European Accessibility Act 2025: Ensure your Cookie Banner is compliant

The European Accessibility Act 2025 (EAA 2025) will soon come into force. Companies in the EU must ensure that their websites or online shops are accessible by the implementation deadline of 27 June 2025. This also applies to the first point of contact, the cookie banner, which must also be accessible for people with disabilities. But how do these accessibility standards differ from the cookie banner requirements already set out by the GDPR? Do companies need to take additional measures?

In this article, we will guide you through all the necessary steps to make your cookie banner EAA compliant and show you how to ensure compliance with the consentmanager CMP.

What is the European Accessibility Act 2025?

The European Accessibility Act, officially known as Directive (EU) 2019/882, is a European Union directive adopted on 27 June 2019 and due to enter into force on 28 June 2025.

Their goal is to create a framework for digital accessibility so that online spaces such as websites and apps are easily accessible and usable for everyone.

The European Accessibility Act focuses on key products and services for people with disabilities and ensures that accessibility standards are consistent across all EU countries.

Here are the categories of restrictions that the EAA highlights:

1. Visual impairments, including blindness
2. Hearing impairments, including deafness
3. Motor impairments
4. Cognitive impairments and learning disorders
5. Sensitivity to light
6. Multiple disabilities

The EAA is part of an initiative to support the EU Strategy on the Rights of Persons with Disabilities 2021-2030.

Who has to comply with the EAA 2025 and how?

From 28 June 2025, products and services covered by the European Accessibility Act must comply with the requirements of the EAA.

Companies should check country-specific accessibility regulations. Additional requirements may apply in some EU Member States.

The European Accessibility Act applies generally to products and services focused on digital technologies . The main sectors mentioned under services in this regulation include, among others:

1. Telephone services
2. Banking services
3. E-commerce
4. Websites, mobile services, electronic tickets and all information sources for air, bus, rail and water transport services
5. E-books
6. Access to Audiovisual Media Services (AVMS)

Any company operating in the EU or providing digital services to customers in the EU will soon have to comply with these new accessibility requirements. Micro-enterprises may have certain exemptions but should still make their services accessible to people with disabilities.

To ensure EAA compliance, it is important to understand the core accessibility principles established for websites and mobile applications. These principles can be found in the official EAA Directive as well as in Directive (EU) 2016/2102 on the accessibility of the websites and mobile applications of public sector bodies.

The four principles of accessibility for websites and mobile apps

An accessible cookie banner means that it complies with the basic principles of perceptibility, usability, comprehensibility and robustness.

What these principles mean for the design and behavior of your cookie banners:

1. Perceivability – Users must be able to see, hear or otherwise perceive the information in the cookie banner. The banner should be presented in such a way that no essential information is obscured or inaccessible.
2. Usability – Users should be able to interact with the cookie banner without any problems. The user interface should allow all required actions without obstacles, such as selecting a setting, accepting or rejecting cookies or navigating through options.
3. Understandability – The language and layout of the cookie banner should be easy to understand. Avoid complex legal jargon. Instead, use simple and direct language to explain options and implications.
4. Robustness – The cookie banner must work properly on different devices and technologies. Whether the user accesses the banner on a mobile phone, tablet or desktop computer, the banner must adapt to different screen sizes and support different technologies.

How should you design your cookie banner according to the EAA guidelines?

There are a few important steps you should take. First, you should adjust the visual and functional aspects of your banner, which you can usually adjust yourself in the design editor of a CMP – more on that in the next section. The second step is a more technical one, but can be done in the consentmanager CMP with just one click.

Let’s first look at the design aspects: As a user of a paid consentmanager CMP package, you have access to a variety of ready-made cookie banner designs as well as extensive customization options. Ultimately, it is your responsibility to design the appearance of your cookie banner so that it is accessible to all users.

