Do US and UK Companies Need to Comply with the European Accessibility Act?

The European Accessibility Act (EAA) is often filed away as "an EU thing." That is the single most expensive misreading of this law, because the EAA does not follow your company's address. It follows your customers.

If you are a US or UK business offering in-scope digital products or services to consumers in the EU, the EAA applies to you. Enforcement began on 28 June 2025. It is no longer a deadline on the horizon — it is a live regime, and the first cases have already been filed.

This guide explains exactly when the EAA reaches across the border, what it means for your video and audio content specifically, and how the UK's own separate obligations layer on top.

The rule that catches non-EU companies

The EAA — formally Directive (EU) 2019/882 — applies to economic operators placing in-scope products or services on the EU market, regardless of where the company is established.

That phrase does the work. There is no exemption for foreign companies. A US SaaS platform with paying subscribers in Germany, a UK e-commerce brand shipping to Ireland, a Canadian e-learning provider selling courses to students in Spain — all are placing a service on the EU market, and all are in scope.

The test is not where you are. The test is:

  1. Is your product or service on the EAA's covered list?
  2. Are you offering it to consumers in the EU?

If both are yes, you are an economic operator under the EAA.

What's on the covered list

The EAA covers a defined set of products and services. The ones most likely to matter to a US or UK business:

  • E-commerce services — B2C online services provided via websites or apps, covering the full customer journey
  • Services providing access to audiovisual media services — streaming platforms, on-demand catalogues, and the websites and apps that deliver them
  • Consumer banking services
  • E-books and dedicated software
  • Electronic communications services
  • Transport information services — websites, apps, e-tickets, real-time travel information

Note the shape of that list: it is service-led, and most modern services are delivered through a website or an app. That is why the EAA reaches far more companies than a first glance at "accessibility directive" suggests.

One extra step for product manufacturers

If you manufacture in-scope products (rather than only providing services) and you are based outside the EU, you must additionally appoint an EU-based authorised representative to handle compliance tasks on your behalf. Service providers do not carry this specific obligation — but they are still fully bound by the accessibility requirements themselves.

What this actually requires for video and audio

The EAA's functional requirements are built on the POUR principles — content must be perceivable, operable, understandable and robust — the same four principles that underpin WCAG.

Compliance is assessed against the harmonised European standard EN 301 549, which incorporates WCAG 2.1 Level AA in full. Conform to EN 301 549 and you get a presumption of conformity with the EAA under Article 15. (An enforcement authority can still challenge that presumption if your service isn't accessible in practice — the standard is a strong shield, not an absolute one.)

For anyone publishing video or audio, the practical translation is short:

Pre-recorded video needs synchronised captions. Pre-recorded audio needs a transcript or equivalent text alternative.

That is WCAG 1.2.2 (Captions, prerecorded, Level A) and WCAG 1.2.1 (Audio-only and video-only, prerecorded, Level A) doing the heavy lifting. Beyond simply existing, captions need to be:

  • Accurate — a faithful representation of what was actually said
  • Synchronised — properly timed to the speaker
  • Complete — including speaker identification and significant non-speech audio (music, laughter, sound effects) where these matter for comprehension
  • Readable — paced so a viewer can actually finish reading each block before it disappears

That last point is the one most auto-captioning tools quietly fail. A transcript dumped into a subtitle file at 25 characters per second technically "has captions" and is functionally unusable. Accuracy and readability are both part of the requirement, not a nice-to-have.

Timing: what's in scope, and when

The European Accessibility Act was adopted in 2019 and entered into enforcement on 28 June 2025. Content published on or after that date is now in scope, while content published before 28 June 2025 falls under a transitional period and must be made accessible by 28 June 2030. Third-party content that an organisation neither funds, develops nor controls is generally out of scope, as is archived content that has not been updated or edited since 28 June 2025. The first lawsuits related to the Act were filed in France in November 2025, underlining that enforcement is no longer theoretical.

For organisations with large libraries of older video content, the 2030 deadline offers some breathing room, but it is not a blanket exemption. Editing, updating or republishing an older video may make it harder to treat that content as untouched archival material. And while five years may sound like a generous transition period, reviewing, captioning and making an extensive back catalogue accessible can become a significant undertaking when thousands of videos are involved.

Are you exempt? Read this carefully

Three exemptions get cited constantly, and two of them are narrower than people assume.

