The European Accessibility Act for documentation teams
The EAA has applied since 28 June 2025. Most of the coverage aimed at product teams; very little of it explained what it means for the people who write the documentation.
What it covers
Directive (EU) 2019/882 sets accessibility requirements for a defined list of products and services placed on the EU market. The services side is the part that reaches documentation teams: e-commerce, consumer banking, electronic communications, transport services, e-books, and access to audiovisual media services.
The requirement is not only that the service itself is accessible. It extends to the information about the service — the instructions, the support content, the explanations of how to use it. If your company sells a service in scope, the help centre that explains it is inside the boundary.
The standard in practice
The directive is written in outcomes rather than in a specific version of a technical standard, but the harmonised European standard EN 301 549 is what conformity is assessed against, and its web chapter incorporates WCAG level AA. In day-to-day terms: WCAG AA is the bar.
Micro-enterprise relief, and its limits
Enterprises with fewer than 10 employees and turnover or balance sheet under €2 million are exempt from the service obligations. That is a narrow exemption: it does not scale with revenue alone, it does not cover products, and it is measured at the enterprise level rather than the team level.
Disproportionate burden is a documented argument, not a shrug
The directive allows a provider to claim that full conformance would impose a disproportionate burden. The claim has to be assessed, documented, and re-assessed periodically — and authorities can ask to see it. In practice, preparing that documentation costs about as much as fixing the mechanical failures, which is why most teams end up fixing them.
What this means for a Confluence help centre
If your help centre or knowledge base is published from Confluence, or exposed through a Jira Service Management portal, the accessibility of that content is in scope for the service it documents. The specific failures are the ordinary ones:
- Screenshots without alt text, in step-by-step instructions where the screenshot is the step.
- Headings applied by making text bigger and bolder rather than by using heading levels.
- Tables of plans, prices or limits with no header row.
- Status colours — green for available, red for unavailable — with no text saying so.
- “Click here to contact support”, repeated on forty pages.
A defensible position
Nobody expects perfection on a corpus of ten thousand pages. What holds up under scrutiny is a demonstrable process: you know what you have, you measure it on a schedule, the mechanical failures are being closed, the human-judgement items are being reviewed, and you can produce a dated report showing the trend. That is the difference between a finding and a fine.