ADA vs EAA: what is different?

In brief

The ADA and the European Accessibility Act both aim at digital accessibility, but they work differently. They apply to different organizations and use different routes to a technical standard. Both lean heavily on WCAG, so one set of WCAG work helps with both.

The main differences

• Type of law: the ADA is a U.S. federal civil rights law. The EAA is an EU directive (Directive (EU) 2019/882) that Member States put into national law.
• Who is covered: ADA Title II covers state and local governments, and Title III covers businesses open to the public. The EAA covers specific products and services listed in the directive, such as e-commerce and banking. See EAA scope.
• Technical standard: Title II requires WCAG 2.1 Level AA. For Title III there is no detailed DOJ regulation, and WCAG is a reference. For the EAA, the route is the standard EN 301 549, which builds on WCAG.
• Dates: Title II: 26 April 2027 and 26 April 2028. The EAA has applied since 28 June 2025 to in-scope products and services placed on the market or provided after that date.

Where they overlap

Contrast, keyboard access, alternative text, captions, accessible forms and clear structure matter in all of them. The checklist pages cover those criteria with code examples.

A caution

Meeting one law does not automatically mean you meet the other. Each has its own scope, exceptions and enforcement.

What to do

• Work out which laws apply to each product, market and customer type.
• Use WCAG 2.1 Level AA as a common base, then check the extra requirements of each law.
• Keep one inventory and one test plan for both.

Common mistakes

• Assuming ADA compliance is EAA compliance, or the reverse.
• Building separate fixes for each law instead of one WCAG base.

Sources

• 28 CFR Part 35, Subpart H: Accessibility of Web Information and Services (eCFR), opens in a new tab
• Guidance on Web Accessibility and the ADA (ADA.gov), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official ADA statute and regulations, and ask a lawyer how they apply to you.