Microenterprises providing services are exempt from the service accessibility requirements: fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million. Note the and — you need both. Note also that this exemption covers services; microenterprises still face requirements on the product side.

Disproportionate burden (Article 14) is not a blanket opt-out. To rely on it you must carry out a documented assessment against the criteria in Annex VI, notify the relevant authority, retain the records, and reassess at least every five years. And it is unavailable if you have received public or private funding earmarked for accessibility. Regulators have signalled this will be read narrowly.

Fundamental alteration applies only where compliance would change the basic nature of the product or service. Adding captions to a video does not fundamentally alter a video. This argument will not carry a captioning case.

If you are a US or UK company large enough to have meaningful EU revenue, you are almost certainly too large to be a microenterprise — and captioning is too cheap and too well-established to sustain a disproportionate-burden claim. That combination is why the exemptions rarely help the companies that most want them to.

Enforcement is real, and it is fragmented

This is where the EAA differs from a single-regulator regime like GDPR, and where the risk profile gets uncomfortable.

The EAA is a directive, not a regulation. All 27 Member States have transposed it into national law — each with its own enforcement authority, its own procedures, and its own penalties. There is no single EU-wide accessibility regulator to negotiate with.

The consequences of that structure:

  • Penalties vary enormously by country — reported maximums range from around €60,000 in Ireland to roughly €900,000 in Sweden.
  • You can be pursued in multiple jurisdictions simultaneously. A single non-compliant service sold across the EU is exposed in every Member State where it is offered.
  • Fines are not the only instrument. National market surveillance authorities can require corrective action and, ultimately, order a non-compliant service withdrawn from the market. For a company whose EU revenue matters, market withdrawal is a considerably blunter tool than a fine.
  • Consumers and advocacy groups can act. Most Member States allow individuals and disability organisations to bring complaints or legal action directly.

And this is not theoretical. The first EAA lawsuits were filed in France in November 2025. The Netherlands has signalled audits. Enforcement bodies and advocacy groups moved quickly, and they are moving on new content published after June 2025 — content that is in scope with no transitional cover.

UK companies: you have two problems, not one

Brexit did not remove UK companies from this picture. It gave them a second, parallel set of obligations.

Problem one: the EAA still reaches you

The EAA does not apply in the UK. But it applies to UK organisations that offer in-scope digital products or services to consumers in the EU. A UK e-commerce site selling to customers in France, a UK streaming service with subscribers in the Netherlands, a UK software company with EU users — all are placing services on the EU market, and all are in scope. Being outside the EU is not a shield; it is simply where your head office is.

Problem two: the Equality Act 2010 applies at home

Domestically, the Equality Act 2010 requires service providers to make reasonable adjustments so disabled people are not placed at a substantial disadvantage. Three features of that duty deserve attention:

  • It is anticipatory. You are expected to address barriers before a specific person complains — not in response to one.
  • It has no size exemption. Unlike the EAA's microenterprise carve-out, the Equality Act applies to small businesses too.
  • It does not name a technical standard — but courts and regulators consistently reference WCAG 2.1 AA as the benchmark for what a reasonable adjustment looks like.

Captions and transcripts fall squarely within the auxiliary aids the Act contemplates. Failing to provide them, where no alternative is offered, can amount to discrimination. The Equality and Human Rights Commission can investigate and issue notices; individuals can bring claims directly.

Public sector bodies face a harder line still, under the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018, which mandate WCAG conformance outright.

The practical upshot for UK businesses

The two regimes converge on the same technical answer. The EAA points to EN 301 549, which incorporates WCAG 2.1 AA. The Equality Act is benchmarked against WCAG 2.1 AA. Caption your video and transcribe your audio to WCAG 2.1 AA, and you have substantially addressed both.

You do not need two workflows. You need one good one.

US companies: the EAA may bite before the ADA does

For US businesses, the EAA is frequently the stricter and more immediate of the accessibility regimes they face.

The Americans with Disabilities Act (ADA) has driven a long line of web accessibility litigation, and ADA Title II now sets explicit digital requirements for state and local government entities — with WCAG 2.1 AA compliance deadlines landing in April 2026. But for private companies, ADA digital obligations have largely been established through litigation rather than through a codified technical standard with an announced enforcement date.

The EAA is the opposite: a defined standard (EN 301 549), a defined date (28 June 2025, already passed), defined enforcement bodies in each Member State, and defined penalties.

