Voices - CCIA
With the EAA coming into force, what are the biggest implementation challenges across different EU markets?
CCIA Europe and all its Members strongly support the European Accessibility Act's goals. However, the larger challenges have included the dramatic delays on the side of the European Commission, standardisation bodies and Member States.
Currently, the Act is being enforced in certain Member States, but compliance and derogation processes are still not fully formalised. Moreover, the necessary standards will not be approved until, at least, mid-2026, half a year to a full year after enforcement started. Yet, the Article 28 Working Group, meant as a forum for sharing information, learning lessons and coordinating stakeholders with regulators, thus harmonising the EAA’s implementation, has not been established yet. Consequently, stakeholders have no formal place to provide feedback or input. We know that some regulators deny meeting requests or simply do not respond when formally asked for information, which puts digital sector firms in a difficult position.
Member States have also been delayed in implementation and regulator designation. For instance, Germany only created its centralised regulatory body a few months after the EAA came into force and France published its derogation and non-compliance processes in November of 2025, which is five months after enforcement began. Their guidance on implementation is either non-existent or only now getting up to speed, while other Member States already have enforcement and official documents in place.
Another major challenge is that non-compliance reporting and derogation requests are not harmonised across the 27 markets. A company operating in multiple EU Member States may have to report in 27 different ways. Some regulators have full-fledged official websites for this purpose aim, while others do not even provide any clarification regarding what needs to be done.
For tech companies operating across multiple EU markets, what is the biggest pain point?
The delayed standards and the lack of guidance are definitely the biggest pain points. While these are even more burdensome for smaller companies, larger companies also struggle to ensure total compliance without clarity and direction.
CCIA Europe has asked Member States for interim guidance during this gap period, but most were hesitant to provide any information as they too were still trying to get up to speed. Some Member States such as Sweden confirmed they will use existing standards as "good faith measures”. Yet, those provided by other Member States have made compliance even more unclear. France, for example, declared they will only look at the EAA for evaluation rather than existing guidelines, which is highly problematic as the EAA has both prescriptive and non-prescriptive obligations. Regulators may end up arbitrarily deciding what counts as ‘compliant’ before any common understanding has been established.
What these setbacks mean in practice is that companies with a universal design approach, placing accessibility at the core of product development, can actually be delayed in product releases as teams are forced to wait for the EEA standards to ensure compliance.
Beyond compliance, is the EAA driving genuine cultural change around accessibility?
As one of the first wide-ranging accessibility-focused legislations in the EU, it is definitely fuelling an inspiring cultural change, both in companies already focused on accessibility and newcomers to the space.
The major issues we are observing have less to do with the EAA's goals and more with how it is being carried out. Had the standardisation bodies and Commission kept to their timelines, we would be in a different position today, one with strong guidance, harmonised enforcement and clear benchmarks.
Instead, some EU Member States are now enforcing the EAA with varying methods, leaving companies, especially those with fewer resources, focused on box-checking rather than meaningful accessibility improvements. Some countries are even proposing legislation which goes beyond the EAA's scope, thus risking fragmenting the market even further.
What would shift accessibility from regulatory burden to business opportunity in executives' minds?
It is essential to recognise what the disability community calls for. Consistent collaboration between companies and consumers with disabilities shifts the mindset from compliance burden to something positive. This kind of interaction, focused on real-world experiences, shows companies how important these people are to the market and economy. In terms of industry response, there seems to be very little, if any, pushback to the EAA and its goals, which is extremely rare for any type of new EU legislation, I can assure you.
Yet, the impact is also more practical. For example, when hosting events, not every organisation here in Brussels initially considers wheelchair accessibility, but once someone from the team focuses on these topics, the question becomes, "How do we do this?", rather than, "Why do we have to?". This type of mindset is what the EAA has generated in terms of shifting accessibility perception.
How can we ensure standards keep pace with technological evolution?
Standards already consider product longevity. ICT innovation, though rapid, is still planned. Also, standardisation boards include people who think ahead about what technology might look like in a few years.
It is important to highlight that standards are guidelines, not rigid requirements. If companies develop innovative technologies that do not perfectly fit standards, but adopt an accessibility-first approach, they are already moving in the right direction. Alternatively, they might achieve the same goal in a different, more innovative way, one that those who set the standards may not have considered.
The EAA review comes in 2030, which is four years after standards take effect. We need forward thinking now, so people are not caught off guard again. Standards must be consistently updated.
What are CCIA's key advocacy priorities around EAA implementation?
CCIA Europe’s priorities are tangible: getting standards done, holding the Commission to its requirement for the Article 28 Working Group and advocating for harmonised enforcement across all 27 EU Member States.
Yet, most importantly, we are advocating for the EAA to succeed. In the regulatory space, Europe often moves too quickly to the next piece of legislation without letting the current one settle. We need to see how the EAA performs, how enforcement unfolds, and what is missing.
The Commission's new accessibility strategy is expected in June 2026. The question is whether new flagship legislation will duplicate what the EAA already covers. If the EAA fails for whatever reason, will the next legislation simply copy the same approach, repeat the same mistakes and fail too? Until we have hard facts on performance, let us not redo what we may have already done.
Are there tools from outside Europe that could support the EAA's goals?
Indeed, the EU does not always need to reinvent the wheel. Sometimes, the best approach is to look at what is already working elsewhere and adapt it. Many of our Members are global companies that have been pioneers in accessibility for years, long before the EU even started to think about harmonising accessibility standards across its 27 markets.
There is a lot Europe can learn from their experiences. Take Apple, for instance, when they first focussed on accessibility years ago, they started small, by asking how technology could help students with disabilities in classrooms. That practical, real-world focus eventually shaped their wider accessibility strategy. It is a great reminder that education and concrete use cases can be powerful tools in advancing the EAA’s goals.
Another example is Google, which has integrated accessibility teams directly into its product development process. Such an approach ensures accessibility is considered from the ground up, across various services and products.
The crucial question is: what can Europe take away from these processes? Companies were not held back by hesitancy or uncertainty before, so we need to make sure that the EEA does not slow down truly transformative technologies going forward.
Interview by Karolina Mendecka
Business Accessibility Forum Director