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Graphic showing logos of SAS, Vueling, UBS, and AccessiBe on a dark background, representing high-profile organisations involved in digital accessibility controversies. On the right, the Quertum logo appears above a green label reading ‘Field Notes on Inclusion,’ followed by the title ‘Real Cases & Financial Impact of Digital Non-Accessibility.’ The design highlights real-world enforcement and financial risks related to accessibility failures.

Calculating the Accessibility Non-Compliance Costs: Real Cases & Financial Impact

Written by Kateryna Klynovska on . Posted in EEA.

“Accessibility penalties are not theoretical” – that what we hear from every newspoint from the Europen Accessibility Act inforcement. Though in truth, they never were. In the USA and some EU countries, accessibility violations have long been treated as discrimination issues with legal consequences. Yet many businesses dismissed them as rare enforcement actions that “wouldn’t happen to us.”

The European Accessibility Act has changed that calculation entirely.

We analysed not only the headline-grabbing EAA announcements but dug deeper, and discovered something striking: accessibility topic has evolved from quiet supervision to loud enforcement. The cases below aren’t distant warnings or isolated incidents. They’re recent, high-profile examples where inaccessible digital services triggered significant financial penalties, operational restrictions, and reputational damage. More importantly, they serve as early indicators of how enforcement under the EAA and related regulations will evolve across Europe.

As we approach 2026, digital-based industries like e-commerce and already heavily regulated services like online banking face unprecedented scrutiny. Learn those real-world cases that illustrate how inaccessible digital services lead to measurable consequences and serve as early indicators of how EAA enforcement will evolve across Europe.

Vueling – A Well-Known Spannish Lowcost Airlines (Spain, 2024)

Spain’s National High Court fined Vueling €90,000 and temporarily barred the airline from receiving public funds after its website was ruled inaccessible under national law. Vueling’s website failed to meet accessibility standards required under Spanish Royal Decree 1112/2018, which mandates WCAG 2.1 Level AA compliance for all public-facing digital services. The court found that customers with disabilities could not independently book flights, check in, or manage reservations — the core functions of an airline’s digital platform.

The Consequence: Beyond the direct fine, Vueling’s exclusion from public funding eligibility represented a significant operational restriction. For airlines dependent on government contracts, subsidies, or participation in public transport programmes, this penalty creates cascading financial impact far exceeding the initial €90,000.

What Does This Mean?

This was one of the first major private-sector enforcement cases directly linked to EAA implementation, setting a precedent that non-compliance results in both financial penalties and operational sanctions. Spanish regulators demonstrated willingness to use multiple enforcement mechanisms simultaneously — a strategy other EU member states are now replicating.

AccessiBe – Web Accessibility Company Powered With AI (USA, 2024)

The U.S. Federal Trade Commission fined AccessiBe $1 million for making deceptive claims about its AI-powered widget’s ability to make websites WCAG compliant. AccessiBe marketed its automated overlay tool as capable of achieving full WCAG compliance through AI-driven code injection. The FTC found these claims misleading — the widget could not deliver genuine accessibility and, in many cases, actually created new barriers for assistive technology users.

The Consequence: Beyond the $1 million penalty, AccessiBe must cease making unsubstantiated accessibility claims and notify customers that their widget does not guarantee compliance. The settlement sends a clear regulatory signal: automated shortcuts will not satisfy legal obligations.

What Does This Mean for EU Businesses?

Many European companies currently rely on similar overlay solutions, assuming they provide adequate EAA protection. This case signals rising regulatory scepticism towards automated fixes across jurisdictions. Genuine accessibility work includes manual audits, proper code remediation, template-level fixes. Theywill be required to meet compliance obligations. Overlays may supplement accessibility efforts but cannot replace them.

SAS: The “Impossible to Use” Website (Norway, 2017–2018)

Again we have case with customer-first communication channel, which does not meet the minimal accessibility. Norwegian regulator Difi threatened Scandinavian Airlines with daily fines of approximately €15,000 after its redesigned booking website failed 20 of 28 tested WCAG success criteria.

In 2017, SAS launched a redesigned website that immediately drew complaints from disability organisations. Norway’s Agency for Public Management and eGovernment (Difi) conducted an audit under the country’s Equality and Anti-Discrimination Act, which mandates WCAG 2.0 AA compliance.

The results were damning. Specific failures included:

  • No keyboard navigation support – interactive elements couldn’t be reached without a mouse (violating WCAG 2.1.1, 2.1.2)
  • Insufficient colour contrast for text (failing WCAG 1.4.3)
  • Missing alt text for images, icons, and even the SAS logo
  • Inaccessible CAPTCHA with no non-visual alternative
  • Unlabelled form fields and error messages relying solely on colour cues

Difi’s official verdict described the site as “impossible to use” for disabled customers — a quote that became infamous in Norwegian media.