For a US company with EU customers, that inverts the usual instinct. The EU obligation is the clearer, more concrete, and more immediately enforceable one — and it is already live.

The good news is the same as for the UK: the standards converge. WCAG 2.1 AA is the common denominator across the ADA's practical benchmark, EN 301 549, and the UK Equality Act. Build captioning and transcription to that bar once, and you have covered your exposure across all three.

A practical compliance path for video and audio

  1. Scope it. List every place your organisation publishes video or audio that reaches EU consumers — marketing pages, product demos, help centres, webinars, courses, podcasts, social channels tied to a covered service. Internal-only training content is generally out of scope; external-facing content tied to a covered product or service is not.
  2. Split old from new. Anything published on or after 28 June 2025 is in scope now. Everything before it has until June 2030 — but be honest about what you are still actively editing and re-publishing.
  3. Fix the pipeline before the backlog. The volume of new content will outgrow the backlog quickly. If captioning is not built into your publishing workflow, you are adding to the problem faster than you can clear it.
  4. Set a quality bar, not just a checkbox. Accurate, synchronised, complete, readable. An unreadable caption track is a compliance liability wearing the costume of a solution.
  5. Attach transcripts to audio. For podcasts and audio-only content, a text version needs to be available near the player — visible, or reachable via a clear link or button. Many publishers place the link in the RSS feed under the episode description, which surfaces it across Apple, Spotify and other players.
  6. Document what you did. If you ever rely on a disproportionate burden claim, the documented assessment is the requirement — not the claim itself.

How Inwista helps

Inwista turns video and audio into compliant captions and transcripts automatically — and the compliance-relevant parts are not gated behind an enterprise tier.

  • Accurate, synchronised captions. Export SRT or VTT subtitle files for your player or platform, or download video with subtitles burned in for channels that don't support caption files.
  • Readable output, not just accurate output. Our Enhance feature splits over-long blocks, inserts industry-standard gaps, breaks lines at natural pauses, and reduces characters-per-second so viewers can actually finish reading. This is the part most auto-captioning skips — and it is the part that separates a caption track that works from one that merely exists.
  • Speaker identification. Automatically distinguish who is speaking, then name them in the editor — which is exactly what a compliant transcript requires.
  • Transcripts in the formats you need — TXT, DOCX or PDF — ready to publish alongside a podcast or webinar.
  • Data processed in the EU, with AES-256 encryption — on every plan, including the free one. Your compliance tool is itself compliant. For organisations that need formal documentation, a Data Processing Agreement is available on Enterprise.


You can test the whole workflow at no cost: Inwista's free plan lets you run the whole workflow on your own material — upload, transcribe, structure, edit and export. Current limits and plan details are on the pricing page.

Start captioning for free →

Frequently asked questions

Does the EAA apply to my company if we're based in the US? Yes, if you offer in-scope products or services to consumers in the EU. The EAA applies to economic operators placing products or services on the EU market regardless of where they are headquartered.

Does the EAA apply to UK companies after Brexit? Not within the UK. But it does apply to UK companies offering in-scope digital products or services to EU consumers. Separately, the UK Equality Act 2010 imposes its own duty to make reasonable adjustments — including captions and transcripts — with no exemption for small businesses.

We only have a handful of EU customers. Are we exempt? There is no minimum-customer threshold. The exemption is based on your company size (microenterprise: fewer than 10 employees and under €2m turnover/balance sheet), not on how much EU revenue you have.

What happens if we don't comply? Enforcement is by national authorities in each Member State, each with its own penalties — reported maximums range from around €60,000 in Ireland to roughly €900,000 in Sweden. Authorities can also require corrective action or order a service withdrawn from the EU market. Consumers and advocacy groups can bring complaints directly. The first lawsuits were filed in France in November 2025.

Do auto-generated captions satisfy the EAA? Only if they're actually accurate, synchronised, complete and readable. The requirement is about the quality of the result, not the method used to produce it. Automated captioning is entirely legitimate — poor-quality captioning is not, however it was made.

Is our old video content covered? Content published before 28 June 2025 falls in a transitional period and must be made accessible by 28 June 2030. Content published on or after 28 June 2025 is in scope now.


This article is a general guide to how the EAA applies to non-EU businesses. It is not legal advice. Because the EAA is a directive transposed separately by each Member State, obligations and penalties vary by country — consult qualified counsel on your specific situation.


Last updated: July 2026