Now we’re past the EAA Deadline – What should you do now?

The EAA’s June 2025 deadline wasn’t the end of the accessibility work organisations need to do. It wasn’t even the beginning of that end. But it was maybe the end of the beginning for many companies.

If you’re a company who hasn’t reached the compliance level, what can you do to avoid panicking and encourage the official Monitoring Organisations from each EU Member State (or disability organisations using the same legislation to bring lawsuits, like is happening already in France) to look at other companies to fine before they focus their fines on you?

If you’re a company who’ve reached the necessary level of compliance, what should you do now to ensure you remain compliant, and actually win more business because of the accessibility you’ve achieved?

In this webinar we guided companies through the steps they need to put in place to minimise their risks and maximise their opportunities from the EAA.

September 2025 Webinar - The EAA Deadline has passed, so what now?
September 2025 Webinar - The EAA Deadline has passed, so what now?

PETE: We have Jonathan Hassell who is the CEO of this company, written several books on digital accessibility. Liam Hassell is also part of the team. He’s a consultant. He spent a lot of time researching the European Accessibility Act, thinking about what it means in different countries. And between the two of them, they’re going to share some insights. The EAA is now live, but we also know there’s a lot of people who’ve got a long way to go. So, over to you, Jonathan.

JONATHAN: Thanks, Pete. Just a little bit of me and then I’m going to hand to Liam. Good afternoon, everyone. 3 months after the deadline that everyone was fixated on… June 28th 2025 was the deadline for accessibility to happen, in all sorts of different types of organizations, in different ways all over Europe.

So 3 months on – what do you need to know? Well, we’re looking at this from four different perspectives.

Firstly, we’re going to give you our take on what’s happened since the deadline, and then we’ve got if you like two different scenarios that we think organizations may split themselves into. One is that you know you’re not compliant to the level that you want to be yet and you’re trying to work out what to do with that situation. The second one being that if you have made it to the level of compliance that you feel comfortable with there is so much more to do and fundamentally it’s not time for you to rest on your laurels, it’s time for you to win from all of the great work that you’ve done to make things accessible.

And then the last thing we’re going to look at is there are a few things that we’ve been working on with our clients that we rarely hear anybody else talking about that are fundamental to the EAA but don’t seem to be part of the conversations that we see on LinkedIn and that sort of thing. So we’re going to be giving a lot more of this. 

You’re going to get this from a very strategic point of view. You’re also going to get this from a point of view that hopefully is very supportive of where you are in your journey in the company that you are working for. And a really positive way of actually taking this because actually fundamentally this is all about making sure that more people can use the sorts of things that you are creating and that’s always a good thing.

So, I want to hand over for the first couple of sessions to Liam, and he’s going to take us through what’s happened since the EAA deadline. Liam, if you want to, take the screen, and take it away.

LIAM: Perfect. Hoping that’s coming across now. Yeah, all good. Brilliant. So thanks Jonathan. So, yeah, let’s look a little bit about what has happened since the EAA deadline. And what I want to do is I do want to start off with just a quick reminder. Very aware that a lot of you on this call will already know what the EAA is. But also aware that we have new people to these webinars every month. And so just want to do a quick recap for them. So what is the EAA? So essentially the EAA or the European Accessibility Act is accessibility legislation that has been adopted across the EU. Each of the EU member states have transposed it international law.

There are some differences between the different countries but more or less most of the countries have a very similar sort of approach to the legislation. There was a deadline to meet the initial requirements for the websites and apps and that was on June 28th. So you’ll obviously notice that is now gone which means that the EAA is live as it were. And it’s really important to know that it’s not just for those that are located in the EU member states, but those selling to them. So whether you’re in the UK, the US, Australia, China, wherever you might be, if you’re selling into those EU member states, this is something you’re going to have to take into account. And essentially, it’s about making sure that newly marketed products and services are accessible. Initially WCAG 2.1’s been what everyone’s been saying, yep, that’s probably a good way to start. But recently we’ve been seeing that WCAG 2.2 is a good basis to work towards.

The EAA is very consumer focused and as such there were some specific industries that they’ve really focused on. So the likes of e-commerce, banking services, services for travel, streaming, ebooks, that sort of stuff. And there is another section surrounding hardware. Now this is something where there’s a little bit longer to meet the sort of deadline for this in 2030. But you’ve got things like ATMs, ticketing and checking machines. And essentially the entire purpose of the European Accessibility Act was noticing that some countries in EU member states had accessibility laws, some didn’t and those that did were different from each other. So this was a way of trying to make it consistent across all of those EU member states.

So what’s happened since? Well, one of the first things that is useful to talk about is the monitoring bodies for all of these countries have now been established. And this means that the process has now been established and as such the ability for these countries to take actions, penalties, it’s no longer theoretical. Before the deadline, there was still some question about, you know, who some of these bodies might be. And so, you know, people were like, “Yep, we know the legislation says that there might be a fine or some legal action, but you’ve not told us who it might be. We now know.” Now, each of these countries is going to have a different approach and you’ll obviously see that that’s just Spain, France, and Italy there, but all of them will have these.

