Insights · Trend · Accessibility
EAA: penalties, scope, and compliance audit
The EAA is not a regulation and does not apply only to public bodies. It is Directive (EU) 2019/882, implemented in Poland by the act of 26 April 2024, and its requirements have applied since 28 June 2025. It covers private companies selling to consumers in the EU — shops, banks, transport, e‑books. Below: who is actually in scope, who is exempt and what an audit looks like.
What's changing right now
The scope is broad: sales websites and apps, e‑banking, e‑books, passenger transport, telecoms. The crucial part is rarely written about — microenterprises providing services are exempt: companies with fewer than 10 employees whose annual turnover or balance sheet total does not exceed EUR 2 million. For products there is no such exemption, though a disproportionate burden may be claimed — but it has to be documented, not merely declared. So before you start pricing an audit, check which side of that line you are on.
What you can do better
Concretely, starting today
- Establish two things at once: whether your service is in scope, and whether the microenterprise exemption covers you. The second answer often matters more than the first and takes fifteen minutes.
- Introduce periodic compliance audits with WCAG standards instead of one-time fixes.
- Alternative channels — a phone line, in‑person help — are valuable for customers but do not substitute for conformity. The directive requires an accessible product, not a detour around it.
- Document accessibility processes to prove compliance in case of an inspection.
Proof from our work
We built a free accessibility widget — one file, 14 kB, to download and host yourself — and we keep it switched on across dtl.pl, the site you are reading. It offers contrast, text scaling, a readable typeface, link highlighting and paused animations. Which is exactly why we know its limits: no widget delivers EAA conformity. It will not fix heading structure, keyboard navigation or missing image descriptions — and those are what an audit looks at. An overlay improves comfort of reading; an audit inspects the code. We covered this separately: what a widget does and does not do and accessibility from the business side.
Frequently asked questions
What are the penalties for lack of accessibility?
Penalties are administrative and come from the national implementing act rather than the directive itself — the amount depends on the breach, so confirm the figure with a lawyer. In practice the first cost is rarely the fine: it is an order to fix the shortcomings within a deadline, meaning a rebuild under time pressure, usually dearer than a planned audit.
Who is in scope, and who is exempt?
In scope are businesses offering consumers in the EU the products and services listed in the directive: e‑commerce, banking, passenger transport, e‑books, telecoms. Exempt are microenterprises providing services — under 10 staff and up to EUR 2 million in turnover or balance sheet total. Note the exemption covers services, not products, so company size alone does not settle it.
Check your website's accessibility
Contact us to conduct a professional audit and avoid sanctions related to EAA.
