When Does What Apply? The EAA Timeline 2025-2040

Note: While this article focuses on Germany's implementation timeline of the European Accessibility Act (BFSG), the deadline of June 28, 2025 applies uniformly across all EU member states under Directive 2019/882.

The European Accessibility Act (BFSG in Germany) doesn't come overnight – it rolls out in stages. While digital services must already be compliant on June 28, 2025 without any transition period, other areas have longer deadlines. This detailed timeline shows you exactly when which requirements take effect and how to optimally prepare^[1][2].

The Big EAA Countdown: All Dates at a Glance

📅 June 28, 2025: The Big Start (Day X)

What becomes mandatory immediately?

• All websites for consumers
• Mobile apps and Progressive Web Apps
• Online shops and e-commerce platforms
• Banking and financial apps
• Streaming and media services
• Booking and ticketing systems
• Telecommunications services

⚠️ No Transition Periods! Unlike hardware products, there is no grace period for digital services. Your website must be fully WCAG 2.1 Level AA compliant from the first day of validity^[3].

📅 June 2030: Existing Contracts Updated

What changes?

• Running service contracts must be EAA-compliant upon renewal
• Existing customers receive access to accessible versions
• Legacy systems must be modernized
• Service level agreements are extended with accessibility

Practical Example: A mobile phone contract from 2023 expires in 2026 and is automatically renewed. From 2030, the provider must provide all services (app, website, customer portal) accessible even for this old contract.

📅 June 28, 2040: Hardware Terminals Follow

What is affected?

• ATMs (cash machines)
• Ticket machines
• Check-in terminals (airport, hotel)
• Self-service checkouts
• Information terminals
• Parking meters

Why so late? Hardware cycles are longer than software updates. Terminals often have 10-15 year lifespans, hence the longer transition period^[4].

Month-by-Month Countdown to June 28, 2025

Today - March 2025: Last Chance for Preparation

• To-Do: Immediate WCAG audit of your website
• Time Required: 4-12 weeks for complete implementation
• Costs: €5,000-€50,000 (approx. $5,400-$54,000) depending on complexity
• Risk: High - very little time remaining

April 2025: Intensive Phase

• To-Do: Development and testing in full swing
• Focus: Critical WCAG criteria first (keyboard, contrasts, alt texts)
• Team: All developers working on accessibility
• Testing: Daily automated tests + weekly manual checks

May 2025: Fine-Tuning and Quality Assurance

• To-Do: Fix last bugs, screen reader tests
• Documentation: Prepare conformity declaration
• Training: Prepare support team for accessible operation
• Backup Plans: In case not everything is ready in time

June 1-27, 2025: Countdown Phase

• To-Do: Go-live preparation, final tests
• Monitoring: Performance monitoring of new features
• Communication: Inform customers about improvements
• Emergency Plan: 24/7 support team ready for deadline

June 28, 2025: Day X

• 07:00 AM: Complete EAA compliance must be ensured
• All Day: Monitoring and immediate bug fixes
• Support: Reinforced team for user feedback

Industry-Specific Timelines: Who Has Which Deadlines?

E-Commerce & Online Retail: Immediately from Day 1

• Deadline: June 28, 2025, 00:00 hours
• Affected Services: Shop frontend, checkout, customer accounts
• Special Feature: Marketplaces must also make their platform accessible
• Preparation: 6-12 months for complete implementation

Financial Services: Critical Sector

• Deadline: June 28, 2025, 00:00 hours
• Affected Services: Online banking, apps, insurance portals
• Special Feature: High security requirements + accessibility
• Regulation: Financial regulators will increasingly inspect

Telecommunications: Complex System Landscapes

• Deadline: June 28, 2025, 00:00 hours
• Affected Services: Customer portals, VoIP, messaging, streaming
• Special Feature: Hardware + software affected
• Challenge: Integrate legacy systems

Transport & Mobility: Multi-Stage Rollout

• 2025: Booking apps and websites
• 2030: Existing customer integration
• 2040: Physical terminals (ticket machines)
• Special Feature: Longest transition periods due to hardware

Timeline Pitfalls: What's Often Overlooked

Pitfall 1: Software Updates Before Deadline

Many companies forget that updates and new features from June 28, 2025 must also be WCAG-compliant immediately. No "remediation time"!

