Published by Fractional Coordinator, Inc. | November 2025

When the European Accessibility Act (EAA) moved from theory to reality on 28 June 2025, it marked one of the most consequential shifts in higher education policy in recent memory. Formally adopted in 2019 as Directive (EU) 2019/882, the law now sits at the center of how digital education is designed, procured, and delivered across the European Union. 

What began as a framework for accessible products and services has become something larger. In practice, the EAA is forcing universities and schools to treat accessibility not as an accommodation at the margins, but as a basic property of digital infrastructure, on the same level as security, privacy, and academic quality. 

Several months into full application, institutions are no longer asking whether the act matters. The question is how quickly they can rebuild systems so that accessibility is an ordinary, measurable expectation rather than an exception granted to a few.

A Legal Framework with Continental Reach

The EAA establishes shared accessibility requirements for twenty seven member states across a wide range of products and services, including software, e learning platforms, e books, media, and digital interfaces that now sit at the center of modern teaching and assessment. 

Its reach extends beyond the European Union. Any university, school network, or education technology provider that markets digital services to learners in the EU now falls within scope. That includes non European institutions that recruit EU based students, operate cross border programs, or license learning tools and content into EU markets.

Noncompliance is no longer a remote risk. National laws implementing the EAA give regulators authority to investigate complaints, order corrective measures, withdraw noncompliant products or services, and impose financial penalties.    Reputational consequences and the potential loss of access to EU partners and students amplify that risk for universities that rely on global collaborations.

Technically, the act does not prescribe a single checklist. Instead, products and services are presumed compliant when they conform to harmonized standards, most notably EN 301 549, which in turn incorporates Web Content Accessibility Guidelines, currently at version 2.1 and moving toward 2.2.    In practice, this means that higher education providers must treat WCAG level AA as the floor for digital content and interfaces.

From Countdown to Course Correction

In the years leading up to June 2025, universities were largely in preparation mode. Accessibility teams focused on inventories, audits, and training. Vendors published roadmaps promising future alignment. National agencies and sector bodies issued guidance that often blended the earlier Web Accessibility Directive for public sector bodies with the new obligations under the EAA. 

Since June 28, the tone has shifted. The first months of application have revealed several clear patterns in how institutions are navigating the new landscape:

1. Audits have moved from optional to unavoidable. Sector reports and vendor data show a sharp rise in comprehensive reviews of institutional websites, virtual learning environments, video platforms, and assessment tools. Many universities have commissioned external audits focused specifically on EAA readiness, often coupled with internal accessibility statements and remediation plans. 

2. Procurement has become the pressure point. Because the act applies to services that are currently provided, not only to newly signed contracts, institutions are reviewing existing vendor relationships and insisting on clearer accessibility clauses, roadmaps, and proof of conformance with EN 301 549 and WCAG. 

3. National variation is creating operational complexity. Member states are implementing the EAA through their own laws and regulators. As a result, universities with campuses or partnerships in multiple countries face slightly different complaint routes, documentation expectations, and enforcement cultures, even while working under the same directive. 

4. Legacy systems are testing the transition rules. The directive allows a transition period for certain products used in the provision of services and for contracts signed before June 2025, in some cases lasting until June 2030.    Universities are now deciding which systems to replace immediately, which to remediate, and which to retire as part of a structured phase out.

Across the sector, the shared lesson is simple: the deadline was real, and the grace periods are narrow enough that delay now translates directly into cumulative risk. 

How Universities and Schools are Responding

The response from higher education and secondary schools has not been uniform, but several common strategies have emerged.

1. Building structured accessibility programs

Institutions that were already working under the Web Accessibility Directive and national disability law have begun to fold EAA alignment into broader digital accessibility programs.

Typical elements include:

• Central audits of institutional websites, learning management systems, library portals, video platforms, and student information systems, with prioritization matrices that focus on high impact content such as core courses, assessments, and admissions material. 

• Development of accessibility roadmaps that assign timelines, owners, and funding for remediation rather than relying on ad hoc fixes.

• Creation or expansion of digital accessibility steering groups that bring together disability services, information technology, academic leadership, and legal or compliance roles.

In several EU projects focused on universal design in higher education, institutions have reported that the EAA has provided a concrete lever to integrate accessibility into program design and staff development, not only into technical teams. 

2. Rethinking procurement and vendor management

Universities and school systems are also revising procurement practices so that accessibility is considered at the beginning of purchasing decisions rather than at the end.

New patterns include:

• Requiring accessibility conformance reports and sample accessibility statements from vendors of learning platforms, e book providers, assessment tools, and media services. 

• Including contractual obligations for remediation timelines when issues are discovered, along with escalation pathways if vendors fail to deliver.

