comparison
ACA vs EAA
ACA (Accessible Canada Act, Canada — federally regulated entities, 2019) and EAA (European Accessibility Act, European Union (all 27 member states), 2019) are two of the most-referenced accessibility frameworks in digital compliance. This guide compares them side by side — jurisdiction, scope, conformance approach, penalties, and how a single audit can cover both simultaneously.
What is ACA?
The Accessible Canada Act (ACA, 2019) requires federally regulated entities — federal government, banks, telecom, broadcasting, transportation — to identify, remove and prevent accessibility barriers, with the explicit goal of "a Canada without barriers by 2040" and detailed regulations layered on top including the ICT regulations referencing EN 301 549.
Maintainer
Accessibility Standards Canada
Jurisdiction and enforcement
Canada — federally regulated entities. Accessibility Commissioner; CRTC for telecom; CTA for transportation.
What is EAA?
The European Accessibility Act (Directive (EU) 2019/882) is the EU's prescriptive accessibility law that takes effect 28 June 2025, requiring covered products and services — banking, e-commerce, transport, audiovisual media, ebooks and computer hardware — to meet harmonised accessibility requirements derived from EN 301 549 and WCAG 2.1 AA.
Maintainer
European Commission
Jurisdiction and enforcement
European Union (all 27 member states). Per member state, via national transpositions.
ACA vs EAA — the key differences
The principal difference is jurisdictional: ACA applies in Canada — federally regulated entities, while EAA applies in European Union (all 27 member states). ACA is maintained by Accessibility Standards Canada; EAA is maintained by European Commission. The standards differ on scope, conformance grading, and penalty structure — but a well-designed accessibility programme can satisfy both simultaneously by adopting the strictest applicable requirement and cross-mapping findings.
Scope
ACA covers: Federally regulated workplaces, Federal services (incl. digital), Federally regulated transportation and telecom. EAA covers: Consumer banking services, E-commerce (B2C online sales), Air, rail, water, bus passenger transport, Audiovisual media services and devices, Electronic communications services, E-readers and ebooks, Self-service terminals (ATMs, ticket machines), Consumer computer hardware and operating systems.
Penalties
ACA: Administrative monetary penalties up to C$250,000 per violation. EAA: Germany: up to €100,000 administrative fine + suspension of service.
How to comply with both at once
Adopt the stricter applicable conformance level — typically WCAG 2.2 Level AA — as your engineering baseline. Audit against that baseline once, then cross-map findings to both ACA and EAA specific requirements. A single Accessibility Conformance Report (ACR) using VPAT 2.5 INT can document both.
When you might need just one
If you operate exclusively in Canada — federally regulated entities and have no cross-border procurement exposure, you may only need ACA. The same applies in reverse for EAA. For organisations selling cross-border, into the EU or US public sector, the safer default is to plan to both simultaneously.
Sources
- Accessible Canada Act — Government of Canada
- Directive (EU) 2019/882 (European Accessibility Act) — European Union
- EN 301 549 v3.2.1 — ETSI
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Is ACA stricter than EAA?
Neither standard is uniformly "stricter" — they cover different regulatory domains. ACA is more prescriptive about federally regulated workplaces; EAA about consumer banking services. For organisations exposed to both, a unified WCAG 2.2 AA baseline typically satisfies the technical requirements of both.
Can a single audit satisfy ACA and EAA?
Yes. Both standards ultimately reference WCAG-aligned criteria. A combined audit with cross-mapped findings can produce documentation acceptable to both regulators.
Which jurisdictions enforce ACA?
Canada — federally regulated entities. Accessibility Commissioner; CRTC for telecom; CTA for transportation.
Which jurisdictions enforce EAA?
European Union (all 27 member states). Per member state, via national transpositions.
What happens if I am not compliant with ACA?
Administrative monetary penalties up to C$250,000 per violation
What happens if I am not compliant with EAA?
Germany: up to €100,000 administrative fine + suspension of service France: up to €75,000 + daily penalty up to €3,000 Italy: up to €40,000 + product/service withdrawal Ireland: up to €60,000 / 18 months imprisonment Spain: up to €1,000,000 for repeat serious infringements
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