# European Accessibility Act (EAA): accessibility checklist for product teams

For teams whose websites, apps or e-commerce services are offered to consumers in the EU. The EAA
(Directive (EU) 2019/882) has applied since 28 June 2025; WCAG 2.2 Level AA, with EN 301 549 as the
reference standard, is the practical target. This is general information, not legal advice: confirm your
obligations with a qualified adviser.

The full guide, with sources for every point, key dates and the microenterprise exemption:
[European Accessibility Act testing](https://shipperag.com/european-accessibility-act-testing/?utm_source=github&utm_medium=repo&utm_campaign=release-kit).

## Set up once

- [ ] Scope confirmed with an adviser: consumer-facing, on the EAA list, sold to EU consumers, not a microenterprise.
- [ ] The target is in your requirements and definition of done: WCAG 2.2 Level AA, EN 301 549 as the reference.
- [ ] Owners agreed for design, build, content, third-party widgets, the accessibility information and fixes after launch.
- [ ] The design system is accessible: contrast-safe colour tokens, visible focus states, adequate target sizes, accessible components.
- [ ] The accessibility information required by Annex V is drafted and published with your terms.
- [ ] A route for accessibility complaints exists, with a process to fix problems quickly.

## Every release

- [ ] **Scope:** the key journeys are listed (browse, search, product page, basket, checkout, payment, sign-in, account, help and contact, and the app if you have one).
- [ ] **Sample:** page types, states and complete processes are sampled (the whole checkout, not just its first page).
- [ ] **Automated rules** run on every build (for example axe-core); serious failures block the release; "needs review" results go to a person, never counted as passes.
- [ ] **Manual checks:** keyboard-only use, focus order and visibility, zoom and reflow, error messages, timeouts, meaningful alt text and link text.
- [ ] **Assistive technology:** screen readers on desktop and mobile, voice control and magnification on the key journeys; ideally with disabled people.
- [ ] **Identification, security and payment steps**, including embedded third-party widgets, are tested too.
- [ ] **Evidence:** a dated record of what was tested, failed, fixed and not covered, kept for each release.
- [ ] **Re-test** after every significant change, and when the standard is updated.

Remember: a clean automated report is not proof of conformity. Automation gives breadth on every build;
people judge meaning, context and complete journeys.

## Sources

[Directive (EU) 2019/882 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882) ·
[European Commission: European Accessibility Act](https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/disability/european-accessibility-act-eaa_en) ·
[W3C WCAG-EM 2.0](https://www.w3.org/TR/wcag-em-2/) ·
[What's new in WCAG 2.2](https://www.w3.org/WAI/standards-guidelines/wcag/new-in-22/) ·
[EN 301 549 V4.1.1 (2026-09)](https://www.etsi.org/deliver/etsi_en/301500_301599/301549/04.01.01_60/en_301549v040101p.pdf). Checked 19–20 September 2026.

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Licensed CC BY 4.0. Made by [ShipperAG](https://shipperag.com/?utm_source=github&utm_medium=repo&utm_campaign=release-kit): agentic AI QA testing for tech and product teams (private pilot).