And so what we want to do is just quickly take you through an example with the Netherlands in terms of what they’re doing. So the Netherlands have taken an approach of looking at the different industries that they’ve got and then each of these industries have a little different monitoring body. So e-commerce, financial services, e-books just as an example. Now more or less they’re all working towards the same thing but we’re just going to talk through the e-commerce aspect so you can see what they’re asking for. So first things first, companies must conform with the four basic principles of accessibility. So that basically means that things need to be perceivable, operable, understandable, robust. That’s what the POR acronym stands for. They recommend using WCAG 2.2 as a way to test and demonstrate conformance. And that’s a really interesting point because what that is is it diverges a little bit from what the legislation talks about.

At the moment the legislation when it looks at requirements talks about things like harmonized standards like EN301549 which at the moment is still looking towards 2.1 although it’s sort of the worst kept secret that everyone knows it will be moving to 2.2. So just interesting to see that they’ve decided to sort of go forward with this. You need to have an accessibility statement. You need to talk about what your service does, how it works with assistive tech, how it conforms to the EAA and how it doesn’t. And you really need to talk about your customer service support as well and making sure that that is done in an accessible way. And towards the end, Jonathan’s going to talk a little bit more about that. For the monitoring body, you need to indicate if you have components that aren’t accessible and the impact that it has to the consumer. I think they talk about things in terms of critical, serious, sort of moderate, and minor issues. And one of the other things you need to do is actually create a plan for how you’ll become accessible. It’s not just okay to sort of just test and say, “Yeah, we know we’re not good and we’re going to leave it there.” These guys want to know actually how are you going to get to the level that they want. But Jonathan, I’m just going to come to you for a second because you just wanted to share a couple of points on actually the way that they’re thinking of reporting these particular issues.

JONATHAN: Yeah. So I mean there is a history in Europe about different countries being fierce or kind of not fierce about how they kind of monitor these things. You know quite a little while ago Norway started literally penalizing companies that weren’t accessible in various different areas per day until they got there. So a lot of the things about this particular sort of way of doing things in Holland is quite interesting because this to me feels quite fierce. It feels like the monitoring body actually wants to for want of a better word intrude on the way that organizations are creating things and for them to be reporting in a much more active way.

I don’t know personally whether or not this is actually something which is sustainable and enforcable. So it will be really interesting to see how these things come through. But my gut feel is that the interesting thing here is that it’s not just a one shot deal. It’s not are you okay at the start. It’s actually are you okay all the way through. And that I’m a little dubious of in terms of how often the reporting relationship between the monitoring body and the companies that are being monitored will happen. So we’ll have to see how this kind of comes together. But that’s quite a strong position from Holland and three different monitoring bodies have quite a lot of resources between them I would suggest to try and do their monitoring well. So we’ll wait and see. Back to you Liam.

LIAM: Thanks Jonathan. So what are some of the other things that’s happened? Well one of the things is that in France the lawsuits are already coming. And it’s interesting that it’s coming from a specific group, which I’ll get to in a second. So, just to give you an overview of what this legal action is, essentially on July the 7th, just 9 days after the EAA was enforced, four different retailers were written to by sort of various associations of visually impaired individuals to give formal notice of an intent to raise legal action. They basically gave these organizations until the 1st of September, which you’ll notice has also passed, to ensure that they are compliant with the EAA. That deadline is gone. They are not compliant. The legal action is going to be raised. Now, it’s important to note that this wasn’t an individual or it wasn’t even a monitoring body, but instead it was a group of visually impaired individuals who were established to determine how accessible the companies were.

Now what does this situation mean for you? Well, the first is that the risk is real. It took only 9 days for this notice of possible action to be brought. That means the hypothetical has now gone. We are into the reality of this before the legislation was brought in before the deadline hit. You know people were a bit unsure about whether or not this would actually happen. Well, it has. And it’s also happened in one of the countries that a year ago or so we mentioned might be one of the greatest risks which is France. Also it means that you shouldn’t just think you need to think broadly about who might raise this action. You know it’s just it’s not just an individual but also it could be disability groups who could become strong plaintiffs behind these as organizations or groups who want to promote this and help organizations move further by bringing this.

What you need to do is really aim to be accessible as possible. And if you can’t reach it, make sure that you’ve got a plan on how you’re going to get there. And ideally, this should be published. And we’ll talk a little bit more about the plan in a moment. But the other thing I just wanted to say is whilst we’re talking about accessibility and legislation, let’s always remember who we are doing accessibility for, and that’s the community, the people that need it. So go out into the community, talk to your users, do user research, do user testing, you know, communicate with them, invest in them to gain a little bit of goodwill and maybe even buy you some time where these organizations, these groups might go, you know what, that organization, they are really trying. Let’s avoid, you know, any sort of legal ease or legal action with them because we don’t want to squander the great work that they’re doing. Let’s give them the time to live up to what they’re trying to do.

