The European Accessibility Act and Your PDFs
The European Accessibility Act (EAA) is the EU directive that requires a wide range of products and digital services to be accessible. Its requirements apply from 28 June 2025, and for many organizations that includes the PDFs they publish and distribute.
Who the EAA applies to
- Companies selling products or services to consumers in the EU, including from outside the EU.
- Sectors named in the act: banking, e-commerce, transport, e-books, telecoms, and more.
- Both the digital interfaces and the documents delivered through them.
What it requires
The EAA is outcome-based, but the recognized way to meet it for digital content is the EN 301 549 standard, which incorporates WCAG 2.1 Level AA. For PDFs, that means the same fundamentals: tags, alt text, reading order, headings, table headers, title, and language — the things PDF/UA defines.
Unlike a US lawsuit, EAA enforcement is handled by national market-surveillance authorities, with penalties set by each member state. Non-compliant products can be ordered off the market.
How to prepare
- 1Identify the consumer-facing PDFs in scope — contracts, statements, manuals, e-books.
- 2Check them against WCAG 2.1 AA and PDF/UA.
- 3Remediate and set up an accessible authoring workflow.
- 4Keep documentation of conformance, which the EAA expects.
Check your EU-facing documents for free on this site to gauge where they stand against WCAG 2.1 AA.