Legacy CCM vs European Accessibility Act: Why to Initiate Migration in 2026?

In our last article we already unpacked how The European Accessibility Act (EAA) has fundamentally changed the rules of engagement for banks, insurers, and utility providers. If you are still relying on a print-era engine to drive digital conversations, you have likely noticed a painful reality: your documents might look perfect to the human eye, but to a machine (and the law), they are invisible.

For years, accessibility was treated as a “nice-to-have” or a post-production patch, and these days are gone. With the EAA enforcement deadline looming, sticking to Legacy CCM systems is no longer just a technical debt issue,  but it’s becoming a compliance gamble in 2026.

The 30-Second Read

• The Problem in a nutshell: Old CCM platforms place text on a page using X/Y coordinates (print logic). Accessibility standards require HTML-like tags and semantic structure (digital logic).
• The Risk: Regulators treat inaccessible system outcomes a failure of service. The financial and reputational costs are already visible in global enforcement cases.
• The Solution: Retrofitting is expensive. Migration to a modern platform like Quadient Inspire is already counted as the most cost-effective and future-proof way for strategic business sustainability in regulated landscape.

The “Print-First” Trap: Why Legacy CCM Fails

Most legacy platforms were built when “customer communication” meant printing a letter and putting it in an envelope. They excel at placing ink on paper with pixel-perfect precision.

However, accessibility requirements demand context, not just placement. A screen reader needs to know that a bold line of text is a Header (H1), not just “bold text”. It needs to know that a grid of numbers is a table with rows and headers, not a random collection of floating integers.

Trying to force a print-based system to generate accessible documents is like trying to turn a typewriter into a web browser. You can force it to work with enough glue and plugins, but it will never be scalable.

The Hidden Cost of “Bolted-On” Compliance

Some organisations attempt to solve this with post-processing tools — software that scans a PDF and tries to guess the tags. This is a dangerous strategy, and here is why:

• Fragile workflows: If a marketing team changes a disclaimer layout, the automated tagger often breaks without even a warning.
• No audit trail: You can not prove governance if your accessibility relies on a “black box” fix applied at the last second.
• Performance drag: Retroactive tagging slows down batch processing, threatening SLA deadlines for delivery.

The Business Case: The Real Cost of Fines

While internal operational friction is annoying, the external financial threat is immediate. It is important to look at the broader regulatory landscape to understand the risks and how the world of regulation behaves globally. While the EAA is new, the legal logic behind it, punishing organisations for denying service via inaccessible documents, is well-established globally.

Global Precedents: The “Document Liability” Warning

Though ADA (Disabilities Act in the USA) and EAA are different in scope and jurisdiction, both treat inaccessible communication as a barrier to equal service. For instance, Wells Fargo settled a case with the U.S. Department of Justice for $16 million in 2011 after failing to provide accessible bank statements and forms in alternative formats like large print, Braille, and properly tagged digital files. The case reinforces how inaccessible documents are not considered technical faults but as legal liabilities.

Recent European Enforcement

“Closer to home”, European regulators are already proving they will enforce similar standards:

• Vueling Airlines (Spain): Fined €90,000 for inaccessible digital channels. While this focused on interfaces, it confirms that digital barriers attract significant penalties.
• UBS (Switzerland): Ordered to pay CHF 20,000 regarding inaccessible online banking. The regulator’s message was clear: digital exclusion is a punishable failure.

The EAA simply extends this logic explicitly to your PDF/UA documents and customer communications.

Why Legacy CMM Migration Attracts So Much Attention of Banking and Insurance Leaders?

Meeting WCAG guidelines requires a platform that understands structure from the moment a template is designed. Modern platforms like Quadient Inspire do not “scan” for accessibility; they build it into the DNA of the document.

1. Omni-channel Consistency

Modern ecosystems separate content from presentation. You create the message once, and the system generates a compliant PDF for archiving, an accessible HTML5 email for mobile, and a tagged format for the web portal. This automation ensures consistency across all channels without triplicating the effort.

2. Risk Mitigation (Compliance by Design)

When you migrate, you shift from “detecting errors” to “preventing them”. Designers use templates with pre-approved accessibility blocks. If a font size is too small or a colour contrast fails accessibility standards, the system flags it before production, not after.

3. Future-Proofing

The EAA is just the beginning, and regulations will tighten. CCM migration allows you to adapt to new mandates (like EN 301 549 updates) via software updates rather than rewriting your entire codebase.

FAQ

Can the 2030 transition period delay our migration plans?
Only for historic contracts. All new customers must receive accessible documents now, so postponing migration increases cost and complexity.

Does accessibility slow down batch processing?
Modern platforms build structure and layout simultaneously, so batch performance remains stable.

Are the automated tagging tools enough for compliance?
No. Automated fixes cannot guarantee full alignment with the WCAG 2.1 or PDF/UA standards. Accessibility must be built into the template.

Conclusion: The Era of Static Documents is Over

The European Accessibility Act is forcing a necessary evolution in how organisations handle data distribution. Sticking to Legacy CCM systems is a choice to face regulatory scrutiny and potential financial penalties like those seen in the Wells Fargo and Vueling cases. CCM migration is not just an IT upgrade; it is a strategic move to protect your brand and your bottom line.

Read how to Migration made simple and how to go with it confidently in 6 steps.
And don’t wait for the first fine. Contact our team to review risks and determine your optimal CCM migration strategy.