Digital accessibility can be difficult to stay ahead of. The laws have been evolving and now the European Union (EU) has entered the arena with their own version of the Americans with Disabilities Act (ADA).

If your business sells products, services, and/or software to European consumers, this law will apply to you.

The good news: 

The bad news:

Keep reading for a breakdown of how the Act works and what your business needs to prepare.

What is the European Accessibility Act? 

In 2019, the EU formally adopted the European Accessibility Act (EAA). The primary goal is to create a common set of accessibility guidelines for EU member states and unify the diverging accessibility requirements in member countries. The EU member states had two years to translate the act into their national laws and four years to apply them. The deadline of June 28, 2025 is now looming.

The EAA covers a wide array of products and services, but for those that own and maintain digital platforms, the most applicable items are:

Who Needs to Comply?

The EAA requires that all products and services sold within the EU be accessible to people with disabilities. The EAA applies directly to public sector bodies, ensuring that government services are accessible. But it goes further as well. In short, private organizations that regularly conduct business with or provide services to public-facing government sites should also comply.

Examples of American-based businesses that would need to comply:

There are limited exemptions. Micro-enterprises are exempt, and they are defined as small service providers with fewer than 10 employees and/or less than €2 million in annual turnover or annual balance sheet total.

What is required?

Information about the service

Service providers are required to explain how a service meets digital accessibility requirements. We recommend providing an accessibility statement that outlines the organization’s ongoing commitment to accessibility. It should include:

Compatibility and assistive technologies 

Service providers must ensure compatibility with various assistive technologies that individuals with disabilities might use. This includes screen readers, alternative input devices, keyboard-only navigation, and other tools. This is no different than ADA compliance in the United States.

Accessibility of digital platforms

Websites, online applications, and mobile device-based services must be accessible. These platforms should be designed and developed in a way that makes them perceivable, operable, understandable, and robust (POUR) for users with disabilities. Again, this is no different than ADA compliance in the United States.

Accessible support services

Communication channels for support services related to the provided services must also be accessible. This includes help desks, customer support, training materials, self-serve complaint and problem reporting, user journey flows, and other resources. Individuals with disabilities should be able to seek accessible assistance and information.

What are the metrics for compliance?

The EAA is a directive, not a standard, which means it does not promote a specific accessibility standard. Each member country can define its regulations for standards and conformance and define their penalties for non-compliance. Each country in which your service is determined to be non-compliant can apply a fine, which means that one infraction could accumulate fines from multiple countries. 

Just like the Americans with Disabilities Act, most EU member states are implementing Web Content Accessibility Guidelines 2.1 AA as their standard, which is great news for organizations that already invest in accessibility conformance.

If a member country chooses to use the stricter EN 301 549, which still uses WCAG as its baseline, there are additional standards for PDF documents, the use of biometrics, and technology like kiosks and payment terminals. These standards go beyond the current guidelines for business in the United States.

Accessibility overlays (3rd Party Widgets)

It should be noted that the EAA specifically recommends against accessibility overlay products and services — a third-party service that promises to make a website accessible without any additional work. Oomph has said for a long time that plug-ins will not fix your accessibility problem, and the EAA agrees, stating:

“Claims that a website can be made fully compliant without manual intervention are not realistic, since no automated tool can cover all the WCAG 2.1 level A and AA criteria. It is even less realistic to expect to detect automatically the additional EN 301549 criteria.”

The goals for your business

North American organizations that implemented processes to address accessibility conformance are well-positioned to comply with the EAA by June 28, 2025. In most cases, those organizations will have to do very little to comply. 

If your organization has waited to take accessibility seriously, the EAA is yet another reason to pursue conformance. The deadline is real, the fines could be significant, and the clock is ticking.

Need a consultation?

Oomph advises clients on accessibility conformance and best practices from health and wellness to higher education and government. If you have questions about how your business should prepare to comply, please reach out to our team of experts.

Additional Reading

Deque is a fantastic resource for well-researched and plain English articles about accessibility: European Accessibility Act (EAA): Top 20 Key Questions Answered. We suggest starting with that article and then exploring related articles for more.

THE CHALLENGE

The Challenge

Fidelity Investments manages one of the most extensive content ecosystems in financial services, producing a constant stream of insights, trend analyses, and investment strategies. However, its design team faced a critical challenge — their design system felt restrictive rather than empowering.

While Fidelity’s internal team was updating brand standards, they struggled to apply them strategically within their digital experience. The design system supported incremental changes but lacked the flexibility to evolve with new ways of presenting content. Designers felt stuck in familiar patterns, limiting opportunities to rethink layouts, improve content discovery, and enhance engagement.

To break free from these constraints, Fidelity brought in Oomph to infuse fresh thinking, introduce new editorial layout strategies, and expand the capabilities of their design system.

OUR APPROACH

Oomph worked inside Fidelity’s existing design system, bringing an outside perspective to challenge old assumptions and push the boundaries of their brand standards.

Reimagining Editorial Storytelling

With Fidelity generating massive amounts of financial content, our team explored new ways to organize and present information. We conducted a cohort analysis of leading editorial experiences across industries, studying how different platforms arranged related content, structured topic-based storytelling, and guided users through complex financial narratives.

We then worked within Fidelity’s Figma files, prototyping new layout variations that:

  • Allowed for dynamic grouping of content by topic, trend, or investor interest.
  • Introduced larger, more structured content modules to replace scattered individual components.
  • Created scalable patterns that could adapt to different content types and investment themes.

Expanding the Design System Beyond Incremental Updates

While Fidelity’s internal team was busy refining brand alignment, we helped them move beyond small tweaks to explore new possibilities. Our role was to:

  • Push the boundaries of what was possible within their existing system.
  • Experiment with layouts that weren’t explicitly outlined in the brand standards.
  • Provide fresh external perspectives on how the brand could evolve digitally.

Collaboration & Seamless Handoff

We worked side by side with Fidelity’s internal team, ensuring every new layout and component fit within their development and governance structure. While Oomph focused on strategy and design, Fidelity’s team took the lead on integrating new components into their system and coding them into production.

Our handoff process included:

  • Detailed design annotations and functionality breakdowns.
  • Guidance on flexibility—such as how components could adapt to different use cases.
  • Clear expectations for future scalability and content governance.

By the end of the engagement, Fidelity had not only expanded their design system but also re-energized their creative thinking.

THE RESULTS

A More Flexible, Scalable Design System

Oomph helped Fidelity’s design team break free from rigid design patterns and accelerate innovation by delivering:

  • A reimagined editorial content strategy that improves engagement and storytelling.
  • Expanded design system components that allow for more dynamic content grouping.
  • A faster, more creative design workflow that helps Fidelity scale design updates with confidence.

By combining fresh creativity with structured execution, Fidelity was able to move forward with clarity, confidence, and a more powerful digital experience.

Helping Enterprises Scale Design Without Sacrificing Innovation

For large enterprises, design systems should accelerate progress—not slow it down. If your team is struggling with applying brand standards, creating scalable content models, or evolving your digital experience, let’s talk.