Accessible by Law: How the European Accessibility Act Is Reshaping the Customer Journey

For years, digital accessibility in Europe was mostly the public sector's problem. Private brands could treat it as a nice-to-have - something for the next redesign. That ended on 28 June 2025.

The European Accessibility Act (Directive 2019/882) now applies to a defined set of consumer products and services in every member state. On the service side, it covers the journeys Europeans use every day: electronic communications, audiovisual media, passenger transport, consumer banking, e-books and e-commerce. And it doesn't stop at the EU's borders - it applies to any business offering covered products or services on the EU/EEA market, wherever it is headquartered.

The directive reads like a compliance document. In practice, almost every requirement lands on a screen that a designer owns. For European brands, accessibility has moved off the backlog and onto the critical path of the customer journey.

Three Rules Every EU Customer Journey Now Has to Follow

1. Everyone Has to Be Able to Finish the Journey

The EAA sets accessibility outcomes and leaves the technical “how” to harmonised standards - in practice, EN 301 549, which aligns with WCAG 2.1 Level AA. The examples read like a UX brief: text descriptions for images, every function usable from a keyboard, enough time to read and act, predictable content, and compatibility with assistive technologies.

The audience is not a niche. Nearly a quarter (23.9%) of people aged 16 and over in the EU reported a disability in 2024 - around 90 million adults. Add older customers, and anyone completing a checkout one-handed on a train, and the “edge case” becomes a significant share of your market.

A close-up of a hand pressing the keys of a dark keyboard, representing a customer completing an online journey with a keyboard alone. — Across the EU, a checkout that can't be completed with a screen reader or a keyboard is now a compliance gap as well as a lost sale.

2. Brands Have to Show How They Meet the Rules

Covered services must publish information describing how they meet the accessibility requirements. Most haven't caught up: one 2026 analysis of 326,250 European homepages, tested after the deadline, found a 91.45% failure rate against WCAG 2.1 and EN 301 549.

The exemptions are narrower than many brands assume. Only microenterprises providing services - fewer than 10 employees and annual turnover or balance sheet of €2 million or less - are fully exempt. For everyone else, a “disproportionate burden” claim has to be assessed, documented, and made available to authorities on request.

3. Enforcement Is National - and It Has Started

The EAA is one directive, enforced 27 different ways. A few examples show where things are heading:

France: In July 2025, disability associations apiDV and Droit Pluriel sent formal notices to Auchan, Carrefour, E.Leclerc and Picard Surgelés. In June 2026, the Caen Judicial Court ordered Carrefour France to make its online shop and app fully accessible within six months, with a daily penalty for every day past the deadline.
Germany: A joint authority of the federal states, the MLBF, oversees most covered products and services. It formally began operating on 26 September 2025, and fines can reach €100,000.
Italy: The digital authority AGID introduced a two-stage model in May 2026 - a cooperative fix-it phase with deadlines, followed by formal sanctions if problems persist.
Denmark: The Danish Business Authority supervises webshops and banking services against EN 301 549 and WCAG 2.2, combining testing tools with manual user tests.

“Across Europe, accessibility is no longer a feature request. It's a condition of selling online - and enforcers are testing it the way your customers do.”

What It Means, Sector by Sector

Europeans shop online at scale - 78% of EU internet users bought something online in 2025. That makes each sector's main digital journey the place where accessibility gaps cost the most. Here's where we'd look first:

Banking

Log-in, transfers and payment confirmations. Session timeouts are the quiet risk: a flow that logs out a slower customer mid-payment fails the “enough time” requirement and the customer at the same time. ING, BNP Paribas, Santander and the digital challengers are held to the same standard.

Insurance

Insurance isn't named as its own category in the EAA - but an online quote-and-buy flow, where a consumer concludes a contract through a website or app, sits close to the directive's definition of e-commerce and is worth checking against it with legal advice. Either way, a quote form a customer can't complete is a policy that Allianz, AXA, Generali or ERGO doesn't sell.

E-commerce & Retail

Product filters, image-heavy product pages and checkout. Webshops are the core of the law's scope and the place where the first court orders have landed. For Zalando, IKEA, Carrefour and every regional retailer, the checkout is now the most legally exposed screen they own.

Telecoms

Sign-up, plan comparison and self-service fault reporting. Electronic communications services are explicitly in scope, and customers comparing Vodafone, Orange, Deutsche Telekom and Telefónica will feel the difference before any regulator does.

Transport & Travel

Booking flows, ticketing apps and real-time information. Air, bus, rail and waterborne passenger services are covered - including their websites, apps and e-tickets. For Lufthansa, Air France-KLM, Deutsche Bahn and SNCF, the booking journey is both a revenue line and a compliance surface.

Hotels & Restaurants

The direct booking engine and online ordering. Where a guest concludes a contract online, the journey falls within the EAA's e-commerce scope unless the business qualifies as a microenterprise. For Accor, Meliá and independent hotel groups, an inaccessible booking engine sends guests to an OTA that may have fixed its own.

Five Questions to Ask of Your Own Journey

Before commissioning anything, it's worth walking through your own journey as a customer would and asking:

Can someone complete it with a keyboard alone? Put the mouse away and try to buy, book or pay. If you get stuck, so will a customer using assistive technology.
Does it give customers enough time? Time your log-in, quote or checkout at a relaxed pace. If the session expires first, you're losing customers who never complain.
Is every key fact available in more than one way? Prices shown only in colour, instructions only in video, and errors only as a red outline all fail someone.
Would a customer understand it at first read? Terms, fees and error messages written for a lawyer fail the “understandable” principle - and everyone else too.
Have you tested it with people, not just a scanner? Automated tools catch the obvious issues. The European Disability Forum has said overlay widgets cannot replace actual compliance.

How Tetrabase Benchmarks European Customer Journeys

Answering those questions properly takes two kinds of evidence: how your journey compares with the competitors your customers actually consider, and how real customers in your market behave when they use it. The Tetrabase Framework combines both, benchmarking each stage of your journey against 5-10 comparable brands in your market and testing it with local customers. You get:

A side-by-side view of how clear, usable and completable your journey is compared with 5-10 competitors, stage by stage
Evidence of where customers hesitate, misread or drop out - not just what an automated scan flags
Friction points ranked by their effect on conversion, retention and complaints, split into quick fixes and structural changes
One prioritised roadmap that digital, product, compliance and CX teams can all work from

Across the EU, accessibility is now part of the price of entry.

Every brand in your category is working to the same directive, in front of the same customers and, increasingly, the same courts. What separates them is whether the result feels like a box ticked or like a journey anyone can finish - and the only way to know which one you are is to see your journey next to theirs.