Privacy leaders have spent the last several years building the exact governance muscle a new EU digital accessibility regulation now requires. Most just aren’t aware it applies to them yet.
The EAA took effect on June 28, 2025. It is now in active enforcement across the EU. And if you read its structure the way a privacy leader reads a regulation, something familiar jumps out. This is GDPR’s playbook, applied to accessibility instead of privacy.
Privacy teams spent years learning that lesson the hard way. Accessibility teams are about to learn it fast. The organizations that connect the two will save themselves from rebuilding processes and best practices that translate today.
How is the EAA like GDPR?
The EAA borrows three of GDPR’s most consequential design choices. If you lived through GDPR, you already know how each one behaves.
First, it reaches beyond EU borders. The EAA applies to any company placing covered products or digital services on the EU market, regardless of where that company is based. A US enterprise selling to EU customers is in scope. Sound familiar?
Second, it expects accessibility “by design,” not bolted on at the end. That is the same shift GDPR forced with “data protection by design and by default.” You cannot audit your way to compliance the week before a deadline.
Third, it enforces through decentralized national authorities rather than one central regulator. Each member state supervises and penalizes in its own way. Privacy leaders know exactly how much operational complexity that fragmentation creates.
Does the EAA apply to companies outside the EU?
Yes. Like GDPR, the EAA follows the market, not the mailing address. If your digital service is available to consumers in the EU, the obligation travels to you.
That single fact is why accessibility can no longer sit in a backlog owned by one front-end team. It is now a cross-border regulatory exposure, measured and governed the same way you already measure cross-border data risk.
And the evidence says most organizations are not ready. According to AudioEye’s 2026 Digital Accessibility Index, the average web page contains 62 accessibility issues, and roughly 21% of them are severe enough to block a user from completing a task. These are not cosmetic gaps. They are the digital equivalent of a locked door.
The same report found that EU-based sites average about 25% more accessibility issues per page than US sites. The market now governed by the strictest accessibility law is, today, the least prepared for it.
Do your privacy best practices translate to accessibility?
Yes. Nearly every governance practice you built for privacy carries straight over. The governance muscles you built for privacy transfer almost directly.
Consider what a mature privacy program already does. It maintains a record of processing activities. The EAA expects documented evidence of accessibility conformance. It runs data protection impact assessments. Accessibility needs the same disciplined, repeatable assessment against a known standard, in this case WCAG 2.2 Level AA, the conformance target regulators point to. It vets vendors and data processors. Your digital vendors ship accessibility risk into your stack the same way they ship data risk.
The reporting lines already exist too. A privacy program answers to the board in the language of risk, likelihood, and exposure. Accessibility fits that same sentence without changing a word. You are not building a new function. You are extending one that already works.
This is where accessibility stops being a compliance chore and starts being a growth lever. A site that a screen reader user can actually navigate converts more customers, in more markets, on more devices. The governance work protects you. The accessible experience grows you. Both are true, and privacy leaders are unusually well-positioned to hold both at once.
Where should you start?
Start by measuring your current exposure, because you cannot govern a risk you have not sized. This is the same first move you made with your data map.
Run a scan of your primary web properties to see where you stand today. A free website accessibility checker will surface the issues on a given page and give you a baseline read on risk in minutes. Treat the output the way you would treat a data protection impact assessment: a prioritized list, not a verdict.
From there, the privacy playbook carries you the rest of the way. Assign an owner. Fold accessibility into your existing vendor reviews. Set a conformance target and document your progress toward it. Report it alongside your other governance metrics. None of this requires a new department. It requires pointing a working machine at a new obligation.
This isn’t a new compliance obligation to staff up for; it’s an existing one to extend. The privacy leaders who treat the EAA as a data-map exercise rather than someone else’s project will be the ones with a real answer when the board asks if the company is exposed.
