Digital Accessibility: Why SEO Should Care About the EAA (and How to Prepare)

On June 28, 2025, the European Accessibility Act (EAA) came into effect across the European Union. This legislation requires businesses to make their products and services accessible, including digital services such as websites and mobile applications.

What is Digital Accessibility?

Digital accessibility refers to practices that ensure everyone can use a website or application, regardless of physical, sensory, or cognitive abilities. It primarily concerns people with disabilities but also benefits seniors, users with older devices, slow connections, or temporary adaptation needs (e.g., fatigue, broken arm). 

By making content clearer, more navigable, and more understandable, accessibility improves the experience for all users. It is now also a legal requirement under the EAA directive. Beyond compliance, the goal is to create more inclusive, equitable, and sustainable interfaces that leave no one behind.

EAA and WCAG: What Are They?

The European Accessibility Act (EAA) is a European directive adopted in 2019, effective from June 28, 2025, across the EU. It mandates that certain products and services be accessible to all, particularly for people with disabilities, including digital services like websites and mobile apps.

To prepare for this deadline, many businesses rely on the Web Content Accessibility Guidelines (WCAG), which define accessibility standards. However, complying with WCAG does not always fully meet EAA requirements.

We provide a Simplified Standards Document and a Compliance Checklist at the end of this article. These tools are for informational purposes only and do not guarantee success in a formal EAA compliance evaluation.

The WCAG is a set of guidelines explaining how to design a website that everyone can use, including people with disabilities, regardless of the device (mobile, tablet, PC, e-reader, etc.). These guidelines cover practical aspects such as text contrast, button size, and mouse-free navigation. They are defined by the W3C (World Wide Web Consortium), an international organization that establishes common standards to ensure websites work well for everyone, regardless of browser or device. In short, the W3C lays the foundation for a clearer, more consistent, and inclusive web, with WCAG being a cornerstone of accessibility.

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WCAG vs. EAA: Complementary, Not Equivalent Standards

The WCAG (currently version 2.1) is the most recognized technical foundation for improving website accessibility. It is organized around four key principles: perceivable, operable, understandable, and robust.

It is divided into three accessibility levels:

• Level A: The minimum requirement. The site does not completely exclude certain users. Examples include mouse-free navigation, adding alt text for images, and avoiding flashing content.
• Level AA: The recommended level for most regulations, including the EAA. It ensures robust and realistic accessibility, covering aspects like color contrast, text clarity, and form error handling.
• Level AAA: The highest, most stringent level, which is harder to achieve in practice. It aims for exemplary accessibility with advanced requirements (simplified reading, very clear language, sign language interpretation, etc.). It is not mandatory but serves as a benchmark for excellence.

The EAA, on the other hand, is a broader European directive. It mandates accessibility for an entire service, not just the website. This includes:

• Mobile applications,
• Downloadable documents (PDFs, contracts, manuals),
• Support services (phone, chat, email),
• Physical kiosks or interactive terminals,
• Third-party or dynamic content (e.g., AI-generated),
• And, most importantly, a genuinely usable user experience, not just technical compliance.

A possible mistake is assuming that a WCAG Level AA–compliant site is automatically EAA–compliant. This is not the case. The EAA introduces additional, often more practical requirements and holds businesses accountable for actual user outcomes.

Being EAA-compliant requires WCAG Level AA compliance, but the reverse is not true.

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Why This Matters for SEO

At first glance, accessibility and SEO seem like separate disciplines. In practice, they are often aligned. An accessible site:

• Loads faster (better structure, cleaner code),
• Makes content more understandable (semantic tags, clear headings),
• Improves user experience (navigation, clarity, visual feedback),
• And, crucially, allows a broader audience to access its content (inclusivity, device compatibility).

These secondary benefits are well-known to SEO experts. With the EAA, they become legal obligations for certain entities. This shift makes accessibility a priority to integrate early in web projects, alongside SEO.

Where to Start?

First, determine if your business is subject to the EAA. It applies to a wide range of entities, including:

• Online retailers, including marketplaces,
• Banks and payment providers,
• Public transportation (airlines, railways, etc.),
• E-book publishers and e-readers,
• Electronic communication service providers,
• Manufacturers or distributors of interactive terminals (ATMs, self-service kiosks, etc.).

If you offer a digital product or service likely to be used by the general public, you are probably affected.

Once confirmed, the first step is understanding the requirements, which can be complex. To help, we provide two tools at the end of this article:

• A Simplified Standards Document, summarizing WCAG 2.1 Level AA criteria and additional EAA obligations (e.g., downloadable documents, customer support, multi-channel accessibility).
• A Compliance Checklist, designed as a practical self-assessment tool to track progress and identify areas for improvement.

These resources can be used to:

• Train internal teams (design, development, product, legal),
• Audit existing services,
• Prepare a compliance plan.

What Are the Risks of Non-Compliance?

The EAA took effect on June 28, 2025. From this date, affected digital products and services must meet the directive’s accessibility criteria. Non-compliance may lead to:

• Legal and financial penalties: National authorities can impose administrative fines (Article 28§1).
• Market withdrawal: Non-compliant products or services may be banned from the EU market (Articles 22 and 23 of the EAA).
• Contractual liability: Users or partners may pursue legal action for non-compliance (while not explicitly stated in the directive, this risk exists under general EU law).
• Reputational damage: Non-compliant businesses may face public criticism, harming their brand image, especially if they position themselves as innovative or inclusive.

In 2025, 180 Belgian public sector websites were selected for official accessibility audits. The list is available on the official Belgium Web Accessibility website:

https://accessibility.belgium.be/fr/actualites/liste-des-sites-qui-recevront-un-audit-daccessibilite-en-2025.

Such audits are expected to gradually extend to other organizations, including private ones, as the EAA is further implemented across EU member states. It’s better to prepare now.

Why Accessibility Can No Longer Be Ignored

Accessibility Directly Impacts Your SEO and Business

Many accessible elements (clear structure, proper tags, alt text, fast loading times, etc.) also improve natural search rankings. For example, a well-structured site with hierarchical headings and explicit links enhances both user experience and search engine understanding.

Beyond SEO, accessible design benefits all users with optimized loading times, keyboard navigation, and improved readability. This reduces engagement rates, boosts conversions, and strengthens customer loyalty.

A Growing Social Responsibility

Approximately 87 million people in the EU live with a disability, nearly 20% of the population (source: European Commission). This group is often excluded from non-accessible digital services.

Accessibility aligns with Corporate Social Responsibility (CSR), demonstrating that a business considers all users, regardless of their abilities.

In Conclusion

Digital accessibility is becoming essential with the EAA’s enforcement on June 28, 2025. Beyond legal obligations, it’s an opportunity to improve user experience, performance, and your company’s reputation.

Simplified Standards Document: https://docs.google.com/document/d/1DZmpnzhUoOSF0zFLc4prIXsUXioI6h8PtIIY0_dPX9s/edit?usp=sharing

Compliance Checklist: https://docs.google.com/spreadsheets/d/1jh-giAHvTIOm457Nzi7XRRB8Uz0y1SXLQE8FAaW3Ft8/edit?usp=sharing

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