And so one of the things to note though is that whilst these lawsuits are coming, please don’t blindly panic. We really want you to assess your risk. You know, we don’t want to fearmonger in this. What we want to do is give you measured approaches that you can take a strategic look at risk. So some advocates are essentially communicating that if you have action brought against you in one country because of the EU cooperation systems existing there’s a possibility you can be fined across 27 uh other EU member states. Now whilst technically possible we think probably a little bit unlikely and really the reason behind this is that some countries are more mature in action than others. you know, the likes of France, the likes of Italy, you know, they’ve had accessibility legislation for a long time, so they aren’t new to this. They have their processes established, but other countries could be very new to this. And so that financial penalty might not come as quickly as some of the others.

So, what’s best is to calmly assess the risk and the different fines in different countries. Coming up with a strategy to cover all the countries you sell into. And you might be sat there, you might be sort of screaming through the screen at me going, “Liam, that all makes complete sense, but we just don’t have the resource to even cover all these countries.” So, have you mapped out the ones you operate in and the associated risk? Find the ones that you feel are of greatest risk to you and prioritize addressing them first, because there are countries that might be the biggest risk. You know, from a French perspective, they’ve got a maximum €250,000 euro fine. And recently, you know, they’re the most recent to have this legal action brought. Now, that action wouldn’t have been brought if those plaintiffs didn’t think that their system was set up in a way that would allow them to do this. So, France might be a big risk for you. Spain could be a risk as well. You know, they’ve got quite a high sort of fine that they could impose. And actually in 2024 there was an organization that was fined for making their website, for not making their website accessible.

So Spain recently having had problems there. Whilst Italy don’t have any public stories, they do have a fine of up to 5% of your turnover which could be a big amount. And actually they’ve had the stanker law for a long time before EAA. So they’re already used to accessibility as a legislative piece. And then the Netherlands, as we’ve mentioned, I mean, they go up to a 10% fine for turnover, which could be a significant amount. And they have monitoring bodies that have already released their monitoring mechanisms. And so they are ready for this process going forward. But it’s important that you look beyond just the countries and also reflect on what are we selling? you know, is there something about our website or app which might make it a bit more risky, especially to some of these monitoring bodies? If you’ve got something, you know, a website or an app that’s in the public space, it’s easily found. Something in retail or e-commerce, you might naturally be at a greater risk than something that is protected, something like online banking or a subscription service. you know, if I’m a monitoring body, it’s much easier for me to go and, you know, audit Amazon, you know, based on what I can see there than it is to go behind a banking organization into someone’s protected account where you get all of those features. So, where do you land on that spectrum?

Also consider the size of your company and your importance to the market as well. whilst it wasn’t the monitoring bodies that brought it, the French lawsuit does show that it was four of the biggest retailers in France. And so monitoring bodies might take a similar approach. They might go, “Okay, we’re going to start off with the organizations that can have the greatest impact or influence by making something accessible.” And so how big you are might again impact your risk. So think about these things when you’re considering where you land in that risk scenario. So that’s sort of what’s happened since the EAA’s gone live and it’s only been a few months. There’s already been a lot.

So as Jonathan says, we’re going to talk through a couple of scenarios. The first being if you aren’t there yet, please don’t panic. I don’t know if you feel like you’ve got this lion, you know, you’re one of these gazelles and you’ve got this lion on your back. But what we want to do is actually say you don’t need to panic. There’s a few things that you can do. The first off is know you’re not alone. Please don’t think you’re the only ones out there who are not there yet. You know, we looked at some of Silktide’s indexes to really look at different automated assessments for different industries. And what we found is that five out of 24 European insurance companies had a score of 70% or plus. Looking at financial institutions, it was only 10 out of 43. And really important to note that 70% is still not compliance. You know this is 70% of an automated assessment not a manual audit. So if even the organizations that maybe have more resources than you are further ahead you’re not alone in thinking that you’re just an organization that doesn’t meet compliance yet.

Our next step is and we’re going to use this analogy a little bit going through of the lion and the gazelle a little bit is first off we want to make sure that the lion doesn’t see you as prey. And the way that you can do that is maximizing your score against the requirements for reporting with regards to the EAA. And one of the key ways you can do this is through creating a accessibility statement or a report. You know, you want to talk about a general description of the service, the information to understand the service, you know, how you meet the legislation and you know, how you don’t, but also how are you going to monitor an audit going forward? And whilst it doesn’t explicitly state it, we would say put something in around timelines updating every year because if you have that report, if you have that statement to a monitoring body to a different organization, they might look at you and go, “Okay, well, these guys are not as easily targetable. They’ve already tested. They already know where they’re, you know, not as good and they’ve already made that and communicated that. So they’re maybe not as big of a risk.” And though, you know, if we take that lion perspective, they might not see you as that easy target. And the next thing I wanted to recommend highly is start fixing and do so strategically. With the EAA, it’s not enough just to audit and tell people what’s not there yet. You need to fix problems. The EAA was not created to essentially prop up the accessibility auditing industry. It was done because it wanted to make things accessible for consumers on the end product. And in order to do that, you need to fix. You can do this strategically. And Jonathan, I know you had a couple of points you wanted to share on this.

