EUR 1 261 164 or 5% of the annual net turnover
ItalyFines range up to EUR 40 000 or, for private entities that fall within the scope of the Stanca Law, up to 5% of turnover
The NetherlandsFines range up to EUR 103 000
SlovakiaFines range up to EUR 200 000
SpainFines range up to EUR 1 000 000

From Privacy to Accessibility: How GDPR Prepared Us for the EAA

The GDPR era taught businesses several hard-earned lessons. Some of them can be directly applied to the EAA:

✅ Compliance is a continuous process, not a single deadline

✅ User expectations evolve, and meeting them consistently builds trust

✅ Regulatory alignment can become a competitive advantage

✅ One-size-fits-all solutions rarely work in complex, multi-market operations

✅ Technology alone isn’t enough – internal processes and policy need to support it

Perhaps most importantly, GDPR showed us that EU legislation doesn’t stay theoretical for long. Once enforcement begins, regulators act – especially where clear obligations have been set and ignored.

The EAA will likely follow a similar trajectory. Companies that treat accessibility as a long-term priority, and can demonstrate visible progress, will be in a much stronger position than those that scramble to catch up. Building capability early helps reduce risk, avoid reputational damage, and respond confidently as national enforcement frameworks mature.

EAA Day One: What Happens After June 2025?

The EAA becomes enforceable on June 28, 2025 – but that date doesn’t mark the end of the road. It marks the beginning of active enforcement and increased scrutiny. Compliance won’t be measured by a single audit on that day, but by how well your organization is prepared to show progress, intent, and structure.

Just as with GDPR, regulators are unlikely to expect flawless implementation on day one. What they will expect is a demonstrable plan – evidence that your company understands its obligations and is actively working to meet them. That includes documented audits, defined roles and responsibilities, and timelines for remediating accessibility gaps.

The most resilient companies will treat this moment not as a finish line, but as the launch of a more permanent phase of compliance. Laws will evolve, interpretations will shift, and enforcement will likely become more consistent over time. Establishing regular review cycles, tracking relevant country-level legislation, and integrating accessibility into procurement and development processes will be essential to keeping pace.

June 2025 isn’t the point where you need to have everything perfect. It’s the point where you need to have a credible, visible path forward – and the ability to prove that accessibility is already part of how your organization operates.

Set the Standard, Don’t Chase It

If GDPR taught us anything, it’s that the cost of inaction grows fast. The companies that took early, practical steps toward compliance were the ones that avoided penalties and earned long-term trust. The same holds true for the EAA.

At Quertum, we can help you take those early, practical steps, by making your digital communications accessible, efficiently and at scale. Whether you need support implementing PDF/UA standards or ensuring your customer-facing content meets EAA requirements, we’re here to help you get it right from the start.

Accessibility doesn’t have to be overwhelming.

Quertum helps make it manageable. See how we can support your accessibility implementation.

Summary

The shift from GDPR to the European Accessibility Act (EAA) marks a new phase in EU regulation, this time focused on digital accessibility. Like the GDPR, the EAA has a broad scope and serious penalties, yet many organizations remain unprepared. Industries that depend on digital customer interaction, including finance, retail, transport, and public services, are especially exposed. The more essential and visible the service, the greater the risk of regulatory scrutiny. While the EAA provides a shared EU framework, each Member State sets its own penalties, resulting in varied enforcement across countries. This variation is intentional, which makes staying informed about local requirements essential. A key lesson from the GDPR still holds true: compliance is not a one-time task. Companies that take early steps toward accessibility will be better equipped to manage risk and build long-term trust. June 2025 is not the point when everything must be perfect, but the moment when meaningful progress must be visible.

Image with text 'PDF Accessibility for EAA: How to Start, Where You Stand, and Why It Matters'. On the right side are icons representing WCAG 2, ISO 14289 (PDF/UA), a PDF document with a checkmark, and a universal accessibility symbol, emphasizing compliance and accessibility standards for digital documents under the European Accessibility Act.

PDF Accessibility and EAA: Guide for Compliance

Written by Kateryna Klynovska on . Posted in EEA.

