European Accessibility Act for product designers

The European Accessibility Act has applied since 28 June 2025. For product designers it means that many digital products sold in the EU, such as online shops, banking apps and e-book services, must be accessible. The practical target is WCAG 2.2 level AA, and the cheapest way to reach it is to build it into the design system from the start.

This is a design article, not legal advice. Check the details for your product with a specialist.

What is the European Accessibility Act?

It is an EU law that sets accessibility requirements for a range of products and services. For digital work it covers, among others, e-commerce, consumer banking, e-books, electronic communications and websites and apps for passenger transport. Each member state enforces it under its own procedures and penalties. Microenterprises, with fewer than 10 employees and a turnover or balance sheet of up to 2 million euros, have exemptions.

The technical reference is the European standard EN 301 549, which uses the Web Content Accessibility Guidelines (WCAG).

What is new in WCAG 2.2?

WCAG 2.2 builds on 2.1, so working to 2.2 AA is a safe target. Some of the additions that affect design every day:

• Target size. Interactive targets should be at least 24 by 24 CSS pixels.
• Focus not obscured. A focused element must not be hidden behind sticky headers or banners.
• Dragging movements. Anything you do by dragging needs a simpler alternative.
• Consistent help. Help options appear in the same place across pages.
• Redundant entry. Do not ask users to enter the same information twice.
• Accessible authentication. Logging in must not rely on remembering or solving a puzzle.

How do you build accessibility into the design?

Put it in the design system

Accessibility is cheapest at the component level. Set minimum sizes, focus styles and contrast in the tokens, and every screen inherits them. On this website, chips are 32 pixels tall with a 44 pixel touch area, and the design system page lists the contrast of every text role in both themes.

Check early with agents, then test with people

In my process, AI agents check accessibility and design system consistency on the working prototype before users test it. That catches the mechanical problems, like missing labels and low contrast. People then test what a checker cannot judge: whether the flow makes sense without sight, with a keyboard or with a screen reader.

Design the states

Error messages, focus, loading and empty states are where products fail. Write error text that says what is wrong in plain words, and never rely on colour alone.

A short checklist

1. Contrast of text and interface elements in all themes.
2. Visible focus on every interactive element.
3. Touch and click targets of at least 24 pixels, better 44.
4. Labels for every field, and errors that explain.
5. A logical keyboard order.
6. Alternatives for gestures and dragging.
7. Motion that respects reduced motion settings.

Key takeaways

• The EAA has applied since 28 June 2025 and covers many digital services.
• WCAG 2.2 AA is the sensible design target.
• Put accessibility into tokens and components, not into a final audit.
• Use agents for the mechanical checks and people for the real ones.

See also what else changed in product design.

Sources: European Accessibility Act, Davis Wright Tremaine · What is new in WCAG 2.2, W3C