28 June 2025 · transitional arrangements · what happens if you are late
The deadline has passed. Here is what that actually means for you.
Most pages about the European Accessibility Act were written before it applied and still talk about preparing. The date is behind us, which changes the question from when to what now: what the transitional provisions really cover, what an authority does when a complaint arrives about a site that was never tested, and what position you can reach in the next five business days if you start today.
Cover from day one during the seven-day trial.
The dates, precisely
Four dates matter, and most of the confusion online comes from mixing them up.
| Date | What it means | Who it affects |
|---|---|---|
| 28 June 2025 | Requirements apply to products placed on the market and services provided | Everyone in scope |
| 28 June 2030 | End of the transitional period for service contracts concluded before June 2025 and continued unchanged | A narrow set of pre-existing contracts |
| End of economic life, up to 20 years | Self-service terminals lawfully in use before June 2025 may continue | Operators of kiosks and terminals |
| 31 December 2026 | Ontario compliance report | Organisations with 20+ employees in Ontario |
The second row is where most of the confusion lives. It covers contracts, not websites: a service agreement signed in 2024 and running unchanged may benefit, while the shop you update every week and sell from every day does not.
What being late actually looks like
The fear is usually worse than the reality, and knowing the mechanics removes most of the panic.
There is no European inspectorate opening websites at random. Enforcement is reactive: a consumer meets a barrier, cannot get a useful answer through the feedback route, and writes to a national body. What happens next is a letter asking for three things — the statement, the evidence behind it, and the response given to the user.
An organisation that started late but started has an answer: here is the statement published two weeks ago, here is the audit it was written from, here is the plan and here is what we told the person who wrote to us. That is a manageable file, and in most member states it ends with a deadline to finish the work.
An organisation that has nothing has to produce everything under a clock, usually while also answering the customer who complained. The gap between the two is not the law; it is preparation, and it is five business days wide.
What to do this week if you have done nothing
- Scan the site. Two minutes, no card. It tells you whether you have a structural problem or a tidy one.
- Order the audit. Ten minutes of scope questions; testing starts the same day.
- Publish the statement as soon as it is signed. Listing open barriers is lawful and expected. Silence is not.
- Open the feedback route. An address that reaches a named person, with a reply time you can meet.
- Fix the blocking items first. There are usually two to six, and they are the ones that stop a purchase.
- Keep the monthly re-test running. So the document and the site stay in step from here on.
Six steps, of which four are yours and two are ours. The full version of the process is on the checklist page, and what the finished document looks like is on the example page.
Two deadlines, one piece of work
A practical note for companies operating on both sides of the Atlantic, where the calendars do not line up but the work does.
Companies that sell in Europe and employ people in Ontario are living with both clocks: one that has already struck and one arriving on 31 December 2026. The documents are different — a public statement written to Annex V, and a provincial compliance record supporting a self-declaration — but the testing underneath them is the same, and paying twice for it is a common and avoidable waste.
The Ontario side is set out on the requirements page and the reporting duty on the AODA 2026 page. The global plan covers both plus the United Kingdom with one renewal date.
The myths worth discarding
Each of these is repeated in good faith, often by someone competent, and each one delays the only thing that helps.
“There is a grace period until 2030.” There is a transitional arrangement for pre-existing service contracts. It is not a general extension and it does not cover a live consumer website.
“Nobody is enforcing it yet.” Enforcement is complaint-driven, which means it is invisible until it is personal. The absence of news is not the absence of risk.
“We are too small.” The microenterprise relief covers services below specific thresholds. Check the numbers rather than the feeling, because most shops discover they are above them.
“We will handle it in the redesign.” Redesigns slip. The consumers using the current version are using it today, and the statement describes what is live.
“Our agency said we are fine.” Ask what was tested and on what date. If the answer is a tool and a score, that is a starting point, not an assessment.
Where you can be by the end of next week
The gap between having nothing and having a defensible file is smaller than most people assume, and it is measured in days rather than quarters.
Scan today, order today, testing runs, and within five business days you have a signed statement online, a findings report in your developers' hands, a working feedback channel and a plan with dates. The open barriers are still open, and that is fine: the document says so, the alternatives are named, and the work is scheduled.