We rarely stop to think about how seamless our digital lives are. But with the PDF Accessibility and European Accessibility Act (EAA) deadline approaching in June 2025, organizations must act now to ensure digital equality — and legal compliance.

We scroll, shop, book, and bank without ever questioning whether the platforms we use are built for us. For the roughly 80 million Europeans living with a disability, though, the digital experience often looks very different, marked by limitations or outright exclusion.

That’s where the European Accessibility Act (EAA) comes in. From 28 June 2025, businesses offering digital services or selling certain products in the EU will need to meet strict accessibility standards. It’s a major step toward creating a more inclusive digital economy, and it’s going to impact everything — e-commerce platforms, e-books, insurance documents, ticket machines, shopping platforms, banking statements and apps. You can read more on our previous blog about how enterprises are preparing to EAA in different European countries.

The directive has been in motion for years, but many organizations still haven’t taken real steps to prepare. Meanwhile, industry leaders are quietly doing the work and positioning themselves to gain compliance and a competitive edge.

If you’re not there yet, you’re not alone. However, you are now at a decision point – move forward or fall further behind?

All Starts from Growth Mindset

There’s a tendency to frame accessibility in regulatory terms, as a box to tick, a deadline to meet, or a risk to avoid. Yet, for businesses that want to squeeze more from opportunity and lead, not just comply, the EAA offers something far more valuable. Namely, a clear reason to improve the user experience for everyone. 

Early adopters are already seeing the benefits. Some retailers, for instance, report up to a 35% increase in conversions after making their digital platforms more accessible. That’s because accessibility improvements often go hand-in-hand with better usability – not just for people with disabilities, but for everyone. We’re talking about cleaner interfaces, clearer navigation, consistent content structures, features that make digital experiences more intuitive. They reduce friction, spark innovation, build trust, and keep customers coming back. 

Essentially, being EAA-ready doesn’t only protect you from fines and sanctions, it also positions you as a business that understands where the market is going – and is prepared to lead in the right direction. 

First Steps to Get Accessibility

So what does it look like to get serious about accessibility when you may be starting a little later than others? 

The first step is very simple: figure out where you stand. That means inspecting your website, apps, service platforms and internal tools, not merely for obvious issues like missing alt texts or contrast failures, but for structural barriers that affect real user journeys. 

  • Can a customer complete a purchase without using a mouse? 
  • Is your chatbot accessible by screen reader? 
  • Do your mobile experiences meet the same standards as desktop?

Of course, these aren’t questions for a single compliance officer to answer. Accessibility touches product, design, development, customer service, and legal operations, which means it has become a shared priority, not a siloed task.

Don’t know where to start EAA preparations? For the first touchpoint, you can download our WCAG 2.1 and PDF Accessibility guides for free (no email address is required). Those guides are created for: 

  • Better understanding of your PDF/UA and WCAG compliance situation
  • What makes PDF documents and site accessible
  • Understanding on how to fix first accessibility red flags.
Download a WCAG 2.1 Guideline
Download a PDF Accessibility Guideline

These guides could be your roadmap to EAA preparations and how to be compliant with PDF/UA (ISO 14289), EN 301 549, and WCAG 2.1. By the way, both of those PDFs are accessible and PDF/UA compliant 🙂

Closing the Gap Without Falling Behind

When time is short and pressure is high, it’s tempting to search for shortcuts. But accessibility isn’t something you can just add on at the end of the process. Real progress means building a roadmap that accounts for both short-term fixes and long-term change.

Yes, some updates are straightforward: adjusting colors, labelling buttons, adding keyboard support. These can and should be addressed quickly. However, other work, such as redesigning navigation flows, integrating with assistive tech, or rethinking your content strategy, takes more time, more collaboration, and more care. 

This doesn’t have to mean halting business as usual – accessibility can be integrated into agile workflows and existing development cycles. In fact, some of the most effective efforts happen incrementally. The key is to start, and to treat accessibility not as a project with an end date, but as a part of how you build and maintain digital services going forward.

Don’t Stop on Alt Text Only

It’s easy to fall into the trap of performative accessibility, making a few quick, visible changes like adding alt text or tweaking colors, and assuming the job is done. However, real accessibility is more than mere appearances, it is also about outcomes: can users with diverse needs actually complete tasks, access information, and engage with your service without barriers?