These design and behavior requirements are based on the WCAG Quick Success Criteria and Techniques (see WCAG guidelines here):

1. Color contrast – Make sure the text on your cookie banner is easy to read by maintaining a minimum contrast ratio of 4.5:1.
2. Don’t just convey information through color – Accessible design requires additional information that isn’t just conveyed through color. For example, your “Accept” and “Decline” buttons shouldn’t just be green for “Accept” and red for “Decline” without showing the actual text.
3. Keyboard accessibility – The banner should be fully navigable with a keyboard, without the need for a mouse.
4. Clear wording – Use clear, understandable words and convey your content clearly.
5. Adaptive design – Make sure your banner can adapt to different screen sizes, from mobile devices to desktop computers.
6. Alt text – If your banner contains icons or images, provide alt text descriptions for any elements that perform a function or represent a status. This is essential for users who rely on screen readers.
7. Easy opt-out – Ensure users can opt out of cookies in a single step without having to navigate through multiple screens.
8. Links – Follow web conventions by underlining links and, when possible, using colors such as blue to indicate interactivity.

Mistakes that make your cookie banner non-EAA compliant (with examples!)

A cookie banner with a poor accessibility rating can significantly impact the user experience for people with disabilities, not to mention the hefty fines that can follow!

In addition to failing to comply with the above points, here are some common mistakes that can cause your banner to not comply, along with examples:

Error 1: Poor contrast ratio

The minimum contrast ratio of 4.5:1 is not achieved here. Users with visual impairments may find it difficult to read your banner.

Error 2: Text is too small

Small font sizes make it difficult for users to read and interact with the content.

Mistake 3: No immediate opt-out option

If a clear and immediate option to opt out of all cookies is not provided, the banner may be frustrating and inaccessible for users. Users should be given an easy way to refuse the use of cookies.

How to enable EAA compliance in your consentmanager CMP

The second step, a little more technical but quite simple, is to activate the accessibility function in your CMP banner. By activating our “WCAG Compliance” function, our system automatically adds code to your banner that makes it easier for screen readers and other accessibility tools to interpret the content. Enabling WCAG compliance in the consentmanager system activates the following functions, among others:

1. Easier navigation paths for keyboard navigation (e.g. navigating the banner via the tab key instead of the mouse)
2. Better recognition of graphics (e.g. how graphics work is explained)
3. Better assignment of elements to functions (e.g. headings are explicitly marked as such)
4. Better readability of functional elements (e.g. the status of checkbox graphics is made readable)
5. Focus on the current element (e.g. keyboard navigation remains in the cookie banner)

The goal of all these functions is to make it easier for screen readers, browsers and other tools to make the website or the cookie banner easier to use and read, and generally easier to navigate.

Follow these steps:

1. Log in to your consentmanager CMP dashboard.
2. Go to the Designs section.
3. Choose your cookie banner design.
4. Select your CMP.
5. Under “Box Settings” look for the setting “Enable WCAG Compliance” (that stands for “Web Content Accessibility Guidelines”). Simply click “Yes” to enable it.
6. Once selected, your cookie banner will be optimized for EAA 2025 compliance.

Fines for non-compliance with the EAA

Penalties for non-compliance with the European Accessibility Act may vary from one EU Member State to another. In Germany, fines of up to 500,000 euros can be imposed and may even lead to the blocking of services . In addition, any necessary corrections must be made immediately after a complaint is made.

It is important to know that from the entry into force on June 28, 2025, customers will already be able to lodge complaints with national courts or data protection authorities. Fines generally range between €2,000 and €500,000 across the EU, with a maximum fine of €1,000,000 in serious cases. The exact amount of the fine depends on factors such as the severity of the violation and its impact on those affected, and is based on the enforcement policies of each EU country.

Conclusion

By following the steps above, you can achieve EAA compliance. By designing your cookie banner to meet accessibility standards, you will not only avoid potential fines, but also ensure a more inclusive web experience for all users. Thanks to the built-in accessibility feature in the consentmanager CMP, compliance is possible even without much technical know-how!

As the implementation deadline approaches, now is the time to make these changes.

Start here with a free account setup and a 14-day trial of our paid plan.