Since June 28, 2025, the European Accessibility Act, EAA is enforced in all EU countries, and in Germany as the BFSG (“Barrierefreiheitsstärkungsgesetz”). What might sound as a bureaucratic guideline for large companies, actually affects everyone who offers a digital product, app, website or online service in the EU – and founders, as well as startups, are included. As a note: Products and digital services which were offered before June 28, 2025, have a transition deadline until June 28, 2030 to include the EAA requirements. Products and services after this date need to comply with the EAA from the beginning.
What’s behind the EAA?
Websites, mobile apps, e-commerce platforms, streaming services, digital communication tools and even e-books have to comply with clear requirements on accessibility and ease of use. The EAA aims to create accessibility standards in the entire EU inner market without creating different regulations for all EU countries. In other words: an app or software developed in Germany has the same accessibility requirements as a developed application in Spain or Austria. At the same time, it means that apps or software marketed for one or more European countries need to comply with the EAA regulations.
What applies for startups?
The EAA applies for startups which have at least ten full-time employees or have yearly annual sales of more than 2 Mio. Teams with less than 10 employees and below 2 Mio. Euro annual sales are considered small companies, and are thus excluded from the EAA for services, such as support pages or community platforms. Nevertheless, products such as apps, games or a digital tool are not excluded from the EAA guidelines, whereas the requirement differences among them are not clearly defined yet.
The POUR Model
The core principles of th4e EAA can be easily remembered employing the POUR Model:
- Perceivable
- Operable
- Understandable
- Robust
In practical terms, this means clear contrast, keyboard navigation, screen reader compatibility, video subtitles, no text as image, clear error notifications and alternative text (alt-text) for visual contents.
EAA Examples in Apps
EAA Accessibility requirements can already be found in different applications. Here, we show you some examples.
- Spotify, the renowned music streaming app, has been gradually optimized for screen reader compatibility: All buttons and icons are with descriptive labels, so visually impaired users can navigate the app completely via VoiceOver (iOS) or TalkBack (Android). This is not special feature, but a minimal requirement from the EAA already present in Spotify.
- Duolingo has a clear example on error feedback: when an answer is wrong, the app communicates it not only with a red color, but also with text, icons and vibration. It’s this multi-canal-feedback – and not only the color - one of the most missed EAA features in startup products, and Duolingo addresses it successfully.
- Instagram, as a last example, shows how small, but specific accessibility features can create a big inclusive experience: Since 2018, users are able to enter an alternative text (so called “alt-text”) to their image posts. As well, the app can generate automatic picture descriptions with AI, which can be read by a screen reader. Other features are automatic captions for videos and reels, as well as VoiceOver (iOS) and TalkBack (Android) support. For startups, it’s important to note the following: alt-text, automatic captions and screen reader labels are not large technical implementations, require low development efforts, and cover a large area of the EAA basic requirements. They also expand the usage reach for new users with visual or hearing impairments.
What about tabletop games?
Analog products such as tabletop games are not considered under the EAA, since this regulation is for digital and interactive products. But, if a tabletop startup launches a game with a side app, digital shop or community platform, then the EAA components need to be complied for those digital products. This highlights an important design philosophy: accessibility needs to be considered not as a digital requirements, but as part of an overall product experience – even if there is no legal accessibility guidelines for analog products yet.
Checklist: What can startups do now?
- Check if EAA applies: more than 10 employees or annual sales over 2 Mio. Euro? Then consider the BFSG (for Germany)
- Perform an own "Accessibility Audit”: test existing website, app or product with the WCAG 2.1 AA (Web Content Accessibility Guidelines) – free tools such as WAVE or AXE help for this.
- Create and publish an Accessibility Statement: This is an explicit requirement under the EAA
- Integrate accessibility in the design system: contrast, labels, keyboard navigation and alternative texts as standards, not as exceptions
- Keep an eye on the company development: if the young startup scales to a bigger company in the future, should start implementing EAA into its products.