The Enforcement Timeline

  • November 2017: Difi releases audit findings, gives SAS one year to remediate.
  • Mid-2018: Follow-up audit shows significant problems remain unresolved.
  • August 2018: Difi issues 10-day ultimatum with threat of NOK 150,000 (~€15,000) daily fines.
  • Final deadline: SAS resolves critical issues just in time to avoid penalties.

The Consequence: Whilst SAS ultimately avoided the daily fines by achieving compliance before the final deadline, the case generated extensive negative publicity. Headlines like “SAS website gets failing grade” and “SAS risks fines for new website” ran in major Norwegian newspapers. The threat of €15,000 daily accumulating fines forced immediate action and resource allocation.

What Does This Mean?

The SAS case demonstrates how daily penalty mechanisms work: an initial audit identifies violations, a compliance period allows remediation, then escalation to accumulating fines when progress stalls. Norway’s enforcement model shows that even large private companies face accountability for WCAG failures, and that daily fines create powerful incentives for rapid compliance.

By the way, SAS’s competitor, Norwegian Air, had invested in accessibility proactively and passed its Difi inspection with only minor comments — a fact widely noted during the controversy, demonstrating competitive advantage for early adopters.

Union Bank of Switzerland

UBS faced a 20,000 CHF fine plus mandatory remediation after its online banking platform was found to exclude visually impaired customers from basic operations like account login and transactions.

UBS’s digital banking interface was not screen reader-friendly or keyboard-navigable, effectively denying blind users independent access to their accounts. This violated Switzerland’s accessibility standards (based on WCAG 2.0/2.1 Level AA) and constituted discrimination under Swiss disability law.

Specific issues included:

  • Missing screen reader labels and alt text (violating WCAG 1.1.1)
  • Inadequate keyboard navigation (violating WCAG 2.1.1, 2.4.7)
  • Critical interactive elements rendered inaccessible to assistive technology users

Swiss authorities ordered:

  • Immediate payment of 20,000 CHF fine
  • Mandatory accessibility improvements within 6 months
  • Compensation for affected customers who had been unable to use online services
  • Accessibility training for staff to prevent recurrence

What Does This Mean?

The UBS case demonstrates that financial services face particularly strict scrutiny. Banking accessibility isn’t just about compliance. But it’s about fundamental access to financial services, which courts and regulators treat as essential infrastructure.

Notably, Swiss law allows individual discrimination claims with awards up to CHF 5,000 per person. For banks with thousands of affected customers, the potential liability extends far beyond the initial fine. The requirement to compensate affected users sets a precedent that inaccessibility creates measurable financial harm requiring restitution.

Common Patterns Across Enforcement Cases

These cases reveal consistent enforcement approaches emerging across jurisdictions:

1. Multiple Penalty Mechanisms: Financial fines (fixed or daily accumulating), operational restrictions (funding eligibility), mandatory remediation timelines, customer compensation requirements, and staff training obligations.

2. Focus on Core Functionality: Regulators prioritise accessibility failures that prevent users from completing essential tasks—booking flights, accessing bank accounts, completing purchases. Cosmetic or minor issues receive less scrutiny than barriers to critical services.

3. No Safe Harbours for Large Companies: Major airlines and multinational banks face the same enforcement as smaller entities. Brand recognition and market position provide no protection from accessibility requirements.

4. Automated Solutions Face Scepticism: The AccessiBe ruling signals that overlay widgets and AI-driven “quick fixes” will not satisfy regulators. Genuine code-level accessibility and manual validation are increasingly required.

5. Daily Fines Create Urgency: The SAS case demonstrates how daily accumulating penalties (€15,000/day = €450,000/month) force immediate resource allocation and executive attention in ways fixed fines may not.

Visual diagram titled ‘Steps to Accessibility Enforcements’ showing an upward arrow with four ascending steps. From bottom to top: Customer Complaints as Triggers (customers or advocacy groups file complaints), Formal Investigations (regulators launch investigations based on complaints), Systematic Audits (regulators conduct proactive accessibility audits), and Escalating Penalties (failure to fix issues leads to larger fines and restrictions). Icons accompany each stage, illustrating complaints, investigations, audits, and penalties.

Calculate Your Exposure

Ask yourself:

  • How many customer-facing channels your organisation operate?
  • What percentage meet PDF/UA and WCAG 2.1 AA standards?
  • If each inaccessible online communication a potential violation, what’s your total exposure?

For example, for a bank generating 50,000 monthly PDF statements:

  • If 0% are accessible and individual fines reach €1,000 per violation (conservative estimate)
  • Potential exposure: €50 million monthly

Even if only 1% of customers file complaints, that’s €500,000 in immediate risk—before considering reputational damage, operational restrictions, or daily accumulating penalties for non-remediation.