While alternative text is an essential part of accessibility, it’s only one piece of the puzzle. A truly accessible PDF requires correct tagging structure, proper reading order, logical headings, usable tables, form field labeling, color contrast checks, and more.

Passing an audit once doesn’t guarantee long-term compliance — especially under the European Accessibility Act, where consistency and future updates matter. That’s why accessibility must be systemic, not superficial.

The truth is, accessibility is only meaningful when it works for real people navigating real challenges. That means going beyond checklists to understand how users actually experience your site or service – and whether they’re truly able to use it. 

Even a website that passes today’s audit may fail tomorrow if updates are made without accessibility in mind. Regular testing, feedback from users with disabilities, and iterative improvements are what separate superficial fixes from sustainable progress.

Additionally, there’s value in openness. Letting your customers know you’re working on accessibility,  even if you’re not there yet, can earn you credibility. It signals that you care, that you’re listening, and that you’re committed to building a better digital experience. 

Why PDF Accessibility Demands More Than Automation

Making your PDFs truly accessible isn’t as simple as running an auto-check or pressing a “Make Accessible” button in Adobe. While tools can help flag issues, they rarely deliver fully compliant, user-friendly results on their own — especially when it comes to complex layouts, interactive forms, or branded documents that rely heavily on custom styling.

The challenge? Maintaining visual consistency and brand integrity while ensuring that every element — from tables and infographics to reading order and form fields — works seamlessly with assistive technologies. Automated fixes often flatten design, strip meaning, or miss key accessibility gaps altogether. Worse, they can create a false sense of security while leaving you exposed to compliance risks.

This is not something most internal teams are equipped to handle alone — especially under time pressure. That’s why many organizations partner with accessibility experts who not only understand the technical requirements (PDF/UA, EN 301 549, WCAG 2.1), but also know how to preserve design and user experience throughout the process.

It’s Not Too Late, But It Is Time

This is your chance to step back and ask: How do users move through our services? Where do they get stuck, frustrated, or excluded? What would it look like to make every touchpoint intuitive, inclusive, and seamless?

Accessibility doesn’t sit in a vacuum. It intersects with your ESG goals, your DEI commitments, and your customer experience ambitions. Leading companies are already drawing these lines, and using them to futureproof their strategies. 

So yes, the clock is ticking, but getting serious about accessibility now puts you in a position to lead, not scramble to catch up later. 

Summary

With the European Accessibility Act deadline approaching on 28 June 2025, industry leaders are already working toward compliance and gaining a competitive edge in the process. However, even if you’re behind now, it’s not too late to start. Accessibility isn’t only about ticking boxes. Done well, it improves the experience for everyone, and early adopters are already seeing the benefits. The first step is understanding where you stand and recognizing that accessibility touches every part of your organization. It’s not a one-off project, but an ongoing commitment. Avoid the trap of quick fixes that don’t serve real users. Instead, use this moment to rethink how your digital experiences can be more inclusive and take the first step now. 

Accessibility logo on left-hand side. PAC app accessibility checker on right-hand side.

Is Your Business Ready for the 2025 European Accessibility Act?

Written by Kateryna Klynovska on . Posted in EEA.

The European Accessibility Act (EAA) is reshaping the digital landscape in the EU. At its core, the EAA aims to break down barriers and ensure that a wide array of products and services are accessible to everyone, including the millions of people with disabilities across the European Union (EU). This extends beyond simply using an accessibility checker; it necessitates embedding accessibility into your design thinking, from websites to all customer communications. A key challenge is that the EAA’s requirements, while comprehensive, can sometimes be perceived as broadly defined. As a result, many organizations do not realize that the EAA also applies to documents, including PDFs, which are a critical component of their communication workflows. 

While EU member states were required to transpose the EAA into national law by June 2022, the critical date is June 28, 2025, when full enforcement begins. This day marks the point when the requirements of the EAA will become legally binding for a vast number of businesses operating within the EU. The window for delaying serious action has effectively closed. Procrastination now carries significant risks, not just from a legal standpoint, but also in terms of market reach and brand perception.

