EAA European Accessibility Act: from Obligation to Opportunity

What happens on June 28, 2025? From this date, digital accessibility will no longer be an option or a "nice practice" to implement with residual end-of-project budgets. It will become a binding legal requirement that will separate who can continue to operate in the market from who will be excluded. An important page in the European digital market.

Of course, being a new requirement, many organizations frown upon it, seeing it as yet another bureaucratic cage imposed by Europe. But are we sure that the European Accessibility Act (EAA) represents just another regulatory obstacle to overcome? What if, instead, it concealed a unique opportunity to stand out, a competitive differentiation opportunity, particularly in the world of public administration?

The most forward-thinking companies are already changing perspective. Those who truly shine a light on the future stop calculating "how much will it cost us to comply?" and instead ask "how much advantage can we gain, what strategic return, by embracing and anticipating this change?".

This article is a magnifying glass focused on this shift in approach. It explores how to transform regulatory compliance into a strategic asset, examining not only the technical implications of the EAA but also its potential for business transformation as a true engine of growth and innovation.

Those who understand first that website accessibility is no longer a marginal cost, an optional extra, but a core element of the digital product will obtain a measurable competitive advantage: in public tenders, in expanding the potential market, in reducing operational costs, and in innovating digital products.

And you? Are you ready to look at the European Accessibility Act 2025 with new eyes?

Beyond Compliance: The shift in digital accessibility

The EAA (EU Directive 2019/882) introduces stringent requirements for digital products and services. The regulation requires compliance with the WCAG 2.1 AA level (Web Content Accessibility Guidelines), a framework that requires significant interventions on architecture, interfaces, and development processes. Our compendium on the EAA is a comprehensive guide that analyzes these requirements in detail (it's focused on Italy and available in Italian only), but it's essential to understand that the impact is systemic.

From "nice to have" to primary functional requirement

Historically, website accessibility has often been treated as a secondary element, managed with residual budgets and addressed in the final phases of projects, when fundamental architectural choices were already consolidated. This approach has led to suboptimal, expensive, and often ineffective solutions.

With the entry into force of the European Accessibility Act 2025, we are witnessing a fundamental paradigm shift: accessibility becomes a primary functional requirement, on par with security or performance.

This shift is particularly evident in the public sector, where tenders and bids will necessarily have to include detailed and binding accessibility requirements from the functional specification phases, in line with what is also provided for by the AGID accessibility guidelines.

In the context of recent public tenders, digital accessibility requirements occupy an increasingly significant portion of the total technical specifications, with contractual clauses that provide for penalties in case of non-compliance. This is indicative of the direction the market is taking, with increasing attention to web accessibility as a key element of digital transformation.

Rethinking budgets: from accessibility as a cost to accessibility as an investment

Decision makers must make a crucial mindset change: stop seeing website accessibility only as an additional cost to minimize, and consider it as a true strategic investment that decides who will be competitive tomorrow.

Companies that see far ahead, that are already anticipating this shift in perspective, are already securing important competitive advantages.

• First of all, a significant part of development budget is allocated to accessibility, from the design phases. This is an important change in approach, integrating it directly into the basic design and development costs, not as an extra expense at the end of the project.
  
  This advantage develops in two directions. On one hand, the organization budgets for its own accessibility, for its properties and internal projects. On the other hand, service providers such as tech companies, developers, designers, and agencies already include all aspects of accessibility in their offers, offering "accessible by design" solutions and differentiating themselves by skills and professionalism from other entities for which they are still extras.
  
  
• In tender contexts, moreover, we are witnessing an important modification of the evaluation parameters, with accessibility criteria and usability that are taking more and more weight, becoming an element that can make a difference in the evaluation of offers.
  
  Accessibility can therefore represent a true growth engine for organizations, even more so for those that have important relationships with the public sector.
  
  
• Last but not least, virtuous organizations are already investing in the creation of internal skills dedicated to digital accessibility and their promotion in internal culture and processes, laying solid foundations to transform the mere regulatory requirement into a concrete opportunity for innovation.

Because implementing accessibility doesn't mean making superficial and trivial adjustments. It requires a holistic vision, a true rethinking of information architecture, user interaction, and the entire development process.

For decision makers, this means considering website accessibility not as an additional end-of-project cost, but as a structural investment, a solid foundation in the foundations of the digital product. An investment that, among other things, puts you in line with the WCAG guidelines (level 2.1 AA) and all Italian regulations on the matter.

