Does the European Accessibility Act apply to my US company?

If you sell online to consumers in the European Union, the answer is probably yes, and the deadline already passed. The European Accessibility Act (EAA) took effect for services on June 28, 2025, it was not extended, and it applies based on where your customers are, not where your company is based.

What the EAA is, and why the date matters

The EAA is an EU directive that requires a defined set of products and services, including ecommerce, banking, and passenger transport services, to be accessible to people with disabilities. For services the obligations took effect on June 28, 2025, and there was no general grace period. Enforcement started moving soon after the date, including formal legal notices from French disability advocacy organizations to major retailers.

Here is the part most US coverage misses. In April 2026 the US Justice Department extended the ADA Title II web deadlines by a year, to 2027 and 2028. The EAA got no such extension. So for a US business selling into the EU, the regulation that is already live today is the European one, not the American one.

Are you in scope?

• You sell to EU consumers. The EAA follows the customer. A US company offering ecommerce services to consumers in the EU, by shipping there or marketing to them, is in scope regardless of where it is established.
• Unless you are a microenterprise providing services. Service providers with fewer than 10 employees and annual turnover or balance sheet at or under 2 million euros are exempt from the service requirements. Both conditions must hold, the exemption covers services rather than products, and it ends the moment you outgrow the thresholds.
• Old systems get a narrow runway, new ones do not. A transitional window lets service providers keep using certain products that were lawfully in use before June 28, 2025 for a limited period, but the service obligations themselves are live now. How that transition applies to your stack is a counsel question.
• Penalties are set country by country. The EAA is a directive, so each member state enforces it through its own national law. Exposure depends on which markets you sell into.

The standard is one you already know

The technical benchmark behind the EAA is the harmonized European standard EN 301 549, whose web chapter incorporates WCAG 2.1 Level AA. Conforming to the harmonized standard gives a presumption of conformity with the accessibility requirements. In plain terms: for a website, the engineering work the EAA asks for is WCAG 2.1 AA conformance, the same standard US courts and settlements use as the benchmark, and the same standard every Site Brace scan measures against. Fixing your site for one side of the Atlantic is most of the work for the other.

The usual honesty caveat applies in both jurisdictions: automated testing covers roughly 30 to 40 percent of WCAG criteria. We report the automated slice and say exactly what a machine can and cannot catch. Conformance is a measurable property of a page; whether you meet a legal obligation in any country is a determination for counsel.

What a US business should do now

1. Establish your exposure. Do you ship to the EU, price in euros, or market to EU consumers? If yes, talk to counsel about scope, member-state specifics, and the microenterprise thresholds.
2. Find out what is actually broken. Scan one page free in about a minute, or run a $149 baseline audit of up to 25 pages. Our data says the odds are not in your favor: 76% of the large US retailers we scanned had at least one automated WCAG 2.1 AA violation on the home page, per our 2026 ecommerce study.
3. Fix, then keep it fixed. The EAA is an ongoing obligation, not a one-time certification, and every deploy can introduce new issues. Scheduled Watch monitoring from $129 a year surfaces regressions in days. If you also operate under US demand-letter risk, the same baseline and monitoring serve both: see our 72-hour demand letter guide.