JONATHAN: Yeah. So, please, please kind of hear the intention behind this. There are ways of playing these games that may be helpful for you to protect you whilst you are getting everything sorted. So the thing to kind of note here is that effectively if we just take WCAG 2.1A there are 50 success criteria. So if you are trying to work out if you like a score out of a 100 effectively each success criteria ticked off the list gets you another 2%. That’s the way the French have been doing this for a long time. So the key thing when you are thinking your about strategy here is to look to see is it likely that you are going to be able to if you like get full marks that those you get two marks or zero if you like you get nothing for in the middle.

So I’ve got a few a few examples here. So WCAG 1.1.1 is alt text. it is almost impossible for a large retailer to be perfect when it comes to alt text on their site. They will have huge numbers of images of products and huge numbers of products being created and added to their shop all of the time. It’s unlikely that you’re ever going to be absolutely perfect on 1.1.1. So, it’s probably not the place that I would kind of focus my energies.

If you have problems in various different places, for example, 3.3.3 is all about errors on forms. So, it could be you’ve got a couple of forms on your site and that’s something that you can fix and it doesn’t it doesn’t take so much time and effort. So, you can get more points if you like that way. That way of looking at things can be really really helpful. We’ve had lots of organizations working with us saying we’re still not perfectly compliant because some of these things are harder to get 100% marks on if you like than others. So, it’s a really good idea to actually think a little bit strategically on those sorts of things because it will help you prove to not only people like monitoring bodies but also your bosses that you are making some progress in fixing things. Liam, brilliant.

LIAM: Thanks, Jonathan. So, our next thing with the sort of lion the gazelle a little bit is to outrun the lion, be faster than the other guys. And so this talking about looking at the competitive landscape and what others are doing. Whilst we obviously recommend to address accessibility as fast as you can, we fully appreciate that resources are not unlimited.

You may not you may just be one person trying to fix everything. You may have a team but actually sometimes it can be running, just be about running faster than those around you. We assume that monitoring bodies and advocates will likely go after those that you know to continue the analogy are more towards the back of the hood. So do you know what’s happening around you and where you stand in comparison to your competitors? Do you know where you are strong and where there are opportunities for you to differentiate yourselves in the market? And there are ways that you can do this and ways that we’ve helped our clients. And we look at it from two perspectives. From a reputational and a technical.

On a reputational side, what we do is we look at things like what does it look like you’re doing? If I’m a consumer and I am searching for your organization, do you look like you’re taking accessibility seriously? Have you made big commitments? Have you published stories, case studies? Have you done some research, shared innovations? Have you won awards? You know, what does it look like your reputation is for accessibility? If it’s a lot stronger than your competitors, perhaps you’re at lower risk compared to others in this instance.

And then from a technical perspective, how well are you actually doing? You know, if we take your website or your app, how are you doing from those requirements? You know, how are you compared to some of the others? If looking at your competitive landscape is something you think actually that would be really helpful, please give us a message on our contact us or even in the chat.

This is definitely something that we can help you with. But if the start we’ve looked at, you know, how do we get the lion to not see you as a prey, but it still sees you? And in the second one, we’ve looked at, okay, it’s coming, but now we just want to run quicker than everybody else. How do we get that lion to turn away from you? How do we make it look at you and go, you know what, I’m going somewhere else if I’m honest. We want to create your narrative, your road map, your plan to getting compliant. Not being compliant yet may be okay, but only if you have a plan of how you’re going to get there.

You know, to be blunt, we assume that most organizations aren’t going to be perfect. But what you do need to do is talk about how you’re going to reach the desired level of compliance that you’re hoping for. And this gives you a few things. It gives you a plan to work towards and tangible achievements which can be shown whether that’s to public monitoring bodies or even internally to demonstrate the ROI of the investment they’ve given you. But it can also be good for risk mitigation by sharing what you’re doing in terms of how you’re getting compliant with the public and compliance bodies. You buy yourself that time. You demonstrate that your effort is going somewhere. And there are essentially two plans that you can create. one for internal and then one for the public. The internal one is going to be detailed. Have lots of information in your strategy, how you’re going to get there, when you’re going to get there, what are the responsibilities for all of us.

And then one for the public. Maybe it’s more generic. Maybe it has a more positive sort of focus on it, but something that talks about what you’re doing and how you’re trying to get there. I will say, you know, these types of plans are not something that Hassell Inclusion can claim credit for in creating. They’ve been around for a long time. You know, RGAA in terms of France, their legislation’s been requiring plans for a long time. You know, talking about your strategy, your policies, your human resource and your financial resources that you’ve applied to this, and they ask for a lot. But you might be sitting there thinking, “Okay, Liam, you’ve told me that a plan’s really important. So, actually, what am I going to put into this?” Well, we see that there are essentially five key inputs.

