Does the European Accessibility Act apply to US companies?

Yes, if you sell to or have users in the EU. The EAA is market-access regulation — if your product reaches EU consumers through any channel, you need to comply. Being incorporated outside the EU doesn't exempt you.

What's the difference between WCAG 2.1 A, AA, and AAA?

Level A is the bare minimum (e.g., alt text, keyboard access). AA is the practical standard most laws require, including the EAA — it's what you aim for. AAA is aspirational and often impractical for marketing or branded content. Target AA, document anything that can't meet it, and move on.

How long does an accessibility audit take?

A full WCAG 2.1 AA audit of a mid-sized web app takes 3-5 business days of focused work. At Testopius it's bundled into the 1-week Full QA Audit, so you don't pay for two separate engagements.

What tools do you use for accessibility testing?

A mix: axe DevTools, WAVE, Lighthouse, Chrome accessibility inspector, and real screen readers (VoiceOver on Mac, NVDA on Windows). Automated tools catch about 30-40% of issues; the rest requires manual testing with a keyboard and screen reader.

2026-10-28·10 min read

The European Accessibility Act is live — 12 accessibility tests every web app must run

The EAA has been enforceable since June 2025. Fines go up to €100,000. Most startups still ship inaccessible UIs. Here are the 12 tests I run on every Full QA Audit — and why skipping them is now a legal risk, not just a UX one.

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On June 28, 2025, the European Accessibility Act (EAA) became enforceable across all 27 EU member states. If you sell to European consumers — SaaS, e-commerce, fintech, media, banking — your product has to meet WCAG 2.1 AA standards or face fines up to €100,000, plus the possibility of being banned from the single market.

The weird part: most of the startups I audit still don't know this is their problem. The engineering team says "we'll do accessibility later." The founder says "we have EU customers but we're not a bank, we're fine." Both are wrong.

This post is the 12-point accessibility test I now run on every Full QA Audit, and the reasoning behind each one.

Who the EAA actually affects

If you have EU users and you sell any of these, you're in scope:

E-commerce platforms
Banking and payment services (fintech)
E-books, media streaming, communications
Transport ticketing
Smartphones, tablets, computers, and their software
Self-service terminals (ATMs, ticket machines)

"B2B software" is a gray area but the clear direction is: anything a human uses, needs to be accessible. Don't bet your market access on the gray zone.

The 12 tests I run

### 1. Keyboard navigation top-to-bottom

Can a user tab through every interactive element in a logical order, without a mouse? If any button, link, or form field skips, traps focus, or lands in the wrong place — that's a WCAG 2.1.1 failure.

Test: Unplug your mouse. Try to complete your signup flow. Count every element you can't reach.

### 2. Visible focus indicator

When you tab onto an element, you must see where you are. A missing or invisible focus ring (common with outline: none CSS resets) breaks WCAG 2.4.7.

Test: Tab around with keyboard. If you can't tell which element is focused, you fail.

### 3. Semantic HTML (not div soup)

Screen readers can't parse 50 nested divs. Use