Does the EAA apply to my organization?

The EAA applies to private sector organizations with 10 or more employees or annual turnover exceeding €2 million that sell or distribute digital products or services to consumers in EU member states. Micro-enterprises below both thresholds have a derogation until 2030 for services (though not necessarily for products). Public sector organizations are covered by the Web Accessibility Directive, not the EAA — but equivalent obligations apply.

What is the penalty for EAA non-compliance?

Penalties are set by each EU member state. The Directive requires effective, proportionate, and dissuasive penalties. Several countries have published enforcement scales including formal warnings, mandatory remediation orders, sales bans on non-compliant products, and financial penalties proportional to turnover. Consumer organizations and accessibility bodies can also file complaints that trigger enforcement investigations.

Which PDFs are covered by the EAA?

PDFs distributed to consumers as part of a digital product or service in EU markets are in scope. This includes e-books, digital publications, product documentation, annual reports, policy documents, and e-learning materials. Internal-only documents not distributed to consumers have lower priority, but organizations should verify their national transposition law for precise scope definitions.

What is the fastest way to make PDFs EAA compliant?

Converting PDFs to EPUB3 is the fastest remediation path for most document types. EPUB3 satisfies WCAG 1.4.10 (Reflow) by design, and a good converter handles heading structure, reading order, table headers, and language declarations automatically. toolkit.bot converts PDFs to EPUB3 free, in about 30 seconds, with no account required. Validate output with ACE by DAISY to generate a formal WCAG 2.2 AA conformance report.

EAA 2026 Digital Accessibility Compliance Checklist for Organizations

The European Accessibility Act entered enforcement on June 28, 2026. Organizations selling or distributing digital products and services in EU markets are now subject to active compliance review. This checklist is designed for compliance managers conducting an EAA readiness assessment — covering scope determination, document remediation, web accessibility, and process documentation.

Step 1 — Determine If Your Organization Is in Scope

The EAA applies to private sector organizations that:

Have 10 or more employees, or
Have annual turnover exceeding €2 million
And sell or distribute digital products or services to consumers in EU member states

Checklist:

☐ Confirm headcount and revenue thresholds (micro-enterprises below both thresholds have a 5-year derogation until 2030 for services)
☐ Identify all digital products distributed in EU markets (websites, apps, e-books, digital publications, online services)
☐ Confirm whether you're a manufacturer, importer, or distributor under EAA — each has different obligations
☐ Check your member state's national transposition law (each EU country has its own penalties and enforcement mechanism)

Step 2 — Inventory Your Digital Products

You cannot comply with what you haven't catalogued. Build an inventory of:

☐ Public-facing websites and web applications
☐ Mobile applications (iOS and Android)
☐ PDF documents distributed to EU consumers (annual reports, product documentation, user manuals, e-books, policy documents, marketing materials)
☐ E-books and digital publications sold through any channel
☐ Self-service terminals and kiosks (physical devices in EU markets)
☐ Electronic communications services (customer portals, email services)
☐ Banking and financial services digital touchpoints

For each item: note current accessibility status (audited, unaudited, known failures, compliant) and assign a risk priority.

Step 3 — PDF Document Compliance (High Priority)

PDFs are the most common EAA gap for organizations outside the web development space. Most corporate PDF workflows produce non-compliant documents by default.

Why PDFs fail EAA: The EAA requires WCAG 2.2 AA conformance. All fixed-page PDFs fail WCAG 1.4.10 (Reflow) by design. Additionally, most PDFs lack semantic heading structure, correct reading order in multi-column layouts, language declarations, and accessible table markup.

