If you thought AODA was serious, Europe is about to make it look like a polite suggestion at a garden party. And it’s already late, so grab your pearls, you’ll need something to clutch on.
The EAA is a sweeping law requiring a wide range of products and services (think: websites, mobile apps, e-books, banking services, transportation, e-commerce platforms, ATMs, and more) to meet accessibility standards across the entire European Union.
The official compliance deadline is June 28, 2025. After that date, non-compliant companies could face enforcement actions, fines, or be shut out of the European market.
Should Canadian companies worry about the EAA deadline?
If your company sells, licenses, or provides products and services in the EU, even indirectly, you will likely be impacted.
Here’s the cold, hard reality:
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You don’t have to be based in Europe to be covered.
If a Canadian company has European customers, users, or partners, your digital products and services must comply.
(Think Shopify vendors, Canadian banks offering EU services, SaaS products, educational publishers, fintech startups, even airlines.) -
Accessibility documentation will be demanded.
Expect your European partners and clients to start asking for accessibility conformance reports (like EN 301 549 compliance statements, which are the EU equivalent of VPATs in the U.S.). -
Procurement and partnership barriers will rise.
If you’re not compliant, EU companies and governments simply won’t be able to buy your product or service. You’re not just risking lawsuits, you’re risking lost revenue streams. -
Legal liability exists.
EU enforcement mechanisms vary by country but can include fines, mandatory corrections, public naming and shaming, and contractual penalties.Priority Why it matters Immediate Action 1. Review your EU exposure. Do you sell into Europe? Even one customer triggers obligations. Create an inventory of EU-facing products, services, and contracts. 2. Get an accessibility audit done. If your digital offerings aren’t WCAG 2.1 AA compliant (soon 2.2), you will have problems. Engage accessibility experts now — remediation takes time. 3. Prepare to produce documentation. EU buyers will want proof of compliance (e.g., EN 301 549 conformance statements). Develop accessibility statements and documentation tailored for EU legal requirements. First Steps Checklist: Preparing for the European Accessibility Act (EAA)
1. Audit Your Exposure to the EU Market
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Inventory Products and Services:
List everything you sell, license, or deliver digitally that reaches European customers – directly or through partners, resellers, or subsidiaries. -
Identify Distribution Channels:
Do you sell on the App Store, Google Play, Amazon EU, Shopify EU, or similar? All of that counts. -
Review Contracts:
Watch for clauses with European partners that might trigger compliance requirements.
If you have EU customers, congratulations, you’re on the hook.
2. Assess Current Accessibility Compliance
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Audit Websites, Apps, and Digital Products:
Prioritize those used by EU customers. -
Check Against WCAG 2.1 AA (and 2.2 AA by late 2025):
The EAA expects compliance with these international standards. -
Don’t Forget Non-Web Digital Products:
PDFs, e-books, software interfaces, self-service kiosks – all must be reviewed.
No, “it’s kind of accessible” is not going to cut it.
3. Develop a Remediation Roadmap
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Triage Urgencies:
Fix critical blockers first (e.g., inaccessible navigation, missing alt text, keyboard traps). -
Plan for Full Compliance:
Accessibility isn’t a one-patch wonder. Build a timeline, assign owners, and stick to it. -
Include Mobile, Desktop, and Other Digital Interfaces:
Full ecosystem compliance matters, not just your website homepage.
With spring in full force, the clouds are already gathering. Have you built your ark yet? Don’t wait to build an ark after it starts raining.
4. Prepare Your Accessibility Documentation
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Create an Accessibility Statement:
Public-facing, honest, and aligned with EN 301 549. -
Develop a Conformance Report (like a VPAT):
If you don’t know how, hire someone who does. You’ll need this for B2B and procurement deals. -
Establish a Feedback Mechanism:
EU regulations require that users can report accessibility barriers easily.
No paperwork = No sale. Period.
5. Train Your Team
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Raise Awareness Internally:
Especially among developers, designers, product managers, marketers, and sales teams. -
Teach Compliance Basics:
Everyone should know what accessibility is and why it matters, not just the accessibility lead. -
Keep Up with Updates:
EAA compliance is a moving target (especially as WCAG 2.2 and future standards evolve).
Accessibility isn’t a department; it’s a team sport.
6. Monitor Legal and Regulatory Updates
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Stay Connected to European Regulatory Agencies:
Different EU countries will enforce slightly differently — watch for country-specific rules. -
Anticipate Sector-Specific Requirements:
Banking, transportation, education, and commerce have extra layers.
In Europe, ignorance of the law is not bliss, it’s expensive.
What Needs to Happen Now
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Triage:
Identify critical EU-facing digital assets immediately (websites, apps, e-commerce, client portals). -
Quick Audit:
Rapid accessibility testing to spot critical blockers (navigation, keyboard traps, missing alt text, mobile usability). -
Emergency Remediation:
Focus on the highest risk areas first: customer touchpoints, purchase funnels, service portals. -
Draft Accessibility Statements:
Even if everything isn’t 100% fixed yet, companies must show evidence of an active commitment and roadmap toward compliance. -
Prepare for Procurement Questions:
Clients and partners will start asking for accessibility conformance reports before the deadline, possibly next month. -
Crisis Communications Plan (Optional but smart):
Be ready to respond diplomatically if someone flags an accessibility barrier publicly. (Because they will.)
Final Thought:
Accessibility is becoming the new baseline for doing international business.
Early movers in Canada will not only dodge fines and lawsuits – they’ll win market share by being ready when their competitors are still busy playing catch-up. -