Navigating Digital Accessibility in Europe
Beyond WCAG: The Next Generation of Accessibility
Digital accessibility is increasingly critical for modern organisations. Teams generally understand the importance of meeting Web Content Accessibility Guidelines (WCAG). Yet, to genuinely grasp digital accessibility today, organisations must look beyond WCAG and embrace the broader, more comprehensive requirements of the European Accessibility Act (EAA), guided by EN 301 549 and EN 17161¹.
WCAG primarily covers web content elements such as colour contrasts, headings, navigation, and focus states—fundamental for accessible digital experiences but limited when viewed in isolation. Ensuring that a screen reader can navigate a website is the foundational starting point. Complete accessibility involves providing consistent, seamless experiences across all user interactions, from initial engagement to final transaction and support².
Understanding the Broader Scope of the EAA
The European Accessibility Act notably broadens digital accessibility expectations. EAA demands comprehensive accessibility across entire product and service lifecycles, including software applications, mobile apps, digital banking interfaces, e-books, and ticketing systems³.
Under EAA, accessibility covers precise information delivery, interoperability with assistive technologies, usability across diverse contexts, and seamless post-sale support. For instance, a digital banking app must offer barrier-free interactions, from account creation and management to customer support, across all platforms—desktop, mobile, or assistive devices. This end-to-end approach dramatically expands accessibility considerations beyond WCAG⁴.
Real-Life Implications of EAA Compliance
The practical implications of the EAA have become highly visible across Europe. Since the June 28th, 2025, enforcement deadline, disability associations in France have actively enforced compliance, issuing formal notices compelling major retailers to upgrade their accessibility measures rapidly. This enforcement highlights EAA’s shift from occasional audits to continuous compliance⁵.
Organisations must now integrate accessibility organically within their operational frameworks, comparable to privacy or security, involving continuous monitoring and improvements integrated seamlessly throughout product development and lifecycle management.
Operationalising Accessibility with EN 17161
From Checklists to Integrated Accessibility Governance
While WCAG and EN 301 549 outline accessibility requirements, EN 17161 provides organisations with a structured model for embedding accessibility within daily operations. It emphasises role-based accountability, continuous monitoring, proactive risk management, third-party compliance, and centralised reporting⁶.
Implementing EN 17161 involves cross-functional planning, clear accountability across leadership, and continuous integration of accessibility features. Organisations that proactively integrate accessibility early in development cycles effectively avoid costly retroactive fixes. This approach mirrors the comprehensive management strategies used in cybersecurity and privacy governance, such as those outlined by ISO 27001⁷.
Accessibility as a Cross-Functional Responsibility
EAA’s comprehensive framework demands that accessibility become deeply embedded within organisational cultures. From concept to user experience, every stage of product development must prioritise accessibility. This includes integrating accessibility checks during early software development phases, substantially reducing future costs and ensuring smoother product releases.
Organisations operating under EN 17161 view accessibility as an integral, ongoing operational responsibility. Accessibility standards must become a habitual aspect of development and governance processes, similar to standardised cybersecurity practices⁸.
Proactive Vendor and Third-party Alignment
Under EAA, organisations must actively ensure that third-party vendors align with comprehensive accessibility standards. Vendor compliance is now critical, ensuring that all user-facing digital solutions, including booking and payment systems, are interoperable with assistive technologies and meet accessibility requirements.
For example, digital ticketing platforms must guarantee that users with accessibility needs can effortlessly purchase tickets, access event information, and utilise support services. Proactive management of these third-party services under EN 17161 significantly reduces compliance risks and enhances user experiences⁹.
Building a Sustainable Accessibility Approach
Infrastructure for Comprehensive Compliance
Successfully operationalising accessibility under EAA requires a robust infrastructure that integrates continuous monitoring, proactive remediation, and clear governance policies. Effective operational models are designed around technological integration, inclusive organisational culture, measurable business impacts, international adaptability, and clearly defined governance policies¹⁰.
Integrated real-time accessibility checks, alerts, and remediation mechanisms enable teams to manage accessibility proactively. Centralised hubs provide transparency, accountability, and clear governance across diverse departmental workflows. Such infrastructure empowers teams to address accessibility challenges promptly and consistently, significantly reducing compliance risks¹¹.
Cultivating an Inclusive Organisational Culture
An inclusive culture is fundamental to sustainable accessibility compliance. Organisational practices must actively foster a culture where accessibility is a shared responsibility. Training, onboarding, incentive structures, and consistent messaging reinforce the importance of accessibility, embedding it within organisational values and daily practices.
Regular measurement of accessibility impacts on operational costs, product velocity, and customer satisfaction positions accessibility as a tangible business benefit as a clear and compelling business advantage. Organisations effectively enhance their competitive market positioning by prioritising inclusive practices¹².
Multidimensional Tracking for Continuous Improvement
Sustainable accessibility management requires recognising progress as inherently multidimensional. Organisations typically excel in specific areas, such as culture, while continually seeking improvements in governance and tooling. A practical accessibility management framework allows precise tracking of these varying dimensions, ensuring balanced enhancements across all areas.
Establishing a comprehensive record and action system supports ongoing compliance management. This approach enables organisations to swiftly adapt to evolving regulatory demands, continuously improve their accessibility standards, and ensure long-term sustainability¹³.
Kainjoo specialises in assessing and implementing comprehensive digital accessibility strategies aligned with WCAG, EAA, and EN standards, providing expert guidance to organisations seeking robust compliance and inclusive practices. For further insights, comments, or to explore how your organisation can benefit from an accessibility maturity assessment and implementation guidance, don’t hesitate to get in touch with Kainjoo directly.
References
¹ European Accessibility Act, European Commission, 2025.
² WCAG 2.1 Guidelines, World Wide Web Consortium (W3C), 2018.
³ EN 301 549 Accessibility requirements, ETSI, 2021.
⁴ EN 17161 Design for All – Accessibility following a Design for All approach, CEN, 2019.
⁵ Disability Rights Associations France, Official Notices, July 2025.
⁶ European Commission Harmonised Standards, July 2025.
⁷ ISO 27001 Information Security Management, International Organisation for Standardisation, 2022.
⁸ “Embedding Accessibility into Software Development,” IEEE Software, 2024.
⁹ European Digital Ticketing Accessibility Report, 2024.
¹⁰ Operationalising Accessibility: Best Practices, 2025.
¹¹ Accessibility Monitoring and Compliance Frameworks, 2024.
¹² Accessibility Impact Report, Harvard Business Review, 2024.
¹³ Sustainable Accessibility Practices, Journal of Organisational Management, 2024.