The organisations thriving post-EAA aren’t debating whether accessibility matters. They fixed their digital communication channels before enforcement arrived.

A digital banner titled “Field Notes on Inclusion” by Quertum introduces a section on real-world accessibility projects. The main headline reads “EAA Compliance Examples: European Banks Accessibility Cases.” The background features a dark navy design with stylized purple file icons connected by white circuit-like lines, symbolizing digital communication and compliance systems.

EAA Compliance Examples: European Banks Accessibility Cases

Written by Kateryna Klynovska on . Posted in EEA.

Living in the business world, we are getting used to seeing the opportunities, when most people have no attention to. This is a great ability, which helps not only earn but also make our life better. 

In the World Health Organization (WHO) European Region, an estimated 90 million people have vision impairment or blindness and 190 million have hearing loss or deafness.
We collected some great examples of companies, which managed to treat Accessibility as an opportunity and got not only better ROI, but earned trust.

Now people with impairments  can use the service of the next companies and live their best life. They can buy a ticket, hear the banking statement and monitor the usage clearly with utility service bills. 

Points of Development for Banking Leaders: Observing the Demand to Fill It In

Despite growing regulation and awareness, the majority of digital services and documents remain inaccessible to people with disabilities. The WebAIM Million study (2025) found that 95% of the world’s top websites contained detectable WCAG 2 failures, highlighting how pervasive accessibility gaps remain – even among large and regulated companies that are expected to lead by example.

The issue extends beyond websites. In academia, where digital publications should be a cornerstone of inclusive knowledge sharing, the situation is equally problematic. Kumar and Wang (2024) examined scholarly PDFs published between 2014 and 2023 and found that fewer than 3.2% met basic accessibility standards such as tagging, alternative text, language metadata, and structured tables. This neglect reflects a broader trend across industries: documents, though widely used for contracts, policies, billing, and customer communications, are rarely designed with accessibility in mind.

Even with accessible websites, PDFs remain a weak link in the compliance chain. However, the reality is that many companies still struggle with both – non-compliant websites and inaccessible documents often coexist, and either can trigger enforcement. Most companies don’t realise how many critical documents (onboarding, billing, contracts) fall outside centralised systems and therefore skip routine audits.

The institutions below recognized this reality and took action. Their implementations offer practical roadmaps for organizations still planning their compliance strategies.

Case #1: Eurobank (Greece) – Comprehensive EAA Alignment

Not every bank has created a document that officially recognises their accessibility gaps and development plans. Eurobank deserves recognition for this transparency—they’ve formally aligned their accessibility strategy with the European Accessibility Act through Greek Law 4994/2022, publishing a comprehensive public statement that most competitors avoid.

What They’re Doing

In their 2025 accessibility statement, Eurobank commits to making all services and channels, including digital content like “files in PDF format”, accessible and comply with EN 301 549:2021 and WCAG 2.1 AA standards. This means customer-facing PDFs (forms, statements, brochures, account documents) are being updated to meet technical accessibility requirements.

Eurobank emphasizes that accessibility is both a legal obligation and “a fundamental expression of respect, inclusion, and customer-centred service.” The bank’s digital channels are currently partially compliant and undergoing continuous improvements toward full accessibility.

Strategic Approach

Rather than treating accessibility as a one-time project, Eurobank frames it as core to their customer experience strategy. This positioning signals to customers, regulators, investors that accessibility improvements are sustainable, not superficial.

Case #2: Bank of England (UK) – Public Sector Leadership

As a public-sector entity, the Bank of England follows UK accessibility regulations, requiring all new content meet WCAG standards.

What They’re doing

The Bank’s accessibility statement notes they “strive to make any new PDFs and Word documents we publish meet accessibility standards.” In practice, newly published reports, consultation papers, and policy documents are designed for assistive technology compatibility, tagged PDFs with alternative text, proper reading order, and semantic structure.

Legacy documents (pre-2018) may not all be remediated, but accessible versions are provided upon request. This pragmatic approach acknowledges resource constraints while ensuring ongoing compliance for new publications.

Strategic Approach

The Bank of England adopted an “accessibility by default” policy for new documents rather than attempting to retroactively fix decades of archives. This forward-looking strategy prevents accumulation of new accessibility debt while managing legacy content requests case-by-case.

Case #3: Honda Bank GmbH (Germany) – Forward-Looking Compliance

Honda’s finance arm in Germany issued an accessibility (Barrierefreiheit) statement aligned with the EAA under German law (Barrierefreiheitsstärkungsgesetz – BFSG).

What They’re Doing

Honda Bank acknowledges that some PDFs on its website currently lack accessibility features (missing tags, insufficient alt-text). However, the bank “plans to design future PDF documents to be barrier-free, in order to meet the required standards.”

