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Disability Inclusion in Europe
The European Accessibility Act (EAA) requires many products and services sold in Europe, from online stores to banking apps, to be accessible to people with disabilities. Built on legal research by White & Case LLP, this resource shows how France, Germany, Ireland, Italy, the Netherlands, Spain, and Norway are enforcing the law, and what it means for your business, wherever you are based.
NEW Research Findings At-A-Glance
The EAA applies to any company selling covered products or services in the EU, wherever it is based. Drawing on legal analysis conducted by White & Case, Disability:IN’s newest briefing on EAA enforcement in six key European markets brings surfaces several key trends:
- Initial enforcement architecture has begun to emerge across the jurisdictions surveyed
- Accessibility documentation is becoming concrete, and early enforcement activity is providing greater visibility into the types of accessibility documentation authorities may expect
- Early enforcement activity is coming from private actors, not public authorities
- E-commerce and financial services are the early focus of enforcement activities
- Blind and low-vision users have been identified as significant drivers of the majority of early accessibility enforcement activity
- AI products are not regulated differently than legacy tech
- Only Spain has exceeded the EAA’s minimum accessibility requirements
Understand the Implications for Your Company
Get the Full Guide
Accessible products and services reach more customers. With the EAA now in effect, accessibility is also part of competing in European markets. The full resource shows how each country is putting the law into practice, so your teams can plan market by market and focus investment where it matters first. It also covers what the EAA means for AI-powered products and content, helping you design for every customer from the start.
The full legal briefing by White & Case LLP includes country breakdowns for France, Germany, Ireland, Italy, the Netherlands, Spain, and Norway.
Put the Research to Work Across Your Business
The EAA touches strategy, product development, technology, procurement, legal and compliance, risk management, and customer experience. The full resource includes country-by-country tables your teams can use to plan by function and market.
- Map your EU footprint. List the covered products and services you offer in each market, including those sold from outside the EU.
- Check your documentation. Review conformity assessments, technical files, and accessibility statements against what regulators are asking for.
- Start where scrutiny is highest. Test your highest-traffic customer journeys first, especially online checkout, banking, and ticketing.
- Plan for differences by market. Use the country tables to adjust your approach where enforcement bodies, penalties, or scope differ.
- Document your progress. Keep records of proactive compliance work. Several markets treat this evidence as mitigating if issues arise.
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Compare enforcement bodies, penalty ceilings, and early precedents across markets. Check which documentation regulators expect and where self-reporting is treated as mitigating.
Prioritize testing on the experiences under the most scrutiny, starting with e-commerce sites, apps, and payment flows. Align testing with the functional standards regulators apply.
Plan for AI-driven interfaces and AI-generated content, such as images and video, to meet the same accessibility standards as traditional technology.
Download Considerations for Business Leaders: Disability Inclusive AI Resource (PDF)
Download Corporate Marketing & Communications Leaders Brief (PDF)
Understand the separate obligations for manufacturers, importers, and distributors. Confirm that suppliers of components for consumer-facing products can show conformity.
Use market-by-market findings to inform enterprise-wide strategy, set accessibility priorities and plan investment for Europe.
Turn Insights Into Action
Disability Inclusion in the EU (2024)
Disability:IN's 2024 legal analysis with White & Case and TrustLaw looks at what three European Union laws meant for disability inclusion in business when they were taking shape.
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AI is changing how employers recruit, evaluate and support talent, but established disability inclusion and accessibility obligations still apply- understand what that means for your company.
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Frequently Asked Questions
Get answers to common questions about our new research on the European Accessibility Act (EAA) enforcement from Disability:IN and White & Case, including what it covers and how companies can use it.
You can also explore commonly asked questions about our 2024 legal analysis, Disability Inclusion in the EU. The FAQ on this study also includes a short update on EU rules that have changed since it was published. Note: the European Accessibility Act has not changed. Because some of the dates and company categories in this report are now out of date, readers should check current EU guidance or speak with a legal advisor to confirm how these rules apply to them.
Are You IN?
Disability:IN partners with companies around the world to build accessible products, services, and workplaces. Talk with our team about what the EAA means for your business and how we can help you plan across European markets.
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