• Using the EAA as a negotiating tool to push global providers to align product roadmaps with European expectations, which in turn shapes offerings for institutions outside the EU as well. 

This procurement shift is one of the ways the EAA exerted influence even before June 2025 and continues to do so now that the law is fully in force.

3. Scaling content remediation and training

On the academic side, universities and schools are working through the practical details of accessible digital content:

• Expanding captioning and transcription support for recorded lectures and webinars.

• Standardizing templates for course pages and documents that enforce heading structure, contrast, and alternative text as defaults rather than options. 

• Offering targeted training to faculty, instructional designers, and librarians on accessible document creation, accessible e books, and accessible assessment design.

In many systems, disability support units have shifted from being the sole owners of accessibility to acting as internal consultants and trainers. This aligns with the act’s expectation that accessibility is an organizational responsibility, not a specialist corner. 

4. Preparing for monitoring, complaints, and enforcement

Because member states must designate authorities to monitor compliance, respond to complaints, and require corrective action, universities are strengthening internal governance: 

• Drafting or updating digital accessibility policies that explicitly reference national EAA implementation laws.

• Establishing internal reporting routes for accessibility concerns so that issues can be addressed before they become external complaints.

• Publishing accessibility statements that describe the current state of compliance, known limitations, and remediation plans in clear language.

These governance structures are where the EAA meets institutional culture. They signal whether accessibility is treated as a reputational risk to be managed or as a core expression of academic mission.

Structural Barriers That Remain

Even with this activity, barriers are clear.

Resource and capacity constraints. Many institutions, particularly smaller universities and schools, report limited budgets and a shortage of staff with deep expertise in WCAG, assistive technology, and accessible design. This often leads to reliance on a small number of overextended specialists. 

Inconsistent maturity across systems. Some parts of the digital ecosystem, such as central websites and main learning platforms, are improving quickly. Others, like legacy departmental sites, specialized laboratory tools, or bespoke assessment platforms, lag behind and are harder to remediate.

Cross jurisdictional complexity. Institutions that operate across borders must reconcile EU directives, national law, data protection rules, and local contractual constraints, which can pull governance structures in different directions. 

These barriers do not diminish the act’s impact. They simply describe the distance that still needs to be traveled between compliance on paper and consistent accessibility in practice.

A New Model for Accountability

The most promising responses treat the EAA as a catalyst for institutional redesign. Leading institutions are doing more than checking boxes. They are using the act as a framework to connect policy, pedagogy, and technology within a single commitment to equity.

Common elements of these emerging models include:

• Digital accessibility embedded into strategic plans and quality assurance processes, rather than limited to technical implementation. 

• Cross functional teams that link information technology, academic affairs, disability support, and legal or compliance offices in ongoing review cycles.

• Performance indicators that measure accessibility outcomes, such as the percentage of courses that meet specific standards, and not only the existence of policies.

Accessibility in this sense becomes a test of institutional integrity in the digital era. It is visible in how universities invest, whom they consult, and how they respond when gaps are exposed.

Beyond Compliance: A Cultural Imperative

The promise of the European Accessibility Act is not limited to enforcement. It is the possibility that institutional values and the lived experiences of learners with disabilities and diverse access needs finally converge. Reports from disability advocacy groups in 2025 stress that meaningful implementation will be measured by real improvements in how people engage with education, not only by technical declarations of conformity. 

For universities and schools that move early and honestly, the act offers more than protection from risk. It offers a chance to lead the next generation of inclusive digital education, where accessibility is a hallmark of educational quality and not an afterthought.

The question has changed. It is no longer whether accessibility matters, but how deeply it is woven into the architecture of learning and how transparently institutions account for their progress.

Partnering with Fractional Coordinator

Fractional Coordinator supports institutions as they navigate the post implementation phase of the European Accessibility Act. We provide practical, on demand expertise in digital accessibility, compliance readiness, and organizational alignment, grounded in the realities that universities and schools across Europe are encountering in 2025.

Our team works with institutions to:

• Conduct comprehensive accessibility audits across digital estates, with prioritized remediation plans.

• Review and modernize procurement practices, vendor contracts, and service level expectations in light of EAA obligations and national enforcement trends.

• Design governance and policy frameworks that align institutional structures with accessibility by design.

• Build sustainable training and support models that embed accessibility into content development and curriculum design.

To learn more about strengthening your institution’s accessibility posture under the European Accessibility Act or to schedule a consultation, visit www.fractionalcoordinator.com or email support@fractionalcoordinator.com.

In the new landscape shaped by the EAA, institutions that act with clarity, urgency, and care will not only comply. They will define what inclusive digital education looks like for the next decade.