All newly generated PDFs for customers—product information, account documents, contract terms—will be created to PDF/UA and WCAG specifications before the June 2025 enforcement deadline.

Strategic Approach

Honda Bank’s transparency about current gaps paired with concrete remediation timelines demonstrates regulatory compliance without overpromising. By focusing on template-level changes for future document generation, they can build scalable accessibility into their customer communication workflows rather than pursuing expensive per-document fixes.

For the financial industry, these cases signal a clear shift from one-off document fixes to systematic, scalable accessibility management.  This transparency shows that real compliance depends on embedding accessibility into every customer communication template, not just polishing a few visible reports. 

Opportunities in Numbers

These implementations aren’t just regulatory responses, they unlock measurable business opportunities. Approximately 24% of the EU population lives with some form of disability. By providing accessible PDFs and digital services, banks can serve this demographic that competitors are neglecting. For context, UK households with disabled members control £274 billion in annual spending power. Banks and building societies lose an estimated £935 million monthly by maintaining accessibility barriers that drive these customers away.

Where to Start Your PDF Accessibility Implementation Journey

The institutions above share common implementation patterns your compliance team can replicate:

1. Conduct Honest Accessibility Audits: Don’t assume website compliance means document compliance. Most organisations have accessible web properties but inaccessible PDFs in contracts, onboarding, billing, and customer communications outside centralised systems.

2. Prioritise Template-Level Fixes: Following Honda Bank and Bank of England’s model, focus on making new document templates accessible rather than remediating entire archives. One compliant CCM template generates thousands of accessible outputs—precisely what banks and enterprises need at scale.

3. Document Your Progress Publicly: Like Eurobank, publish accessibility statements with specific standards and timelines. Transparency builds trust with customers and demonstrates good faith to regulators.

Here we broke in our article PDF Accessibility and EAA: Guide for Compliance, where you can find  you need to know where you start to document accessibility strategy and how to lead this process painlessly.

Ready to start your accessibility journey? Learn more about PDF accessibility requirements or request a free PDF audit to identify gaps in your customer communications before regulators do.

Bonus Case: Easy Jet and Accessible Application

EasyJet, British multinational low-cost airline and package holiday group, builds reliable customer experience while taking maximum from the market. In this short case, we welcome you to immerse yourself in the world of people with visual impairments and discover the principles of accessible customer experience in less than 5 minutes. 

Our simple question: Have you ever tried to book a flight with closed eyes?

This sounds like a real challenge, but anyway EasyJet gets things solid, and lets people actually book the flight just with the voiceover. In this short video, you can try these shoes and understand the approach of accessibility better.


Comparing the service of Ryanair, Jet2 and Tui, Adi Latif, the well-known accessibility consultant, is booking a flight to Alicante, Spain. With no loud market data or buzzwords, but with real usage he showcased the ease of use of the EasyJet application for people with visual impairments. 

This real-world example gave approximately 340,000 people with vision impairments a comfortable way to travel, whilst opening the door to market dominance among people with impairments. EasyJet proves that accessible customer experiences aren’t just compliant —they’re competitive advantages.

Visual comparison showing four major PDF accessibility checker logos — PAC, Adobe Acrobat, PDFix, and CommonLook PDF Validator — beside a computer monitor displaying the text “PDF Accessible” with an accessibility icon, symbolizing the evaluation of tools for ensuring accessible PDF documents.

Top PDF Accessibility Tools in 2025: Comparative Review for Those Starting Their Accessibility Journey

Written by Kateryna Klynovska on . Posted in EEA.

Checking PDFs for accessibility may sound straightforward, until you realise this: automated tools only catch 30-40% of real accessibility barriers. The European Accessibility Act has made PDF compliance mandatory across banking, insurance, utilities, and public sectors. Yet most compliance teams still rely solely on automated checkers to shape their EAA compliance strategy, missing critical issues that only manual testing reveals. And the the loop is clear: the more company relys on automated checkers, the more it puts financials at risk. Read our article about fines and penalties here.

This guide offers practical techniques for evaluating PDF accessibility tools and services in 2025. We’ll compare the most popular free and paid validators: PAC 2024, Adobe Acrobat Pro DC, PDFix Desktop Lite, and CommonLook PDF Validator. We’ll explain why even the best automation must be paired with manual accessibility audits by people who understand how assistive technologies actually work.

If you’re starting your accessibility journey post-EAA, this is your roadmap to choosing the right pathways without wasting budget on features you don’t need.

Visual diagram titled 'EAA-Ready PDF Accessibility Workflow' showing a linear four-step process. Step 1: ‘PDF Checker’ – automated tool validation. Step 2: ‘Manual Audit’ – human review for accessibility compliance. Step 3: ‘Template Fix’ – correction of document templates. Step 4: ‘Regulatory Approval’ – final compliance confirmation. All steps are displayed in connected purple boxes with arrows on a dark blue gradient background.