That position is not compliance in the sense of perfection, and no honest supplier will tell you otherwise. It is the position that answers a letter, satisfies a buyer and, more importantly, gets the barriers removed in the order that matters to the people meeting them.
Why so many companies missed it
Four reasons come up again and again in the first conversation with a company that has just discovered the obligation.
It is worth understanding, because the reasons are structural rather than careless, and knowing them tells you where the next gap will appear.
No letter arrived. Unlike tax or data protection, nothing landed on anyone's desk in 2024 announcing the date. Companies that heard about it heard from a vendor, and vendor emails are filtered as marketing.
It sat between departments. Legal saw a technical matter, engineering saw a legal one, marketing owned the website. Obligations that belong to nobody survive a long time.
The word suggested the wrong thing. Accessibility reads as a design preference, not as a market access condition. The Directive treats it as the latter: a service that does not meet the requirements should not be offered to consumers in the Union.
The deadline was quiet. There was no switch-off, no blocked payment, no error page. Nothing happened on 29 June 2025 to anybody, which is exactly why the exposure accumulates invisibly until the first complaint.
If a complaint has already arrived
Answer it before anything else, and answer it as a person rather than as a legal department. Acknowledge what happened, say what the customer can do right now to complete the task, and give a date by which the barrier will be gone. Then start the audit, because the second letter, if it comes, will ask what you did after the first one.
Two mistakes are common at this point and both are expensive. Denying the barrier without testing it, which is easily disproved and converts a technical issue into a question of good faith. And going silent while the organisation decides internally who owns the problem, which reads from the outside as indifference and is the most common reason a complaint escalates to an authority rather than ending in an email.
What changes as national practice matures
The first period after a directive applies is always uneven: member states stand up their enforcement bodies at different speeds, guidance appears in one country before another, and the first cases set the tone. That unevenness is temporary. What tends to follow is a slow rise in complaint volume, driven by disability organisations that now have a legal reference to point at, and a hardening of procurement language, because public buyers move faster than regulators.
For a company selling in several member states the practical consequence is to stop reasoning country by country. One truthful statement, in the languages you sell in, backed by one audit that is kept current, answers whichever authority writes first. Trying to be compliant only where enforcement is visible is more work and less defensible than simply being compliant.
Deadline questions
What is the EAA deadline?
28 June 2025 is the date from which the requirements apply to products placed on the market and services provided to consumers.
So the deadline has passed?
Yes. Anything published after that date about a future deadline for the main obligations is describing a transitional arrangement, not a grace period.
What transitional arrangements exist?
Service contracts concluded before that date may continue under conditions until 28 June 2030, and self-service terminals lawfully in use may be used until the end of their economic life, up to 20 years.
Does that mean I have until 2030?
Only for a contract that already existed and continues unchanged. It does not cover a website you keep publishing to new consumers.
Am I too late?
No. Enforcement is complaint-driven and progressive. What matters is the position you are in when someone asks, not the day you started.
What happens if an authority writes now?
They ask for the statement, the evidence behind it and your reply to the user who complained. A dated audit answers all three.
Is there a first-offence grace?
There is no formal amnesty, but authorities generally start with a request to act. Being able to show work in progress is the difference.
What is the AODA deadline?
31 December 2026, for the Ontario compliance report by organisations with 20 or more employees in the province.
Are the two deadlines related?
No. Different laws, different jurisdictions, different documents. Only the testing behind them overlaps.
How fast can I get a statement?
Five business days from a complete form, with cover from day one during the seven-day trial.
What should I publish immediately?
An honest statement listing the open barriers with alternatives. That is both lawful and better than silence.
Can I be fined retroactively?
Penalties follow national law and usually attach to failure to act after being told, not to the calendar.
Does the microenterprise exemption still apply?
Yes, for services, on the staff and turnover thresholds. It does not apply to products.
Who enforces this?
Market surveillance authorities for products and designated enforcement bodies for services, in each member state.
What if my site is mid-redesign?
Test what is live today and publish the statement for it. A redesign is not a defence for the version consumers are using now.
What does it cost?
690 € a year for the EU, 1,290 € for three domains and six languages, 1,990 € including the UK and Canada.
Do you do the fixes?
No. We test, document and sign; your team fixes from the prioritised list.
Where do I start today?
Run the free scan, then order. Testing starts the same day.