First, where is your organization going? What’s your strategic priorities? What have you promised? What are your users asking? What are you trying to serve them? And where are you going with accessibility? Are you trying to meet the ISO standard? WCAG, what are your legal requirements? What does your policy say about what you’re trying to achieve? Have you established who your accessibility lead is or is it still everyone does it off the side of their desk? And do you have that centre of excellence, that structure of governance to show this is going to be something that continues all the way throughout? And where are your products going? You know, if you’ve got multiple, have you done a heat map to understand, okay, you know, this one might be a bit more of a risk, this one might be more compliant. Have you tested and done research with users?

Again, let’s not forget that users are the people that we want to be focusing on as well. Have you had that feedback? Something that says, “Yes, you guys are on the right lines. Keep going.” And do you make it easy to do the right thing? A lot of people that don’t know accessibility think it’s quite complicated can say, “Oh, it’s just another thing that I’ve got to do.” So, have you been able to embed it in governance and policy, so it’s business as usual? giving them useful tools and templates to make it easy and putting accessibility into contract so that anything that is coming into the organization you don’t have to worry about you know oh my is it accessible you will have stated it has to be in order to come in and where are your people going do you know in terms of your roles who is maybe more developed who has better understanding do you have a training plan what’s mandatory what’s suggested and have you put accessibility into your job descriptions to make sure that people know they have a responsibility for accessibility in their normal BAU. So if that’s the scenario about if you think you aren’t there, what about if you think you are there? And I’ll pass over to Jonathan now.

JONATHAN: Thanks Liam. So yeah, if you think you’ve made it, is that it? is accessibility done? Well, here’s a quote that I think is quite appropriate for this. ‘This is not the end. It’s not even the beginning of the end, but it is perhaps the end of the beginning.’ That’s Winston Churchill. And that’s how it how it feels. Lots of people on the call will have been working in accessibility for a very long time. Others not so long. And the key thing here is that accessibility is never done.

So a few things for you to be kind of thinking about if you have got to what I would term your high watermark. Say for example, you are one of the organizations who’s done it. You’re perfectly WCAG 2.1AA, 2.2AA compliant. You’ve got everything sorted. Have you got everything sorted or is that just something that is transient?

What I’ve got on the screen here is a sawtooth curve. So this trace is something that we used to, use at the BBC where I was for many years, to help organizations within the BBC understand that accessibility isn’t just about creating something, it’s about maintaining it. So we had about 400 websites and they were all pretty much on a 2 year design sort of change. So every two years they would be refreshed. And when a website was being refreshed it had all of the best minds on it, the best coders, the best designers, and yes, the best accessibility people.

That was where the focus was. And normally when a site went out there, it was brilliant. And then it was handed over if you like to the B team, the people who maybe were just there to add new pages, add new sections to the product. And if they hadn’t had the same level of accessibility training, things just came down. That is the scenario that you do not want. This could be the best point that your accessibility ever has until such time as you get another jolt. Somebody comes and looks at your site now and says perfect, but two years time is not perfect at all anymore. And they find you at that point. So, you go back up again and you do this kind of saw. That’s what you don’t want to happen. And unfortunately it feels like some organizations haven’t got the memo on that one.

What we’re seeing unfortunately is that some organizations think that accessibility is done. They’ve disbanded their accessibility team if they had one because their job is done. They’ve got to that level of WCAG that they needed. Well, that’s not what you need. You know if you’ve been concentrating on getting your sites design and coding to be compliant, what about that ongoing maintenance?

That’s the sort of thing that is going to happen all of the way through the rest of the life cycle of that product. It’s going to go through lots of different versions. And so you need somebody leading work to kind of say, okay, how do we keep this good? That’s normally as I say that accessibility lead from an accessibility centre of excellence. If you can get this kind of done in the best sort of way at the very least you’ll need to be testing things.

You remember that monitoring stuff from the Netherlands that wasn’t we’ve checked you once that was you need to be checking yourself quite frequently. There are lots of different ways of doing that. You probably had an external audit done to you know check you are good against WCAG. How often are you going to do that? How much money is it going to cost you to do that? Are there more efficient ways of doing it? For example, automated tools are very good at finding small issues. Actually training your internal people to actually do accessibility testing themselves can be a much more efficient way of doing things. And yes, from our perspective and what I’m going to be coming on to is that in the end, compliance isn’t the thing you really want. What you really want is people with a disability being able to use your product. And so some form of user testing can be really, really good to give you that information.

The other thing you need to do is to make sure that if your product is going through lots of different versions, say for example, if we swap onto mobile apps for a while, the number of different versions that the mobile app goes through over the course of a year is probably at least four or five. So it’s really important to make sure that all of that new functionality has accessibility built in right from the start. You don’t want to be in the same situation that you might have faced with a year ago, which is that you had a product that wasn’t accessible. Testing told you that you now need to fix things. That’s inefficient. What you want to do is to now use this to get good right from the start.

So, if that sounds like you still need your accessibility team, that’s good. But you need to actually enable the people who would be investing the money the budget in that team and everything they do to agree with you. And for that you need return on investment. From our perspective, there is a lot more for your organization to win from accessibility than just making sure that you can’t be fined under the EAA, sued under the Americans with Disabilities Act, whatever it is. And unfortunately, when we’ve done our research, so we have a scorecard that organizations use to check to see how mature their accessibility thinking is.