Understanding What PDF Accessibility Tools Actually Check

Before comparing specific tools, understand what automated checkers can and cannot do.

What automated tools check well:

  • PDF/UA conformance (tagged structure, reading order)
  • WCAG 2.1 AA technical checkpoints (color contrast ratios, language attributes)
  • Missing alt text or table headers
  • Document metadata and title display
  • Font embedding and Unicode mapping

But what automated tools miss:

  • Whether alt text is meaningful (tools can’t tell if “image1.png” describes the content)
  • Logical reading order across complex layouts
  • Table structure usability for screen reader users
  • Form field instructions clarity
  • Real-world navigation with keyboard or assistive tech

This gap is why EN 301 549 and national EAA implementations require both automated and manual testing. Tools provide technical compliance baselines. But humans verify usability.

PAC 2024 Accessibility Checker: The Free Industry Standard

PAC (PDF Accessibility Checker) 2024 is the first worldwide ISO 14289-1 (PDF/UA) validator and remains the go-to free tool for PDF accessibility testing. Developed by axes4 company, it’s trusted by European accessibility professionals.

Key Features:

  • WCAG 2.1 checks with all machine-testable checkpoints
  • Quality Checks feature to simplify visual inspection during manual assessments
  • Screen reader preview showing logical document structure
  • Detailed error reports highlighting specific PDF/UA violations
  • Completely free with no feature restrictions
StrengthsLimitations
Precise document language checking adhering strictly to PDF/UA and WCAG specificationsWindows-only (Mac users need axesCheck online alternative)
User interface remains consistent across all screen resolutionsManual visual review still necessary because PAC primarily focuses on technical elements
Soft hyphen highlighting in screen reader preview for better differentiationNo remediation features—purely a validation tool
Generates comprehensive PDF reports documenting compliance statusLearning curve for interpreting technical error messages

Best For: European organisations needing free PDF/UA validation for EAA compliance; teams with technical accessibility knowledge; audit documentation preparation.

Real-World Use Case: A Nordic insurance company used PAC 2024 to validate 12,000 policy documents before the EAA deadline. The tool identified 78% structural compliance but flagged 4,200 documents requiring manual alt text review—work PAC couldn’t assess automatically.

Adobe Acrobat Pro DC: The All-in-One Automated Remediation Solution

Adobe Acrobat Pro DC includes built-in accessibility checking, tagging, and remediation tools. It’s the most comprehensive single-tool solution but comes with complexity and cost.

Key Features:

StrengthsLimitations
Industry standard—most accessibility professionals know itChecks many characteristics but doesn’t match PAC’s PDF/UA certification rigor
Combines checking and fixing in one environmentExpensive licensing (€180–240/year per user)
Handles complex table remediationSteep learning curve for accessibility features
Integration with Adobe Creative SuiteTag editing can be tedious for large documents
–Automated tagging often creates more problems than it solves

Best For: Organisations with dedicated accessibility teams; high-volume remediation needs; complex document workflows requiring both creation and validation.

Important Note: Adobe’s checker is excellent for identifying issues, but experienced teams often use PAC 2024 as final validation because it’s specifically designed for PDF/UA conformance certification.

PDFix Desktop Lite: Lightweight Free Alternative

PDFix Desktop Lite offers basic accessibility checking and repair capabilities in a simpler interface than Acrobat. It’s designed for occasional users who need quick assessments without professional remediation features.

Key Features:

  • Automated tagging for simple documents
  • Basic accessibility checks
  • Reading order verification
  • Free for non-commercial use
  • Cross-platform (Windows, Mac, Linux)
StrengthsLimitations
Simpler interface than AcrobatLess comprehensive than PAC or Acrobat checkers
Free tier availableAutomated tagging quality varies significantly
Automatic tagging works well for straightforward documentsLimited manual remediation tools
Good for quick preliminary checksLacks detailed PDF/UA compliance reporting

Best For: Small teams testing occasional PDFs; preliminary document screening before professional remediation; educational purposes.

CommonLook PDF Validator: Enterprise-Grade Free Validation

CommonLook PDF Validator works as an Adobe Acrobat Pro plugin, identifying and highlighting accessibility concerns within PDF documents. Now part of Allyant, it’s widely used in US federal agencies and large enterprises.

