EAA Enforcement: What We Learned at IAAP Dublin
Applause was in attendance at the latest of the IAAP EU Accessibility events, as accessibility professionals gathered in Dublin to take part in two days of workshops and presentations. This one appeared to be the largest of the hybrid events to date — a testament to the growing effort for accessibility in digital products.
After the previous event in the Czech Republic, we were looking forward to discussing some of the finer points of the latest draft requirements with our peers and hearing about new developments in the accessibility world.
Here are my takeaways from the IAAP EU Accessibility event in Dublin.
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Day 1: Diving into EN 301 549
The opening day featured a workshop for deep diving into the requirements of EN 301 549. The groups reviewed updates from the current draft. The conversation centered on how these updates could be interpreted, tested and passed/failed in terms of conformance.
Web accessibility specialist Detlev Fischer led our group, which held the discussion around:
- 11.5.2.11 List of available actions
- 11.5.2.12 Execution of available actions.
After some lively debates, our group recognized that these two requirements seem to fill a gap in WCAG SC 4.1.2 regarding custom actions in native applications. Custom actions are often either unavailable to assistive technologies or fail to function correctly.
Examples could include custom actions seen on the list view in a mail app. In these cases, assistive technology can have access to multiple actions, such as activate, delete and archive. Testing consists of using assistive technology like a screen reader to determine the availability and execution of the actions. It’s then possible to verify whether it passes or fails based on our understanding of the language in the update.
This discussion raised some interesting questions and necessary follow-ups. For example:
- Should we include other hardware like ATMs that use assistive technology in our tests and discussions?
- Is checking actions with a screen reader enough, or do we need to test with other types of assistive technology?
- What is the specific difference between these tests and the WCAG SC 4.1.2 requirements?
- How should we test this on desktop programs for Windows or macOS?
Ultimately, we came away with a deeper understanding of the requirements. Some task items included updating the testing methodology, verifying programmatic availability and determining pass/fail states.
We’re excited to see the IAAP publish the results, and we look forward to the next update of EN 301 549. A huge thanks to everyone for sharing knowledge with the community.
Day 2: Putting regulation into practice
The hybrid part of the event kicked off with the number of attendees growing to around 200. We attended presentations from a wide range of accessibility experts, company leaders, end-users, monitoring bodies and stakeholders from across the EU and US. Wide-ranging sessions covered topics such as kiosks, mobile apps, legal requirements, end-user experiences and big tech updates.
Chris White, CEO of Vision Ireland, set the tone for the day with a strong emphasis that “the time for talking is over.” He reminded us of the impact that regulations had on the financial services industry. Leadership understood the cost of non-compliance and implemented the regulations accordingly. He called for enforcement of the European Accessibility Act (EAA) to get accessibility heard in boardrooms so that effective change can occur.
One of the highest-attended talks was a panel discussion featuring members of European surveillance authorities. Some takeaways were:
- Engage early. Dónal Rice from Ireland’s ComReg reiterated the need for companies to engage with the surveillance authorities at an early stage. He mentioned that some of the early results of monitoring were discouraging. While the regulators might appear to be quiet, he said monitoring is active and ongoing. By the time the economics operators hear from the surveillance authorities, it might be effectively too late to avoid enforcement.
- Complaints are piling up. Carmen Butler from the Swedish EAA surveillance authority provided data on the active monitoring situation. The authority is currently reviewing 17 e-commerce websites, with more on the way, and will include banking services in 2026. Carmen also provided numbers on complaints received: 110 on services, including 61 on e-services. This helped to focus monitoring efforts.
- Accessibility experts are in short supply. Karol Michalski, Counsellor at the Ministry of Digitalisation in Poland, noted that ecommerce has drawn the biggest attention from regulators. There is a lack of knowledge from some operators, but support is available if they need assistance in complying with the regulations. He also highlighted the need for more accessibility experts. Education and dialogue should be the first port of call, while enforcement is more of a last resort.
- Regulators will lead the way. Regulators are moving toward enforcement actions, noted Inmaculada Placencia Porrero, the main architect of the EAA. She compared the EAA requirements to safety or environmental regulations enforcement. This reinforced Chris White’s earlier comparison with financial regulations, driving home the message that organizations must proactively address accessibility requirements. Expect regulators to begin to apply penalties.
The overarching impression from the panel was that monitoring, data gathering, flagging and enforcement are underway. We all have a part to play by flagging accessibility issues with operators to assist monitoring agencies in enforcing the regulations. The more complaints received, the more likely that a monitoring action and enforcement can take place.
If we were to pick a single word to describe the event, it would be: enthusiasm. Attendee numbers are increasing, people are engaging, standards are being clarified, and enforcement is drawing near. It was another fantastic event from Susanna Laurin and the rest of the IAAP. We look forward to further contributions to the EN 301 549 standard in the future.
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