We’ve had a lot more than 400 organizations now that have used it. But of the 400 that we looked at a couple of years ago, what we found was 62% of organizations that care about accessibility weren’t measuring the return in an investment. In fact, only 5% of those who used the scorecard were actually measuring their spend. So if you were the boss actually funding this accessibility work, you don’t know what sort of return on investment you’re getting from it. And that’s so our if you like diagnosis is that poor performance people if you like falling away from accessibility normally stems from a lack of understanding of the benefits of it and a lack of strategy in how to achieve them. So I want to look at that for those of organizations who are doing well.

This is what we call the ROI cycle. So it starts off with somebody saying we really need to do accessibility because there is a benefit that we want. That benefit could be we are not going to be fined under the EAA. That gets you some budget and some buy-in from people within the organization with that money to actually give you the chance to help improve the product. Once you’ve done that, what you would want to do is to tell people who have a disability that you’ve done it. We’re now more accessible than we used to be. Maybe we’re the best accessibility of all of our competitors in the class. And if you do that, then more people will use your product. Which will give you that proof of your return on investment. That’s the way the ROI circle should work.

Unfortunately, a lot of organizations don’t tell people who have a disability that they’ve made improvements. So therefore, more people who have a disability and don’t know that they should use your product rather than someone else’s. So that doesn’t happen either. And you don’t get the ROI. And here you can see the problem for a lot of organizations at the moment. The bosses are saying accessibility is done and nobody is saying that it’s worth continuing with. So if winning is what you should be looking for, how do you do that? Well, a couple of things from this, the key thing here is to don’t forget that this is about people. People who have a disability want to use the sort of things that you are creating. Most of the categories that the AI applies to are banks and shops and things basically places that people buy stuff. If they can’t buy your stuff then you’re not going to make any money. So it becomes really important to make sure that when you are providing information about your accessibility that people know that you’ve done a good job.

So there is a lot about statements of compliance, accessibility statements. We’ve got one on the screen here, which is a translation of one in Germany. It is one of the most boring documents I’ve ever read in my entire life. It tells you everything about the website and very, very little about why as somebody with a disability might you be wanting to use it. This one on the right from ServiceNow actually feels like it was created with people with disabilities in mind. Actually saying why accessibility matters to the company and the sort of things that they’ve done to prove that in the product that you can have a look at if you need it. That’s the sort of thing um that will really get you places. The other thing is that whilst the EAA is very very much about websites and apps at the moment, the key thing that people want is services that are accessible to them.

Here we have on the screen the user journey for buying something from a website and getting it delivered to you. You know, you might find the website because you’ve got a marketing email or some sort of social media. You then get to the website, you find the product, you check out, you pay, you get some sort of confirmation email or text to say that you’ve done this. Maybe if if you’re working in B2B, it might be an invoice. But fundamentally it arrives at some point. All of that needs to be accessible. All of it, not just the bit which is the website. And that’s the thing. If you go and think about just web accessibility, you will not get the return on investment you need because you’re concentrating on one part of a user journey that goes beyond the web. That’s the thing. That’s what Yac was talking about in the chat a little earlier. Our live audits actually don’t just look at your website. they look at your user journey and saying, “Okay, if I were somebody with a disability, would I feel like I was supported all the way through to that product arrives at my door?” If I was, I would continue to use your service and that’s the ROI.

So, that sort of thing is important. And the key thing here is accessible content. So, it’s there on websites, but it’s there beyond websites. And our feeling is is that it’s something that will help you win now and it’s something that will be much clearer in if you like future versions of this documentation. Here in the UK 2021, the UK government basically said to lots of marketing organizations you need to make your stuff accessible or else we’re not going to use your stuff. And they said but we don’t do websites. And the government said we don’t care. you do content, accessible videos, accessible, articles, accessible PDFs, all of these sorts of things are needed for this to really, really work. And we’re not going to work with you if you can’t do it.

So that’s one of the reasons why things like our accessibility for marketing creatives course is now so popular because lots of people are understanding that whilst a website or an app is really useful to make accessible for somebody with a disability to actually get a good service it needs to go beyond that. That is how you win. Okay, one last thing and then hopefully we’ll have a bit of time for some questions. And we’re going to show you something a demo of something at the end as well. So, there are some things that I don’t think are being talked about very much out there at the moment which really frustrates me. So, it’s a couple of things that are there in the EAA that it feels like a lot of people are completely ignoring and they’re actually really quite important to understand. All of our clients were helping with these.

So the first thing is that say for example your website isn’t accessible. What should then a person with a disability do? Well chances are what they will want to do is to talk to somebody on a customer service line and say do you realize that you’ve got a problem here or maybe I’ve missed it but I couldn’t get it working for me. How is it supposed to work for me if I’m using a screen reader? That sort of thing. Now the EAA has in its original form and coming through into the version of this in all of the different countries. A requirement for support services to be accessible to have information on the accessibility of the service and its compatibility with assistive tech and to enable people to be able to get that in an accessible mode of communication. And this includes call centres.