Key Features:

  • Tests against Section 508, WCAG 2.0 AA, PDF/UA, and HHS guidelines
  • Guides users through manual tests necessary for complete accessibility compliance
  • Tag-based content highlighting—select content in PDF and immediately see corresponding tags
  • Provides certification report documenting compliance for each tested document
StrengthsLimitations
Divides checks into structure (ISO 32000) and accessibility conformance categoriesRequires Adobe Acrobat Pro DC (adds to total cost)
More comprehensive standard coverage than PAC’s PDF/UA focusInterface differences from PAC may require learning adjustment
Table summaries accuracy validation improves comprehension of tabular dataUS-centric standard focus (though PDF/UA applies globally)
Accepted by regulatory agencies for compliance documentation–

Best For: Organisations serving US and EU markets; federal contractors; enterprises needing multi-standard certification reports; teams already using Acrobat Pro.

Quick Sheet for PDF Accessibility Chekers

ToolCostPDF/UA CheckWCAG CheckRemediationBest For
PAC 2024FreeCertified – provides highly accurate validation aligned with PDF/UA and WCAG 2.1 standards, widely accepted across the EU.Level AA – verifies accessibility according to WCAG 2.1 AA, ideal for compliance audits.No correction or editing options; used purely for validation and reporting.EU compliance validation, auditors, and accessibility specialists needing a certified, trusted tool.
Acrobat Pro DC€180–240/year per userGood – performs detailed PDF/UA checks, including tagging and structure validation.Broad WCAG coverage integrated with accessibility features and reports.Full remediation workflow – allows manual and semi-automated fixes directly within documents.Organizations seeking an all-in-one tool for creating, editing, and remediating accessible PDFs.
PDFix LiteFree (limited version)Basic – performs basic structure and tag checks for small or simple documents.Basic – supports quick accessibility validation but lacks deep analysis.Simple – includes limited remediation features like auto-tagging and metadata editing.Occasional checking or small teams that need a quick, lightweight accessibility validator.
CommonLook ValidatorFree (requires Adobe Acrobat)Multi-standard – supports PDF/UA, WCAG, Section 508 (US Accessibility Standard), and HHS standards.Extensive cross-standard compliance validation with detailed reports.Validation only; remediation requires other CommonLook products.Enterprise-level – large organisations, and government audits.

Why Automated Chekers Alone Fail EAA Compliance?

Here’s the uncomfortable truth: checkers and automated remediators primarily focuse on technical elements of accessibility, so manual review is still necessary, other wise the document can make no sence to a real person. Every major accessibility standard, like WCAG, PDF/UA, EN 301 549, requires human evaluation. It requires manual check because of:

Automated Tools Can’t Judge Context

A checker sees <Figure alt="graph"> and marks it compliant. A screen reader user hears “graph” with no data context. It is completely useless for person with impairment. A human auditor would flag this as non-compliant despite passing automated checks.

Reading Order Logic Requires Human Understanding

Tools verify that content has a reading order. They can’t assess whether the order makes sense. Multi-column layouts, sidebars, and callout boxes often pass technical checks while creating incomprehensible experiences for assistive tech users.

Form Usability Is Invisible to Automation

Validators check if form fields have labels. They don’t assess whether instructions are clear, whether error messages are helpful, or whether tab order follows logical completion flow.

Real-World Example: A Swedish bank we audited had 100+ PDF templates passing PAC 2024 checks at 98% compliance. Manual testing by accessibility specialists revealed:

  • 40% of alt text was generic (“chart,” “logo”) without meaningful descriptions
  • 29% of tables had correct tags but illogical header associations
  • 16% of forms lacked keyboard navigation hints despite having technical labels

Fixing these issues at the template level eliminated manual remediation costs and ensured genuine accessibility, not just checkbox compliance.

How Quertum Combines Tools with Human Expertise

We use automated validators as the first screening layer, not the final answer. Our process includes automated scanning, manual accessibility audits with actual screen readers (NVDA, JAWS) and keyboard navigation, plus contextual review of whether alt text and form instructions actually communicate meaning—not just whether they exist.

However, for banks, insurers, and enterprises generating thousands of documents monthly, individual file remediation quickly becomes unsustainable. That’s why template-based accessibility implementation is the only approach that makes sense at scale.

The Template-First Strategy:

Instead of fixing 50,000 customer statements one by one, we remediate your CCM templates once. For Quadient Inspire, OpenText Exstream, Smart Communications or other enterprise systems, this means:

  • One compliant template = unlimited accessible outputs – Every bank statement, insurance policy, or invoice generated from that template automatically meets PDF/UA and EN 301 549 requirements
  • Future-proofing – New regulations or standard updates require template adjustments, not archive-wide remediation
  • Operational continuity – No disruption to document generation workflows; accessibility becomes built-in, not bolted-on

This template-centric approach is precisely what European banks and large enterprises need: scalable compliance that doesn’t require armies of remediators or disrupt customer communications.

Final Takeaway: Tools Are Your Starting Point, Not Your Finish Line

PAC 2024, Acrobat Pro, and CommonLook Validator are excellent tools when used correctly. They identify technical violations efficiently, but they’re screening tools, not compliance guarantees.

