The European Accessibility Act became enforceable on 28 June 2025. Almost a year on, regulators across the EU are no longer just sending out warning letters, they are actively auditing and fining. If you sell or run online courses, training programs, or a learning platform with European customers, now is a good time to find out whether you are actually covered, and whether your platform holds up.
A lot of independent trainers assume this law is something for big software vendors or online retailers. That assumption can get expensive. If you have consumers in the EU as customers and your content or platform isn't accessible to people with disabilities, you could end up on the wrong side of the rules without even realizing it.
What the law actually requires
The EAA requires providers of certain digital services and products to make their offering usable for people with visual, hearing, motor, or cognitive disabilities. In practice that means things like captions on video, full keyboard navigation, text that screen readers can actually parse, and enough contrast between text and background to read comfortably.
E-commerce is explicitly within scope. And here's the catch most course creators miss: the moment a learner checks out and pays for your course on your site, you're running an e-commerce service. That covers your learning environment itself, not just your marketing website.
Does this even apply to you as a solo trainer?
There's genuinely good news for smaller operators. Micro-enterprises, meaning businesses with fewer than 10 employees and annual turnover under 2 million euros, that provide services are exempt from the act's hard requirements. If you're running things solo or with a small team and mainly selling a service rather than a physical product, you likely fall outside the strict obligation.
A couple of caveats though. The exemption only covers services, not products, and individual member states get some say in how they apply it locally. Bigger training institutes with more staff or higher revenue usually don't get the exemption. And even if you personally qualify for it, a corporate client or government contract may still require accessible materials as a condition of doing business, especially in sectors like healthcare or public administration where accessibility is already standard practice.
What your course environment needs to actually do
Whether you're legally required to act or just want to stop losing learners, here's what auditors typically check for:
- Videos come with captions, ideally alongside a transcript.
- Images carry short, descriptive alt text.
- The whole platform can be operated using only a keyboard.
- Text-to-background contrast is high enough to read, including for people with color blindness.
- PDFs and documents are readable by screen readers, not just scanned images of text.
- Forms and buttons have clear labels that make sense without a mouse.
None of this is technically difficult. Most of it comes down to building a habit and running through a short checklist whenever you publish new content.
What happens if you do nothing
Enforcement varies by country, but typically starts with a warning, then a deadline to fix the issue, and can escalate to a fine if nothing changes. Beyond the legal risk, there's a more immediate business cost: learners with disabilities quietly drop out, corporate buyers with strict procurement rules pick a competitor instead, and word gets around if your platform turns out to be hard to use.
Five things you can start today
- Pull up your last three courses and check whether the videos have captions.
- Try navigating your entire learning environment using only your keyboard, no mouse at all.
- Ask someone using a screen reader, or grab a free tool like NVDA, to walk through one module.
- Ask your LMS provider directly whether their platform meets WCAG guidelines. Most support teams have a stock answer ready.
- Assign one person on your team to own accessibility for new content going forward. Shared responsibility usually means nobody's responsibility.
A requirement that's also an opportunity
Accessibility sounds like a compliance checkbox, but it quietly grows your audience too. Captions don't just help deaf or hard-of-hearing learners, they also help everyone watching a video on a train with the sound off. Clean alt text and a clear structure tend to improve your search rankings as a side effect. And a course that works for everyone usually just works better for your whole audience, disability or not.
This article isn't legal advice. If you're unsure whether the act applies to your specific situation, talk to a lawyer who specializes in EU regulation. But waiting for your first fine to find out is not a strategy. Start small, start now.