PDF compliance checklist:

☐ Inventory all public-facing PDFs actively distributed to EU consumers
☐ Prioritize by distribution volume and user-facing importance (annual reports, product sheets, policy documents first)
☐ Run an accessibility audit on a representative sample using PAC 2024 or Adobe Acrobat Pro's built-in checker
☐ For each non-compliant PDF: determine whether to remediate in PDF (partial fix only) or convert to EPUB3 or HTML (full fix)
☐ Convert PDFs to EPUB3 using toolkit.bot — free, browser-based, resolves the majority of WCAG 2.2 AA failures automatically
☐ Validate converted EPUB3 files with ACE by DAISY to generate formal accessibility reports
☐ For complex or high-stakes documents (legal, regulatory, financial): arrange human expert review — see toolkit.bot Premium Verification
☐ Update your document production workflow to generate accessible outputs for all new documents

Step 4 — Website and Web Application Compliance

Websites and web apps must conform to WCAG 2.2 AA. Key checks:

☐ Run automated scans with axe DevTools, WAVE, or Deque axe — these catch roughly 30-40% of WCAG failures automatically
☐ Manual testing: keyboard-only navigation, focus management, skip links, visible focus indicators
☐ Screen reader testing: NVDA+Firefox and VoiceOver+Safari minimum
☐ Color contrast: confirm 4.5:1 for normal text, 3:1 for large text and UI components
☐ Form accessibility: all inputs labeled, error messages associated with fields, required fields identified
☐ Images: alt text on all meaningful images, decorative images marked as presentational
☐ Video/audio: captions on all video content (WCAG 1.2.2), audio descriptions where required (WCAG 1.2.5)
☐ Accessible name for all interactive elements (buttons, links, inputs)
☐ Mobile accessibility: touch target size (WCAG 2.5.8 requires 24×24 CSS pixels minimum in WCAG 2.2)

Step 5 — Accessibility Statement

The EAA requires organizations to provide an accessibility statement for digital products, describing:

☐ Which accessibility standard is being targeted (WCAG 2.2 AA)
☐ The conformance status (fully conformant, partially conformant, non-conformant)
☐ Known non-compliant elements and planned remediation timeline
☐ Contact mechanism for users to report accessibility issues or request alternative formats
☐ Enforcement procedure (link to the relevant national accessibility body)

An accessibility statement does not grant immunity from enforcement, but it demonstrates good-faith compliance effort — which affects how national enforcement bodies respond to complaints.

Step 6 — Establish Ongoing Compliance Processes

One-time remediation is not enough. EAA compliance requires ongoing maintenance:

☐ Integrate accessibility testing into your design and development workflow (shift-left testing)
☐ Require accessibility sign-off before launching new digital products or significant updates
☐ Set accessibility requirements for third-party vendor contracts (procurement standard)
☐ Designate an internal accessibility lead or compliance owner
☐ Schedule annual accessibility audits for high-priority digital products
☐ Establish a process for users to request accessible alternatives (particularly for PDF documents)
☐ Train content authors on producing accessible documents (heading styles, alt text, link text)

Step 7 — Documentation for Regulatory Purposes

National enforcement bodies may request evidence of compliance efforts. Maintain:

☐ Audit reports for each major digital product (dated, identifying the standard tested against)
☐ ACE by DAISY reports for EPUB3 documents (generated automatically after conversion)
☐ Remediation logs showing what was fixed and when
☐ Accessibility statements (maintain historical versions)
☐ Records of user accessibility complaints and how they were resolved

Immediate Actions for Non-Compliant Organizations

If your organization is currently non-compliant and enforcement is already active, prioritize in this order:

Audit and inventory: Know what you have before committing to remediation timelines
Remediate high-volume, public-facing PDFs first: These carry the highest complaint risk — convert to EPUB3 using toolkit.bot
Fix critical website failures: Missing form labels, keyboard traps, and missing alt text are the highest-priority WCAG failures
Publish an accessibility statement: Even if compliance is incomplete, a published statement with a remediation roadmap demonstrates good faith
Establish a complaint handling process: Users who cannot access content need a route to request accessible alternatives

Start PDF remediation today — convert free at toolkit.bot, validate with ACE by DAISY.

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For accessibility teams managing EAA compliance workflows, see our dedicated guide at toolkit.bot/for/accessibility-teams →