The European Accessibility Act doesn’t ask, “Did your PDF pass an automated checker?” It asks, “Can people with disabilities actually use your documents?” That second question requires human testers who understand assistive technology, not just software that counts tags.

Organisations that thrive in the post-EAA era understood this early. Read our case study on how a leading Finnish bank met the EAA deadline and future-proofed its reputation. By combining automated tools for technical checks with expert manual audits, they ensured real usability and lasting compliance.

Ready to move beyond checkbox compliance? Contact Quertum for a comprehensive accessibility audit combining automated validation with expert manual testing or explore our PDF accessibility services designed specifically for EAA requirements.

A presentation slide from a company named Quertum titled "How European Accessibility Act Affects Nordic Businesses." The slide features a green map of the Nordic countries (Norway, Sweden, Finland, and Denmark) with each country's flag and an accessibility icon over the map. The background is a dark blue-purple gradient with light green grid lines.

EU Accessibility Act in the Nordics: Consistent, Contextual, and Culturally Anchored

Written by Kateryna Klynovska on . Posted in EEA.

In our previous articles, we outlined how countries like France, Poland, Germany, and the Netherlands have implemented the Accessibility Directive, so it’s time to have a closed view to European Accessibility Act in the Nordics region. Sweden, Denmark, Finland, and Norway stand out for its long-standing digital accessibility culture. These countries are not starting from scratch: accessibility is already a legal and social expectation.

In this article, we examine how the European Accessibility Act applies across the Nordics and what companies need to prepare for, whether they operate locally or cross-border.

How the European Accessibility Act Affects Nordic Businesses?

The Nordic approach to the EAA is marked by integration rather than reinvention. Instead of building entirely new frameworks, each country has chosen to embed the EAA into existing national legislation. This reflects the region’s long tradition of treating accessibility as both a legal right and a cultural norm.

  • Sweden has incorporated the EAA into Lag (2023:254), broadening its existing accessibility framework to cover sectors such as banking, e-commerce, transport, and telecom. Oversight is shared between the Swedish Consumer Agency (Konsumentverket) and the Agency for Digital Government (DIGG).
  • Denmark enforces accessibility through Act no. 801 of 07/06/2022, with a strong emphasis on consumer protection. The Danish Business Authority (Erhvervsstyrelsen) is the lead body, taking a guidance-led approach while retaining the power to issue fines and corrective measures.
  • Finland aligns the EAA with Government Decrees 179/2023 and 180/2023, building on the accessibility requirements already established under the Act on the Provision of Digital Services. Compliance is supervised by the Finnish Transport and Communications Agency (Traficom).
  • Norway, while not an EU member, implements equivalent rules via the Anti-Discrimination and Accessibility Act and related ICT regulations. Enforcement is handled by the Agency for Public Management and eGovernment (Digdir), ensuring alignment with the EEA Agreement.

For businesses, this creates continuity with national traditions but also complexity: obligations are consistent in principle, yet enforcement models and regulatory expectations differ across the region. Multinationals must be prepared to navigate these nuances while ensuring compliance with a baseline set of EAA requirements.

What the European Accessibility Act in the Nordics Requires?

The baseline obligations are the same across all Nordic countries, as they derive from the EU Directive:

  • Digital content must comply with WCAG 2.1 AA (websites, apps, PDFs)
  • Products and services must be compatible with assistive technologies
  • Accessibility statements, documentation, and feedback mechanisms are mandatory
  • Labels, instructions, and user interfaces must be legible, perceivable, and understandable
  • Identification, security, and payment functions must meet POUR principles

Banking and e-commerce services carry extra requirements:

  • Identification methods, e-signatures, and payment services must be perceivable, operable, understandable, and robust
  • Financial information must be written at B2 language level or lower, ensuring clarity
  • E-commerce operators must provide information about the accessibility of products and services where available

This mirrors the approach in the Netherlands and highlights how financial services are under special scrutiny across the EU, including the Nordics.

Exemptions and Exceptions for European Accessibility Act in the Nordics

The Nordic countries follow the general EAA exemptions:

  • Microenterprises: Fewer than 10 employees and turnover/balance sheet below €2M are exempt. Regulators in Sweden, Denmark, and Finland nevertheless encourage voluntary compliance to remain competitive in the digital single market.
  • Disproportionate burden: Businesses may be exempt if compliance would create costs disproportionate to the accessibility benefit, based on Annex VI of the Directive. Lack of time or knowledge is not a valid reason.
  • Fundamental alteration: When accessibility requirements would alter the service so substantially that it becomes a different service.
  • B2B services: The EAA applies only to business-to-consumer services, not pure B2B contexts.