Integration of accessibility into the design system

If you want to build a site or application that is truly accessible and EAA compliant, capable of growing with you, the real starting point is the design system. It is the foundation for any scalable implementation of the Accessibility Act. Think of it as the instruction manual for your digital interface, but it speaks accessibility from the first page.

Working side by side with clients in various sectors, we have refined an approach based on some key principles:

• Accessibility by design: Integration of WCAG 2.1 AA requirements from the early design phases. It means considering accessibility from the start, not thinking about it later.
• Continuous testing: Constant verification of compliance with WCAG 2.1 AA requirements during the development process. The check happens step by step, as we build, not just at the end. Additionally, we implement both automatic and manual checks.
• Training and awareness: We promote the spread of web accessibility culture within teams, both ours and clients'. It is essential that it becomes part of the DNA, the way of operating, so that accessibility is always considered and not an afterthought.

This methodological approach allows us to approach projects with an integrated vision of accessibility from the beginning, reducing subsequent implementation costs and improving the overall quality of digital products, for all users.

The first phase consists of auditing the existing design system (or designing a new accessible one from scratch). This requires a deep and systematic analysis that looks at:

1. Inventory of critical components: We identify high-impact UI components (by frequency of use or importance), such as search forms, checkout, authentication, and main navigation. We then perform a check-up, evaluating their compliance with the requirements of the Web Content Accessibility Guidelines.
2. Engagement flow analysis: We put ourselves in the users' shoes and map the main user paths to identify potential accessibility barriers at critical touchpoints. We use evaluation methodologies aligned with AGID accessibility requirements.
3. Interaction patterns: We define standardized patterns for more complex interactions such as modals, dropdown menus, and multi-step forms. These standards must comply with the web accessibility guidelines.

Implementation strategies for digital architecture

Accessibility profoundly impacts the overall architecture of digital products. For decision makers, it's important to understand how this translates into concrete requirements for development teams.

Accessible front-end architecture

The front-end is the direct point of contact between your digital product and people. This is where a fundamental match for accessibility is played. It's not enough that it "seems" accessible; it must be so in its architecture.

This means going beyond the visual aspect, taking care of the code to include the correct accessibility tags and to manage interaction, navigation, and information that changes in real-time.

Indeed, accessibility goes beyond aesthetics, making the use of a site inclusive for people with limited interaction capabilities or using non-standard devices. Think, for example, of those who use the keyboard to navigate, those who rely on a screen reader, or even those who simply suffer in case of animations. A front-end architecture designed to be accessible from the beginning makes a concrete difference for the end user.

An accessible front-end architecture must support:

• Advanced focus management: The focus (i.e., where the user is on the interface at a given moment) must be maintained consistently during navigation and during dynamic content updates, moving logically, in compliance with the WCAG guidelines. This is vital for a single-page application, where content and layout can change dynamically without reloading the page.
  
  
• Accessible routing: Transitions between pages must be appropriately announced to screen readers (even if technically it's always the same page in a single-page app). This is a requirement explicitly mentioned in website accessibility specifications.
  
  
• State management and notifications: Asynchronous updates of the interface that happen "behind the scenes" (such as a success message after filling out a form, a validation error, or data that updates automatically in a dashboard) must be communicated to users of assistive technologies, a fundamental element of digital accessibility.

In short, accessibility is not just about contrast between elements, font readability, or alternative texts for images, but also much more complex and less obvious aspects. As can be inferred from these examples, ensuring that such technical aspects are impeccably managed is not trivial. It requires specific front-end skills, deep knowledge of WCAG guidelines, and an approach to development that puts accessibility at the center, from design to code writing.

The choice of an expert partner like SparkFabrik, able to effectively guide important projects in the new landscape of digital accessibility, is more fundamental than ever.

Quality Assurance and Continuous Testing

Website accessibility requires a structured approach to testing, integrated into the development process. An effective testing framework includes:

1. Automated tests: Integration of automatic accessibility checks in the continuous integration pipeline, using tools that verify compliance with WCAG 2.1 AA
   
   
2. Manual tests: Automatic checks, unfortunately, are not sufficient for a comprehensive view of accessibility, at least currently. It is necessary to combine manual audits and human insights.
   
   
3. Testing with real users: Involvement of users with disabilities (the real users of these features) in the testing phases, essential for a complete assessment of website accessibility
   
   
4. Continuous monitoring: Implementation of specific analytics systems to track the use of digital accessibility features. Based on such data, it is possible to understand whether it is appropriate to prioritize further improvements and accessibility features, going even beyond the WCAG 2.1 AA standard imposed by the regulation.

