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Which Sectors Are in Focus Under the EAA? GDPR Lessons and What to Expect in 2025

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 organisations 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 essential a service is to daily life, the more likely it is to be scrutinised, 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 harmonised 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.

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 organisation 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 organisation 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 organisations 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.

PDF Accessibility and EAA: How to Start, Where You Stand and Why It Matters

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.

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. 

The Clock is Ticking: Is Your Business Truly Ready for the 2025 European Accessibility Act?

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, now (April 30, 2025) only a few months away, 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 recognise 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 sizeable 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.