The new digital accessibility law – is your hotel ready?

Many hotels around the world are likely to target customers from the EU and as such, the EAA is something that hoteliers need to be planning now as it comes into effect on 28 June 2025. In this article, we will explore how the new EAA will affect hoteliers, what the opportunities are and key insights from legal professionals.  

What to look out for in the new EAA law 

Complying with the EAA is a legal requirement, but it’s also an opportunity for hoteliers to embrace in 2025. One in four adults in the EU is living with a disability, which equates to around 101 million people. On average, around 70% of people in the EU who live with a disability can afford to travel and enjoy tourism, however, research shows that people with disabilities would travel more often if accessible options were available.  

Michelle Sally and Tom Sharpe, Partners specialising in Technology, IP and Data for TLT LLP, say the EAA is another strand to an increasingly complicated area of digital regulation. “There’s already a lot of digital regulation in effect, but there’s a wave of new regulations coming both in the UK and EU,” Sharpe said. “Given that, our clients are having to navigate an increasingly complex patchwork of regulation.” 

But what if there is a lack of compliance?  

If you do not comply, this could lead to a large fine and/or imprisonment depending on the country in which the non-compliance occurred. For example, if the non-compliance offence happened in Spain, this could result in a €600,000 fine whereas a similar non-compliance in Luxembourg could be up to €1,000,000. 

The importance of the EAA law not only stems from people with registered disabilities, but there are older guests and children who may have accessibility requirements and will benefit from the physical and digital accessibility features provided by hotels. Meeting the accessibility requirements outlined by the EAA has the potential to open up to a wider audience of guests to hotels, and as Tom Sharpe suggests, “in the offline world, there's rightly been a huge focus on accessibility and inclusion, and the EAA is bringing that ethos into the digital sphere.” 

So, what are the digital features hotels must be aware of to ensure EAA compliance? 

Unpacking the scope of the EAA 

Hospitality businesses may have conducted a similar mapping process in 2024 for the UK Digital Markets, Competition and Consumers Act 2024 (DMCC Act). With the new EAA law, Michelle Sally highlights that hoteliers should undertake a mapping exercise to identify all the digital touchpoints customers could potentially face for in-scope products and services. She explains that "in theory, anyone who has done the DMCC exercise can use that really good information they already have on digital touchpoint mapping, looking specifically at the user journey. It's not limited to just the purchase; it's the entire customer journey.” So, what happens next for the customer?  

Here are some tools and types of services hotels commonly provide that the EAA is likely to apply to: 

9 ways you can meet the EAA requirements  

Here are some of our best solutions that can be implemented to meet the requirements of the EAA for digital platforms:  

Digital platforms could support screen readers, which converts on-screen content into speech or Braille which is used by people with visual impairments. 

They could have intuitive navigation, consistent layouts, sufficient colour contrast, scalable fonts and alternative text for images. 

The consumer journey should be as streamlined and accessible as possible, including clear labels, error-tolerant forms, mobile payment options and accessible confirmation emails. 

Instructional visuals and videos could include subtitles. 

Have text descriptions as an alternative presentation of the content. 

Will be able to support simple, consistent, easy-to-read language. 

Users could be given the option to resize the text size and adjust the contrast of on-screen content. 

Digital content could be made available through keyboard navigation, so users do not have to rely on a mouse or other pointing devices. 

Include voice output and tactile controls can be used from a seated position.  

How to ensure you are compliant with the EAA 

Starting with a digital mapping exercise is the first step towards compliance with the EAA, as hoteliers need to categorically identify the entire digital ecosystem guests have interactions with. 

There are already internationally recognised standards in place, and hotels need to look towards these to ensure EAA compliance. This includes the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA, supplemented by the European standard EN 301 549. These guidelines define all the specific requirements for meeting accessibility standards. 

As Sharpe suggests, "if you've benchmarked yourself against those international standards, you're putting yourself in a really good place.” So, with the EAA coming into effect soon, it’s vital that you begin to identify any gaps in compliance. 

Managing your EAA compliance with ease 

As hotels typically work with external technology providers, tech partners will ideally support hoteliers with their EAA compliance. Sally explained that “it's a good opportunity to refresh contracts and get a sense of where you stand on liability with third parties who provide your tech.” She goes on to add that hoteliers should “internally document how you comply with this law, including any supply chain risk, in case the regulators ever come knocking.” 

Some member states in Europe may adopt additional regulations on top of the EAA soon, in particular in Italy where enforcement has begun ahead of the June 2025 deadline. As such, hotels need to be aware of which countries their websites and digital services are being accessed from by customers to ensure compliance with any country-specific nuances in relation to the EAA. 

Focusing on the benefits of complying with the digital accessibility standards is a good start. Sally adds that “there’s an expectation now that accessibility is the gold standard.” Sharpe also suggested that “from a business perspective, if you're not making the digital aspects of your business as accessible as possible, then you might be losing out on potential customers and consequently market share.” 

Your hotel EAA checklist  

Hotels that are in the scope of the EAA may need to take the following steps to ensure compliance with the EAA before 28 June 2025. Here is our EAA checklist to get your hotel ready for the latest changes:  

Ready to take on your EAA compliance with Access Hospitality? 

Ensure your EAA compliance is strong from the start with a range of hotel software solutions at Guestline and SHR, now part of Access Hospitality. They have all the accessibility features covered by the EAA built into its products including the Direct Booking Manager (DBM), self-service software, digital experience platforms and automated PMS communications.  

Our recent updates include enhanced keyboard navigation, improved focus indicators for visually impaired users and dynamic content that is fully interpretable by assistive technologies. This enables every guest interaction to be as smooth and inclusive as possible. 

Want to find out more? Explore our digital marketing suite and booking engine solutions to get EAA-ready.