Across Europe, the EAA is no longer a set of “nice-to-have” guidelines, it now carries a price tag on every website, mobile app, and PDF your company sends. Spain’s Ley 11/2023 tops the list with fines that scale up to €1 million per infringement and it explicitly names electronic documents, obliging all outgoing PDFs to meet the PDF/UA tagging standard. Germany’s Barrierefreiheitsstsärkungsgesetz lets market-surveillance authorities impose penalties of €100 000 and even ban a product or service until it is accessible. Sweden will start handing out sanctions of up to 10 million SEK (~€870 000) for inaccessible e-commerce or banking interfaces when its new law takes effect on June 28th 2025. Similarly, in Finland, Traficom can now hand out fines up to €150 000 – and escalate them daily – until defects are fixed. Taken together, these moves make one thing clear: ignoring accessibility is no longer a technical oversight, but a severe financial risk for all companies operating within the EU. 

Overlooking Digital Accessibility? You’re Ignoring 15% of the Global Market

Even if your organization believes it falls outside the direct scope of the EAA, overlooking accessibility in your communication processes is a significant strategic oversight. In today’s interconnected world, inclusivity isn’t simply a moral imperative, it’s a powerful business driver. Consider the sheer potential of reaching the approximately 15% of the global population with disabilities – a substantial market segment often unintentionally excluded by inaccessible communication.

By proactively making your websites, PDF materials, social media content, and customer service channels accessible, you unlock a wealth of opportunities. 

  • Imagine what could happen if every prospective customer could actually use your website, app, or documents without a struggle. Accessible design unlocks an entire segment of the market that might otherwise give up and look elsewhere. Simple steps like applying real heading tags or marking up lists properly can be the bridge that invites them in.
  • Accessibility also earns loyalty. When people see that you’ve taken the time to add descriptive alt-text to images and graphs, they recognize a brand that genuinely cares. That kind of respect sticks – it turns first-time buyers into long-term advocates.
  • And let’s be honest, in a crowded marketplace, “we’re easy for everyone to use” is a big differentiator. Companies that advertise their commitment to inclusive design attract customers who want to spend with businesses that share their values. Regular checks with an accessibility scanner or PDF-testing tool show you’re not only compliant today, but ready for whatever tomorrow’s standards require.
  • Finally, what helps some helps all. Clear language, logical structure, keyboard-friendly navigation – these aren’t just accessibility wins, they’re SEO boosters and usability upgrades for every visitor. Streamline the reading order, make that checkout flow effortless, and watch both your search ranking and your customer satisfaction rise together.

The Accessibility Gap Is Closing – But Not Evenly

In just two years, the share of companies actively planning for accessible PDFs and digital communications has more than tripled. According to industry data, 66% of surveyed companies now have a roadmap for PDF/UA compliance, signalling a clear shift toward inclusive design. At the same time, many public-facing websites, especially in the Nordics, are already scoring exceptionally well for Web Content Accessibility Guidelines (WCAG) compliance, showing what’s possible when accessibility is treated as a strategic priority.

Yet the distance between early movers and the rest of the market is growing. An early 2025 AbilityNet survey found that just 11% of organizations feel confident they’ll meet the EAA deadline. For many, the challenge isn’t a lack of intent, it’s about knowing where to start and how to scale accessibility across documents, channels and teams. That’s where experienced partners like Quertum can help – bridging the gap between legal requirements and real-world implementation with clear audits, hands-on remediation, and long-term support. As compliance becomes a baseline expectation, the companies that act now won’t just meet the standard, they’ll help set it.

The Urgency is Real: Take the Next Step Now

The June 2025 deadline is closer than it seems. Organizations that postpone action on the EAA risk legal penalties and, just as critically, the loss of a sizable customer segment. Whether you’re just beginning or scaling your efforts, now is the time to move beyond acknowledgement and embed accessibility – at minimum PDF/UA compliance and WCAG AA standards – into everyday processes and communications. Now is the moment to move beyond acknowledgement and weave accessibility – at minimum PDF/UA compliance and WCAG AA standards – into everyday processes and communications. Don’t just catch up – lead the way into a more inclusive digital future.