So literally somebody may be phoning you up who has a disability who needs you to explain to them how they can get around any accessibility problems that may be there in your product. Can you do that where you are at the moment? If somebody called your your line and said, I’m listening to your website with Jaws and it doesn’t work for me. Would that person on the customer service line go, “Ah, Jaws, that’s a screen reader. That’s why this person is listening to the website.” Because they’re blind. They’re using that screen reader to do it. And maybe when I’m looking at the website, it’s working perfect for me, but that person is looking at it in a very, very different way. So how can I get to the bottom of their problem? Is that what they would say? Or would they think, “Hold on a second. Someone’s listening to my website.” Maybe they’re looking at kind of like a video or something and they’re talking about their jaw. No idea. This is the sort of thing we help people on contact centres, both call centres and also potentially in branches or stores if you have them. For example, we were doing this just yesterday.

This is a case study from a few years ago where we help the parliament digital service here in the UK. A lot of MPs and people in parliament actually have different types of disabilities. And they help cater for 10,000 people. They wanted to make sure that when people actually phoned them up, they actually understood the sort of language and were able to kind of help. So we gave people an experience of actually working with six people with a disability. What sort of issues might they be phoning a customer service line about? How might they want to communicate best? Say for example, if they were autistic, all of these sorts of things enabled that particular organization to say not only did they feel confident, but it was some of the richest feedback they’d ever experienced. That sort of thing. We do all of the time and it really really helps.

Last thing before we pop on to questions is that kiosk bit that we mentioned there at the beginning. You know everybody is kind of thinking we’ve just got past the first deadline. There is another one coming. If you have anything to do with ATMs, payment terminals, kiosks, within your organization, 2030 is coming and what you don’t want to do is to kind of, if you like, panic again in 2029 because that’s the first time you looked at this sort of thing.

So, if you’re a bank with ATMs, payment terminals, if you’re a travel organization with electronic ticket machines, if you’re an organization that creates ebook readers or the TVs that you would watch streaming services on, you need to get your hardware right. You’ve got until 2030 for this, but it takes a lot longer because when you are thinking about making something accessible that is if you like a physical product, say for example a sign-in tablet which people might use to come into your offices or ATMs or for that matter a self checkout in a supermarket. All of these things are a combination of the digital and the physical.

To give you an example, if this tablet is at the wrong height and people who use a wheelchair can’t reach it, doesn’t matter how brilliantly your digital accessibility works because they’re not going to be able to use it because they can’t reach it. So, it’s about a combination of these things. We’ve been helping loads of organizations with this sort of stuff for a while. So if you are in that place where you’re thinking, okay, we’ve done the first bit, we’ve got our websites and apps accessible. Now the hard part, how do we get to, all of the places where we have those self-service terminals? We can help you with that if you get in touch. So, please do.

So Pete any kind of questions that we want to look at before we show people a mechanism for actually kind of finding answers to questions.

PETE: So it’s been awesome today. There’s been so much conversation in the chat. I hope those who have asked questions have found it useful. Yac, myself and others have jumped in to give you responses. I think one question which is really interesting from Richard Gelder. Canadian companies are increasingly selling to EU. So if you’re outside the EU, if you’re a British company or elsewhere in the world, any indication whether agencies the monitoring organizations are going to go after EU companies first or go after foreign companies? I mean Liam chime in on this one as well. I don’t think we actually have any any evidence one way or the other at the moment. I think the thing to think about is if you were a monitoring agency, what would you spend your time on? Who would you go after first? So, all of that stuff that Liam was talking about earlier about large companies that are very visible. I think that’s the sort of thing, you know, it’s interesting that that’s that case in France, which is the big four supermarkets in France.

So if you are a company outside the country but if you like servicing consumers within that country, it depends on your size. I think if you are you know like a huge company like Apple or Google or Microsoft or whatever then I think they might come after you. If you’re a much smaller one it’s you probably not. My gut feel is that if I’m working in a monitoring agency, I want the world to know that I’m for real. So I’m going to go after the biggest headline that I can get. So are you the type of company that will give me that headline? That’s the way I would look at it. Liam, any thoughts from you?

LIAM: I echo all your sentiments. I think thing that I’d say is what we do know about the EAA since it’s happened, there’s still a lot that we don’t know. So that one legal action still, you know, it wasn’t brought by a monitoring body, it was bought by a group of individuals. So exactly as Jonathan said, if you’re considering your risk when it comes to monitoring bodies, looking at yourself in terms of size, you know, your product, is it in the public or is it behind a lock screen?

Those will give you an indication as to how much risk your product might be. Whether a monitoring body chooses you or not, we will, I suppose, find out in the way that they approach things. But I think still taking a strategic, you know, understanding of okay, maybe the country as itself is more developed. So maybe they’re, you know, for their those aspects, you know, for France, for the Italys, the Spain, maybe we’re more at risk and then consider it from that perspective.

