Web accessibility and the EAA: what does your site actually need?

For years accessibility was treated as niceness: something the public sector had to do, and something private teams "did if there was time". The EAA changes that frame for a concrete kind of private service — especially e-commerce, certain financial and transport-adjacent services, e-books, and electronic communications. In Denmark it is implemented as the act on accessibility requirements for products and services. Application started in June 2025. That is not a rumour. It is a date many shops have already passed.

That does not mean every marketing site is suddenly unlawful. It means you must be able to answer two questions before you buy a tool or promise a customer anything: is our service even in scope — and if yes, can a person using a keyboard, a screen reader, or low vision complete what you sell?

The second question is the one most teams skip. They buy an overlay, drop a badge in the footer, and call it compliance. The overlay does not change that your checkout button cannot be reached without a mouse, that form errors are only red borders, or that a video ad is the only explanation of shipping. The law asks whether the service can be used. It does not ask whether you bought a layer on top.

This is not legal advice. It is the engineering conversation you need before a lawyer can say anything useful. Without knowing your flows, "we are EAA-ready" is a sentence you cannot defend — not to the Danish Safety Technology Authority, and not to the customer who cannot pay.

The EAA is about products and services in named categories when they are aimed at consumers. E-commerce is the one we get asked about most: a site or app where a consumer can enter a contract — browse, cart, checkout, payment, account, delivery, returns. That is not only "the shop". It is also the steps you outsourced: payment, identity, the shipping picker. If those steps are part of the service, they are part of the problem.

Other categories typically include banking and certain financial self-service, electronic communications, e-books, certain transport and ticketing services, and a set of physical products with a digital surface. If you sell clothes online to consumers and you are not a microenterprise as the law defines one, you are in this conversation. If you run an internal time-tracking portal for your own staff, you are probably in a different one.

B2B is where people trip. A pure business service that is not sold to consumers is not what the EAA was written for. A shop that sells to both consumers and businesses, or a checkout that is the same for both, is a different picture. "We are B2B" is not a stamp you can put on a site where private individuals can still place an order. Scope is a legal call from what you actually offer — not from how you brand yourselves.

Microenterprises — the law uses headcount and a turnover or balance threshold — are typically exempt from the service requirements. Product rules can look different. We repeat this because vendors love to say "everyone must comply with the EAA". That is wrong. It is also wrong to assume you are exempt because you feel small. Count what the law counts. Ask a lawyer if you are unsure. An agency should not guess you into or out of scope.

When people say "we need to be AA", they usually mean Web Content Accessibility Guidelines at level AA. The harmonised standard that describes how digital interfaces should be perceivable, operable, understandable and robust is built on that thinking. POUR. It is a useful language. It is not a diploma you get after running an automated scanner.

A scanner is a fine first pass. It finds missing alt text, thin contrast, empty links, and inputs without a label. It does not find that your date picker traps focus, that "next step" is a div with a click handler, or that the error is only a red border. It also does not find that your copy is unparseable — including for people without a disability. Automation is a net. It is not the fishing.

The Danish public sector has lived under the Web Accessibility Directive for years. That is a different kind of duty, with statements and supervision that are not the same as the EAA. Copying a public-sector statement into the footer of a private webshop is not compliance. Borrowing their checklist — keyboard, contrast, captions, labels — is an honest place to start, whether or not you are in scope.

We treat WCAG as acceptance criteria on the flows that matter: home to product, cart, checkout, account, search, contact. A site can score neatly in a scanner and still be unusable at checkout. Conversely: a site with honest labels, visible focus, a sane heading order, and keyboardable dialogs is already far along — before anyone has said "AA".

First: keyboard and focus. Buttons that are divs, menus that only open on hover, dialogs without a focus trap and without Escape, missing skip links. Without that, the rest is cosmetics. On a Next.js site it often lives in your own components — not in the CMS. On WordPress it often lives in the theme and in the page builders that emit a <div> where there should have been a button.

Then: forms. A label that is visible and associated, errors that are text and tied to the field, honest autocomplete, and a checkout where each step has a heading. Payment and identity you embedded must be usable with a keyboard and must have a name. "It is the vendor's iframe" is an honest problem. It is not an exemption. You must be able to change vendor or demand an accessible embed.

Then: content and media. Alt text on meaningful images, empty alt on decoration, captions on the video that explains the product, and a heading order that mirrors the page — not a jump from h1 to h4 because the design looked nicer. That is also SEO. A page a screen reader can parse is a page a crawler can parse. Core Web Vitals and accessibility are not the same, but layout shift that steals the click on "buy" is both.

What we leave waiting: repainting every icon, writing statements before flows work, and "making the whole archive AA" while checkout is still a mouse trap. Prioritise what a person must be able to do today. The archive and the old campaign landing can wait until the purchase works. An agency that starts with an eighty-page report and no change in the cart has sold you theatre.