Pitfall 2: Third-Party Services

Chatbots, payment providers, analytics tools must also be accessible. Check all external services in time.

Pitfall 3: Mobile vs. Desktop

Both versions of your website must be compliant simultaneously. Mobile-first isn't enough - the desktop version also needs accessibility.

Pitfall 4: Document Downloads

PDFs, Excel files and other downloads on your website must also be accessible. This is often forgotten!

International Timeline: EAA in EU Context

The EAA is part of an EU-wide movement. Other countries implement in parallel:

Simultaneous Implementation (June 28, 2025):

• Germany: Barrierefreiheitsstärkungsgesetz (BFSG)
• France: Code de la consommation (Article L. 111-7-13)
• Netherlands: Tijdelijke wet digitale toegankelijkheid
• Austria: Behindertengleichstellungsgesetz amendment

Later Implementation:

• Italy: Decreto Legislativo n. 106/2018 (improvements until 2026)
• Spain: Real Decreto-ley 12/2018 (partial delays)

Earlier Implementation:

• Denmark: Bekendtgørelse nr. 1073 (stricter rules already since 2024)
• Sweden: Lag om tillgänglighet (already tightened in 2024)

Practical Preparation: Your 12-Week Plan

Weeks 1-2: Assessment

• WCAG audit of your complete website
• Identify and check third-party services
• Define budget and resources
• Assemble developer team

Weeks 3-4: Quick Wins

• Add alt texts for all images
• Raise color contrasts to at least 4.5:1
• Keyboard navigation for all interactive elements
• Optimize page titles and heading structure

Weeks 5-8: Structural Improvements

• Implement semantic HTML
• ARIA labels for complex widgets
• Focus management and indicators
• Forms with labels and error messages

Weeks 9-10: Testing & Optimization

• Automated testing with axe-core or similar
• Manual tests with screen readers
• User testing with people with disabilities
• Performance optimization

Weeks 11-12: Go-Live Preparation

• Write conformity declaration
• Train support team
• Set up monitoring and feedback systems
• Emergency plans for deadline

Frequently Asked Questions About EAA Timeline

What exactly happens on June 28, 2025 at midnight?

From 00:00 hours, all digital services for consumers are required to meet WCAG 2.1 Level AA. There is no grace period or transition phase.

Can we ask for a deadline extension?

No, the deadlines are legally fixed and non-negotiable. A postponement is not possible.

What about new features after June 28, 2025?

All new features must be immediately accessible. They cannot be "retrofitted" later.

Are there exceptions for technical problems on the deadline?

Technical difficulties are no excuse for non-compliance. Plan buffers for unforeseen problems.

Do we have to restart our entire website on June 28?

No, but all publicly accessible areas must be accessible from this day. A gradual rollout is not permitted.

What about beta features or internal tools?

Beta features for consumers must be accessible. Internal tools only for employees are not affected.

Is there a "grace period" for small violations?

No, authorities can impose fines immediately. It's at their discretion, but legally there is no grace period.

Can we make page sections accessible successively?

No, the entire website must be compliant on the deadline. Individual page sections cannot be activated gradually.

What Happens After June 28, 2025

July - December 2025: Enforcement Begins

• First random inspections by state authorities
• Complaint-based checks increase
• First fine notices are sent
• Case law develops

2026-2029: Establishment of Standards

• WCAG 2.1 Level AA becomes the "new normal"
• Consumers become sensitized to their rights
• Competitive advantages for early-compliant companies
• Technology stack continues to evolve

2030+: Long-Term Evolution

• Possible tightening to WCAG 2.2 or higher
• Integration of AI-based accessibility features
• International harmonization of standards

Conclusion: Time is the Critical Factor

The EAA timeline is relentless: While hardware terminals have until 2040, digital services must be fully accessible in just a few months. Every lost day makes implementation more difficult and expensive.

Our urgent recommendation: Start preparing today. The time for procrastination is over - June 28, 2025 is coming inevitably.

Further EAA Articles:

• European Accessibility Act 2025: The Ultimate SME Compliance Guide
• Who is Affected by the EAA? The €2 Million Threshold Explained
• EAA Fines: €10,000 to €100,000 - What Really Threatens?