Make Emails Accessible Under New EU Law - Or Else
Ensure email compliance with the EAA by June 2025. Learn WCAG 2.1 standards, audit tips, and avoid €50,000 fines for non-accessible emails to EU users.
EAA Compliance
By Elke Porter | Westcoast German News | July 1, 2025
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The European Accessibility Act (EAA), effective as of June 28, 2025, marks a significant shift in digital accessibility requirements for businesses interacting with the European Union. This legislation, adopted in 2019 and transposed into national laws by June 2022, mandates that digital services, including emails, be accessible to people with disabilities across all 27 EU member states.
Given the current date, July 2, 2025, the law is now in full force, and businesses must act swiftly to comply. This note provides a comprehensive overview of the EAA, focusing on email compliance, drawing from recent research and official sources to ensure accuracy and depth.
Background and Purpose
The EAA aims to remove barriers created by divergent accessibility rules across EU countries, enhancing the internal market for accessible products and services. It covers a broad range of digital offerings, including computers, operating systems, e-commerce, and electronic communications, which implicitly includes emails as part of digital services.
The law's core objective is to ensure functional accessibility, aligning with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, incorporated into the European standard EN 301 549. This alignment is crucial, as multiple sources, including the European Commission and accessibility experts, confirm WCAG 2.1 as the benchmark for compliance.
Scope and Applicability
Research suggests the EAA applies to any business sending emails to EU residents, regardless of its location. This includes online shops, service businesses, membership sites, SaaS platforms, content creators, and non-profits, covering emails like order confirmations, newsletters, and password resets.
The evidence leans toward businesses with 10 or more employees or an annual turnover exceeding €2 million needing to comply, with a narrow exemption for micro-enterprises (fewer than 10 employees and under €2 million revenue). This threshold ensures most WordPress businesses, for example, fall under the law, as contractors and part-timers count toward employee numbers.Key dates and enforcement milestones, as outlined in recent reports, include:
- Directive adopted: June 27, 2019
- Member-state transposition: June 28, 2022
- Mandatory compliance for new emails: June 28, 2025
- Transitional period ends: June 28, 2030, for legacy emails and templates
This timeline underscores the urgency, with the current date post-deadline for new services, emphasizing immediate action.
Email Accessibility RequirementsTo meet EAA standards, emails must adhere to WCAG 2.1 Level AA, focusing on perceivable, operable, understandable, and robust content. Specific requirements include:
- Structured Content: Emails should have a logical flow with clear headings and sections, aiding screen readers. Most email builders handle this automatically, but custom templates require manual structuring.
- Alt Text for Images: Every image needs descriptive alt text, such as "red leather handbag with gold hardware," with empty alt attributes (alt="") for decorative images to skip screen reader announcements.
- Readable Text: Text must have a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text, ensuring readability for visual impairments. Tools like WebAIM Color Contrast Checker can verify this.
- Language Attribute: Emails must specify the language (e.g., English) for correct screen reader pronunciation, crucial for multilingual businesses.
- Clear Link Text: Links should be descriptive, like "View order status," avoiding vague terms like "Click here," to help screen reader users navigate by links.
- Keyboard Accessibility: Emails must be navigable via keyboard, with visible focus indicators, ensuring usability for those unable to use a mouse.
- Text-Based Information: Critical details, such as sale prices or contact info, must be text, not images, to ensure accessibility for screen readers.
These requirements, supported by sources like Mailgun and Mailjet, ensure emails are inclusive, benefiting not just legal compliance but also user engagement.
Auditing and Compliance
rocessAuditing emails for accessibility is essential, with a structured approach recommended:
Step | Action | Tools/Methods |
|---|---|---|
List All Emails | Document every email type sent, like marketing, transactional, newsletters | Check WP Mail SMTP logs, create spreadsheet |
Use Automated Tools | Identify obvious issues like missing alt text or low contrast | WAVE, Axe DevTools, Accessibility Insights |
Manual Testing | Navigate emails using screen readers or keyboard to simulate user experience | NVDA, JAWS, VoiceOver, keyboard tabbing |
Prioritize Fixes | Focus on high-frequency emails like welcome emails, receipts, password resets | Prioritize based on frequency |
Update Templates | Modify email designs in plugins or marketing platforms to meet standards | Update in email builders, plugins |
Retest | Verify fixes by sending test emails and re-checking with tools | Same tools as step 2 |
Schedule Reviews | Regularly review templates to maintain compliance | Calendar reminders, periodic audits |
This process, detailed in recent accessibility guides, ensures ongoing compliance, with tools like WP Mail SMTP aiding through detailed email logging for audits, a feature highlighted in compliance discussions.
Penalties and Enforcement
Non-compliance with the EAA carries significant risks, with research suggesting fines up to €50,000 per offense and daily penalties of €1,000 for ongoing violations, varying by EU member state. Enforcement is handled at the national level, with potential restrictions on EU market access and legal actions from consumers. Sources like EmailLabs and Level Access confirm these penalties, noting the EAA's enforcement aligns with GDPR's impact, with fines potentially reaching high figures for large companies and even smaller ones, like the €50,000 fine for Marketing Solutions LLC under GDPR for email issues.
Exemptions exist for businesses facing a "disproportionate burden," but this is narrowly defined, requiring proof of undue financial or organizational strain, as per European Commission guidelines.
Tools and Resources
Beyond WP Mail SMTP, businesses can leverage tools like WAVE, Axe DevTools, and screen readers for testing. Email service providers often include built-in accessibility features, and resources like the W3C offer training courses. For updates, the European Commission's EAA portal and X accounts like@EURLexprovide official guidance, with recent posts emphasizing compliance urgency post-June 28, 2025.
Broader Implications
Accessibility isn't just legal; it's strategic. By complying, businesses tap into a market of millions with disabilities, enhancing brand reputation and user experience. The EAA aligns with global trends, with the US and Canada developing similar rules, future-proofing businesses for inclusivity. Recent X posts, like@euroblind's statement, welcome the EAA but note limited coverage, highlighting ongoing debates on scope, yet the consensus leans toward broad application, especially for emails.
This comprehensive approach ensures businesses are equipped to meet EAA requirements, balancing legal obligations with ethical and market opportunities, as of July 2, 2025.
TAGS: #EAA Compliance #Email Accessibility #Digital Inclusion #WCAG21 #Accessible Emails #EU Accessibility #Westcoast German News #Elke Porter
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