Timeline and Transition Rules

The enforcement date is consistent across the EU and the EEA:

  • 28 June 2025: All new services and modified contracts must comply with the EAA
  • Existing contracts signed before this date may run until expiry, but no longer than five years, meaning by 28 June 2030 all must comply
  • Physical products used in service delivery (e.g., payment terminals, e-ID devices) have the same five-year transition period. Products placed on the market before June 2030 may be used temporarily, but must be upgraded or replaced to meet the new requirements.

What Penalties for Non-Compliance in the Nordic Region?

The penalty framework varies slightly across Nordic countries, but follows similar patterns:

  • Administrative fines are the main tool, with amounts depending on turnover and severity
  • Regulators may impose recurring penalties until compliance is achieved
  • In serious cases, providers may face suspension of services or public disclosure of violations

Sweden’s model is considered stricter, with higher fines and stronger inspection powers, while Denmark and Finland lean on consumer law enforcement traditions.

Key Differences at a Glance for Nordic Countries

To make the national differences clearer, the table below outlines how each Nordic country has embedded the EAA into its legal framework, who supervises compliance, and what businesses should be aware of in terms of scope and enforcement.

CountryMain Law / FrameworkSupervisory AuthoritySpecial FeaturesPenalties & Enforcement
SwedenLag (2023:254)Swedish Consumer Agency (Konsumentverket) and Agency for Digital Government (DIGG)Broad scope, covering banking, e-commerce, transport, and telecom; one of the earliest comprehensive accessibility laws in Europe.Fines, corrective orders, and strong inspection powers; considered among the strictest in the EU. Fines range up to EUR 200 000.
DenmarkAct no. 801 of 07/06/2022Danish Business Authority (Erhvervsstyrelsen)Strong consumer protection focus; guidance-led enforcement with emphasis on business accountability.Administrative fines, warnings, and recurring penalties until compliance is achieved. Fines range up to EUR 10 000 for initial non-compliance.
FinlandGovernment Decrees 179/2023 & 180/2023Finnish Transport and Communications Agency (Traficom)  Builds on existing Digital Services Act (2019), where WCAG 2.1 AA was already mandatory for public bodies.Fines and corrective measures, applied proportionately to scale and impact. Fines range up to EUR 150 000.
Norway (EEA country)Anti-Discrimination and Accessibility Act + ICT regulationsAgency for Public Management and eGovernment (Digdir)Applies to both public and private services despite Norway being outside the EU; aligns with EEA obligations.Administrative penalties and corrective measures, supported by Norway’s strong ICT audit tradition.

Summary

The Nordics are well-positioned to implement the EAA thanks to their strong pre-existing accessibility laws. For businesses, this means compliance is not just about meeting EU standards but aligning with national frameworks that often go further.

From Sweden’s early adoption of a broad accessibility act, to Norway’s strict ICT obligations, the Nordic region sets high expectations. Companies operating here must take accessibility seriously, integrate it into product and service design from the outset, and prepare for close scrutiny by multiple regulators.

European Accessibility Act in the Nordics region is treated as integral to society, law, and commerce, rather than as a formal obligation alone.

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.

Harmonised 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 organisations, 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 organisations.

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 specialise 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 harmonised 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 harmonised 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 – Harmonised 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 of Accessibility Act in Poland

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 recognise 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 harmonised standards.”

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

  • EN 301 549 – the harmonised 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, colour 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 harmonised standards, organisations can demonstrate good-faith compliance with the Polish Accessibility Act and reduce their exposure to regulatory risk.

Tightly Defined Legal Terms of Accessibility Act in Poland

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.

In 2018, GDPR forced companies to change how they handled personal data. The regulation set a new standard for privacy and introduced penalties that caught many businesses off guard. Today, the European Accessibility Act (EAA) is on a similar path—only this time, the focus is on accessibility.

From June 28, 2025, the EAA is taking full effect. This 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. In practice, 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 European Accessibility Act 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 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.

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 European Accessibility Act

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.

Like GDPR, 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?

On June 28, 2025, the EAA becomes enforceable, but that date doesn’t mark the end of the road. Instead, it signals the beginning of active enforcement and greater scrutiny. Regulators won’t judge compliance by a single audit on that day, but by how well your organisation demonstrates 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.

Resilient companies will treat this moment not as a finish line, but as the launch of a permanent compliance phase. Over time, laws will evolve, interpretations will shift, and enforcement will become more consistent. To keep pace, organisations should establish regular review cycles, track country-level legislation, and integrate accessibility into procurement and development processes.

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. Unlike GDPR, the EAA combines broad scope with serious penalties, yet many organisations remain unprepared. Industries that depend on digital customer interaction—finance, retail, transport, and public services—are especially exposed. When a service is both essential and highly visible, the risk of regulatory scrutiny increases.

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, organisations 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 organisations 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 colours, 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 labelling, colour 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 organisations 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 recognising that accessibility touches every part of your organisation. 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.