This methodology allows for early identification and resolution of accessibility problems, significantly reducing overall development and maintenance costs, and identifying further areas for improvement.

ROI of accessibility: transforming an obligation into a business opportunity

As already touched upon, the implementation of digital accessibility brings tangible benefits well beyond simple regulatory compliance, representing a genuine business opportunity. Let's review these aspects in detail.

Accessibility as a competitive advantage in public tenders

With the entry into force of the European Accessibility Act 2025, accessibility criteria will become discriminating factors in public procurement procedures:

• Public entities are already modifying the criteria for evaluating offers, with technical scores dedicated specifically to accessibility, in line with the AGID accessibility directives
• Contracts increasingly include penalty clauses related to non-compliance with WCAG 2.1 AA requirements
• Certifications and demonstrable skills in web accessibility are becoming prerequisites for participating in certain tenders

This trend is particularly evident in the public sector in Italy, where website accessibility is becoming a central element in the technical evaluations of offers, with increasing attention to adherence to WCAG guidelines and national regulations.

Benefits beyond compliance

Website accessibility can lead to concrete results in various areas:

• Market expansion: More accessible products can reach a wider audience, including users with disabilities and the growing elderly population
  
  
• Improvement of user experience: Accessible interfaces are generally more usable for all users, demonstrating how accessibility and usability are two sides of the same coin, leading to greater satisfaction and loyalty
  
  
• SEO optimization: Many website accessibility criteria coincide with SEO best practices, improving search engine positioning. The WCAG guidelines promote a semantic code structure that search engines reward
  
  
• Reduction of support costs: More intuitive interfaces compliant with Web Content Accessibility Guidelines generate fewer assistance requests, reducing operational costs

Budget allocation: accessibility as a strategic investment

It is essential to rethink the allocation of budgets for digital accessibility:

• Integrate web accessibility costs into base design and development budgets (not as a separate item to cut in case of constraints)
• Consider training in WCAG 2.1 as an investment in strategic skills for internal teams
• Evaluate accessibility in terms of return on investment in the medium-long term, not just as an immediate compliance cost
• In the case of service providers such as tech companies, developers, and designers, projects proposed to clients must already take into account accessibility aspects

This approach allows for obtaining natively accessible products, avoiding the significantly higher costs of corrective interventions after realization. In this historical phase, there is obviously a race to adapt one's properties by organizations, with highly variable but potentially very significant costs, in the case of important projects. New projects, on the other hand, will necessarily have to be approached by taking accessibility requirements into account from the outset.

Application examples: financial sector and e-commerce

We have observed different approaches to implementing accessibility in various sectors.

In the financial sector: The implementation of digital accessibility in this area is particularly critical, considering the complexity of operations and the sensitivity of the data processed. The most advanced financial institutions are adopting an integrated approach that includes:

• Review of the user experience with particular attention to authentication and authorization paths
• Simplification of processes to reduce cognitive load, benefiting all users
• Implementation of alternative methods for critical operations in compliance with the Web Content Accessibility Guidelines

These implementations have generally led to a significant improvement in the overall user experience, especially for the more senior segments of the clientele, with a consequent increase in the use of digital channels.

In the B2B e-commerce sector: In this area, the approach to website accessibility must take into account the complexity of management interfaces and the frequency of use by operators. The most effective strategies include:

• Optimization of repetitive workflows with advanced keyboard support
• Implementation of advanced search systems and filters with support for assistive technologies
• Reporting and accessible dashboards even for users with visual disabilities, as required by AGID accessibility regulations

These interventions often lead to improvements in the productivity of all operators, not just those with disabilities, demonstrating how accessibility can be a driver of operational efficiency.

From constraint to opportunity: are you ready for change?

We are at a turning point: digital accessibility is rapidly moving from a secondary element, managed with residual budgets and considered an inevitable cost, to a strategic factor that will determine winners and losers in the post-2025 digital market.

The questions that every decision maker should ask today are no longer limited to "how to comply", but extend to:

• How can we leverage the European Accessibility Act to gain a competitive advantage in public tenders?
• How much added value can we generate by integrating website accessibility into the core of our products?
• How to rethink development budgets to transform an obligation into an opportunity?
• Who within our organization will be responsible for implementing the WCAG guidelines?

The European Accessibility Act 2025 is not just a regulation to comply with, but an opportunity to redefine one's positioning in the market. In particular, in public tenders, the difference between winning and losing could lie precisely in the ability to demonstrate not only compliance with the AGID accessibility directives, but excellence in accessibility.

