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European Accessibility Act: Email marketers, don't wait until June 28th 

The European Accessibility Act will make accessible email design mandatory starting June 28, 2025. Discover common pitfalls and the steps needed to build campaigns that fully meet the new standards.

Naomi West
Naomi West
Sr. Product Marketing Manager
European Accessibility Act

The European Accessibility Act (EAA) takes effect on June 28th, 2025. For email marketers, accessibility is no longer a nice-to-have. It's a legal requirement. And the latest data is clear: according to the Email Markup Consortium’s 2025 Accessibility Report, 99.89% of email campaigns contain serious or critical accessibility issues.

Out of 443,585 emails analyzed, only 21 passed all automated accessibility checks. That’s fewer than 0.01% meeting even basic accessibility standards. Are your emails passing the accessibility benchmarks? Now is the time to evaluate.

Compliance isn’t optional

The EAA isn’t just another guideline—it’s enforceable legislation that applies to any business offering products or services in the EU, regardless of where that business is located. The stakes are significant:

  • Substantial fines: Each EU member state sets penalties, with fines and sanctions varying by country and severity
  • Market restrictions: Regulators can limit a company’s ability to operate in the EU until accessibility issues are resolved
  • Legal liability: Customers can file formal complaints and lawsuits for inaccessible communications

With the exception of microenterprises with fewer than 10 employees and under €2 million in annual turnover, all other businesses are under the EAA's compliance umbrella. The message is clear: either make your emails accessible or face the potential consequences, which include substantial fines, market restrictions, and legal liability.

The current state of email accessibility: A crisis in numbers

The Email Markup Consortium’s 2025 report reveals the magnitude of the problem facing email marketers:

Critical issues (60.66% of emails)

  • Missing alternative text for images
  • VML elements without proper accessibility attributes
  • Links inside VML that can't be navigated with keyboards
  • Inappropriate use of role="button" on anchor tags

Serious issues (39.23% of emails)

  • Content missing language and direction attributes (affecting 98% of emails)
  • Layout tables without proper role attributes (86%)
  • Links without discernible text (72%)
  • Insufficient color contrast (59%)

Unfortunately, it’s even more concerning that both the education (.edu) and government (.gov) domains—sectors where accessibility should be the gold standard—showed 100% failure rates in accessibility testing.

What should email marketers do now?

The EAA aligns with Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, which require content to be perceivable, operable, understandable, and robust. Here’s what compliance means in practice:

1. Text and structure

  • Use clear, simple language with logical content hierarchy
  • Implement proper heading tags (H1, H2, etc.) for screen readers
  • Choose legible fonts (14px or larger) with high color contrast
  • Ensure dark text on light backgrounds meets contrast ratio guidelines

2. Images and visual content

  • Provide descriptive alt text for all meaningful images
  • Use empty alt attributes (alt="") for purely decorative images
  • Avoid embedding critical information in images without text alternatives
  • Include textual descriptions for animated content

3. Color and design

  • Don’t use color alone to convey information
  • Ensure a strong contrast between text and background
  • Avoid flashing content that could cause seizures
  • Design layouts that support high contrast mode

4. HTML structure and navigation

  • Use semantic HTML tags appropriately
  • Set language attributes on HTML elements
  • Include direction attributes for proper text flow
  • Ensure keyboard navigation works for all interactive elements
  • Write descriptive link text instead of generic phrases

5. Responsive and mobile design

  • Create fluid layouts that work with screen magnification
  • Test emails across different devices and screen sizes
  • Ensure touch targets are large enough for users with motor difficulties

Introducing Customer.io’s Design Studio

Recognizing the urgent need for accessible email design, our Design Studio, available within Customer.io, takes an accessibility-first approach. It’s designed to be as inclusive as possible, even beyond automated checks. In fact, Design Studio’s comprehensive accessibility checker evaluates emails against both standard AXE 4.3 rules and custom email-specific accessibility requirements.

How the accessibility checker works

The tool categorizes issues by severity: critical, serious, moderate, and mild. Then, it provides specific guidance for each problem.

  • Instant analysis: The checker evaluates your email HTML as you build
  • Detailed explanations: Each issue includes information about why it matters and how to fix it
  • Code-level precision: Click on any issue to locate the exact line of code that needs attention
  • Email-specific rules: Includes rules tailored for email clients, not just web pages

Key features for EAA compliance

Design Studio’s Accessibility Checker addresses the most common email accessibility failures:

  • Language and direction attributes: Ensures proper lang and dir attributes are set
  • Table role verification: Checks that layout tables include proper presentation roles
  • Link accessibility: Validates that all links have descriptive, accessible text
  • Image alt text: Verifies that all images include alternative text
  • Color contrast: Analyzes text-to-background contrast ratios

Going beyond compliance

Maintaining compliance is not only legally responsible, but it’s good for your readers and also good for business. By ensuring you’re not alienating a substantial portion of your readers, you can expand your audience. If your emails are easy for anyone to read and interact with, you’ll likely see higher click-through rates and conversions.

Features like clear structure, readable fonts, and descriptive links benefit all users, not just those with disabilities. Accessibility also enhances brand reputation by demonstrating a commitment to inclusion and customer care, which works to strengthen loyalty and trust. Finally, accessible emails tend to perform better technically, rendering more consistently across different email clients thanks to standardized HTML and the avoidance of problematic coding practices.

Your EAA compliance roadmap

With June 28th rapidly approaching, here’s what email marketers should do immediately.

Audit current templates

  • Run existing email templates through accessibility checkers
  • Identify the most common issues in your email designs
  • Prioritize fixing critical and serious accessibility barriers

Update design systems

  • Modify email templates to include proper semantic HTML structure
  • Establish accessible color palettes with sufficient contrast ratios
  • Create guidelines for writing descriptive alt text and link copy

Train your team

  • Educate designers and content creators on accessibility requirements
  • Establish workflows that include accessibility checks before sending
  • Set up testing procedures using screen readers and other assistive technologies

Implement ongoing monitoring

  • Integrate accessibility checking into your regular QA process
  • Monitor engagement metrics to measure the impact of accessibility improvements
  • Plan for continuous improvement as standards evolve

Take action today

The European Accessibility Act represents more than regulatory compliance, it’s an opportunity to create truly inclusive email experiences that effectively serve all customers.

Tools like Customer.io’s Design Studio makes compliance achievable and seamless. By automatically identifying accessibility issues and providing clear guidance for fixes, these tools can help email marketers shift from reactive compliance to proactive inclusion. So, next time there’s an update, you are already one step ahead with your messaging.

The EAA deadline of June 28th, 2025, is non-negotiable. Many member states are expected to update their local laws before that. The question isn’t whether your email needs to be accessible—it’s whether you’ll be ready when the law takes effect. Start testing, start fixing, and start building email experiences that welcome everyone.

In the end, accessible email marketing isn’t just about avoiding penalties, it’s about ensuring that every customer, regardless of their abilities, can engage with your brand’s message.

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