JONATHAN: So Pete, I want to hand over to you now. We’ve been answering lots of questions in the chat. We have another way of people being able to kind of chat and ask questions that we’re kind of piloting at the moment. Do you want to kind of take control of the presentation and some stuff?

PETE: Yes. So hopefully that is going to share my screen and you should see yes. So we’re really quite excited. We’ve been playing around with AI and one of the things we get from clients is I’ve got a quick question, do you have time to respond to it? And we was like, well, we’d love to. But I wonder if we can help you self-serve. And so we’ve been picking the brains of Jonathan, Liam, Yac, Usman, and other members of the team and saying, can we put this into an AI environment so that you can ask it anything and see what what we might say? So, we’ve developed a tool called HiBot. It’s going to be launched soon. We’re looking for beta testers. So, if you feel like you would like to test this out, and particularly we’re looking for people who are current clients with us or if you’re in the process of chatting with us, then those are definitely on the priority for that. We’ve put Jonathan’s books in it, all the transcripts of webinars, our blogs, information from our website and other resources.

So, it is a digital accessibility resource. It’s more at the implementation and business end of it because we do see other websites which have the technical bits around how do I write HTML code. So I took one of the questions we got from somebody who wrote this as they registered for the session for the European accessibility act. Can adding a page with an accessibility statement be enough to avoid penalties and should the content of the statement be updated? So somebody wrote that as a question. Let’s see what the response from the tool will be. To be honest, we are actually amazed when it comes up with stuff because like oh I would have written that. So it’s a crucial step but it’s not sufficient. It should be part of your broader strategy. You should think about the content. You definitely should keep it updated. The European Accessibility Act requires continuous monitoring and there’s communication and transparency on it. So there’s a variety of answers to this. You can basically ask anybody anything.

So does somebody want to write something in the chat something that they want to ask the question of this thing? So first person to get into chat with a question. I will type it into HiBot and see what it says. And of course somebody has rung on my doorbell now at this time of the day. I can’t Okay, I can’t see a question. Okay, let’s take one other question in it. Oh, that’s quite a long question. Okay. How do we deal with contradictory requirements? How do we deal with contradictory accessibility requirements? I’m going to need to just pop down what the stairs for one moment. So, Jonathan, if you can pick up.

JONATHAN: Yeah, I’ll check there. That’s good. So let’s see. I was talking about this in the webinar last month. So hopefully it’s got some of the things in there that I was talking about. So yeah, it can be challenging strategies sort of user research. So yeah, I mean that’s a good one because one of the ways of using user research that you know when I was running this at the BBC oftentimes there were you know different views from different managers in the business. We should be doing this, we should be doing that, actually looking at the users as the arbiters for what decision you were going to make is always a really really good thing. Prioritizing the stuff that is core so the stuff that really matters rather than the stuff that isn’t. You know user personalization is one mechanism for saying one person may for example like dark mode for colours one might prefer you know the other way of colours you can do that if you’ve got those personalisations. So yeah that’s not bad. There’s some good things there and some things that people will be able to kind of to check out. When they come through.

Pete, I’m going to just take over to the last bits because we’ve only got one minute left. So hopefully that’s given you an idea. There is some stuff there in the in the chat about how you can get in touch with Pete and see if you can get part of the of the kind of beta plan for that.

All of this stuff is going to be up on HiHub very very soon. So you’re going to be able to see it. People always ask us for the slides. We don’t give them out because, a lot of our competitors actually kind of try and get our slides and create their own training from them, which is not what we like. So feel free to share stuff though. You know, the key thing is just credit us when you do it, because that’s, what we do all of the time and that’s what honour looks like to us. We’ve got a couple of webinars coming up next month. Pete especially is going to be taking us through. Okay. So, you know, how do you put together an accessibility plan for 2026 that somebody actually in the organization who has money might fund? That’s next month. The month after in November, we’re going to be revisiting AI and accessibility with Liam and Yac. They did an amazing webinar last October on this. It’s there on HiHub for you to go and have a look at it. Go have a look now because obviously AI never never stays still. So more has happened in the year between then and now. So there’s going to be some good stuff in November.

And finally, yeah, if this has been useful for you and you think I’d like more, especially on the kind of strategic side of things, if you use your camera phone and and point it at the screen at the moment, that is the QR code for getting a free audio copy of my book. It’s the first of two books that I’ve got. But hopefully that will give you and certainly it’s the sort of thing that you can give to maybe kind of higherups in the organization so they understand not just why accessibility is so important or even how to do it but how to do it in a way that is continuous and gives you that return on investment which is the thing you need to make this a going concern where you are.

Thank you so much for your time. We really appreciate it. I hope you’ve really enjoyed this. Please feel free to get more get in touch via the contact us form on our website with any other questions that you’ve got, and hopefully if you’ve enjoyed it. We will see you next month. Have a great day and together we are all making accessibility happen. Thank you. Bye-bye.

Three wooden cubes that form the expression 'European Accessibility Act'

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