At SparkFabrik, we deal with these issues daily in custom development projects, integrating accessibility and usability considerations at every stage of the software development cycle, with the aim of transforming a regulatory requirement into an opportunity for improvement and innovation.

WCAG 2.1 AA: not so difficult, with the right partner

For many organizations, the topic of accessibility is a complete novelty. Achieving the level of accessibility required by the regulation, the WCAG 2.1 AA standard, may seem like a challenging peak to climb, full of technicalities and potential costs.

At SparkFabrik, we deal with accessibility daily, and in our daily experience, we have learned how to intervene effectively and with the right priorities, how to apply the right methodologies, how to correctly interpret the guidelines, how to "think" accessible. For this reason, we know that accessibility is perfectly achievable, even quickly and without groping in the dark. As is normal, when you know how to do it and have experience, everything is simpler.

This is why, to make your digital properties accessible effectively and without wasting resources or time, relying on an expert partner like SparkFabrik makes all the difference. A partner who not only knows the WCAG guidelines by heart (we have also created a free and 100% accessible compendium, in Italian), but knows how to apply them concretely in the development process, integrating accessibility from design and code writing. This allows you to achieve compliance efficiently and durably, transforming an obligation into a real opportunity.

Additionally, a further evaluation is necessary. The adaptation to the EAA in this particular phase of introduction is actually part of a moving scenario. Regulations on digital are constantly evolving, and it is likely that in the coming years the level of accessibility required will be further raised (moving from the WCAG 2.1 AA standard to a higher standard).

Getting compliant today with a solid and forward-looking approach and an expert partner is an investment for the future, which prepares you to calmly face the requirements that will come.

A reflection on the gap between regulations and technology (and AI entering the scene)

Let's take a step back and look at the big picture. Digital accessibility is a virtuous goal to aspire to, to make the internet inclusive and accessible to all users. The new regulation will have the positive effect of raising the overall level of accessibility.

However, this digital accessibility regulation, like others in the digital field (think of NIS2 or DORA), has been in definition for some time. Perhaps, too long, if we think about the speed with which the world of technology moves and evolves.

While the regulation was being discussed, approved, transposed, and finally entering into force (over the course of several years), the tech landscape has radically transformed. Meanwhile, revolutionary technologies have emerged, very powerful, powered by AI.

Think of computer vision that "sees" and understands what's on the screen, text-to-speech tools with natural voices unthinkable until a few years ago. Or again, the ability of AI to describe images, autonomous agents that can operate in our place (not only to automate and make efficient, but also to support those with motor and interaction difficulties), or even the ability of AI to understand and even write code, helping developers.

This scenario leads us to an interesting reflection: perhaps, in a not-too-distant future, many accessibility problems could find more efficient and generalized solutions directly integrated at the level of browsers or operating systems, with the support and integration of brand new AI functions (for example, Apple has recently announced many new accessibility features, available directly in iOS 19).

It could be a potentially more effective approach compared to the current scenario, where each single entity must activate to comply, individually and autonomously.

We therefore do not hide a sad criticism for the time that was necessary to have a regulation that would regulate accessibility. Too long timeframes, and an "unfortunate" timing that could soon make the regulation itself and the requirements imposed by it completely superfluous.

This does not make current compliance less stringent, which remains a duty and, as we have seen, an opportunity. But it's a fascinating perspective on the potential of technology to make accessibility a native and universal characteristic of the digital experience. Regardless of the means, AI or human intervention, what counts is the result: a more accessible and inclusive internet for everyone.

Next steps

To support decision makers in understanding and implementing the EAA requirements, we have created an interactive compendium, a complete guide on accessibility in Italy that provides a simplified and synthetic navigation of the regulation.

It is important to emphasize that this compendium does not intend to replace the official documents and resources of the European Union (reported in the bibliography of the compendium itself), but proposes itself as a practical tool to navigate the regulatory requirements and understand their practical implications for digital development in Italy.

Cherry on top: the guide is also a virtuous example of a 100% accessible site.

The time to act is now. Companies that will wait until 2025 to start thinking about website accessibility will find themselves not only chasing regulatory compliance but having lost an important opportunity for differentiation and innovation.

The question is no longer "if" to implement accessibility, but "how" to do it strategically to maximize its benefits, using a structured web accessibility guide and verifiable WCAG 2.1 AA checklist.

Contact us to discuss how your organization can transform the regulatory obligation of the EAA into a concrete opportunity for business and innovation. Do you already have a plan for 2025?