Level Access

Author: Level Access

As they prepare to meet the June 2025 European Accessibility Act (EAA) enforcement deadline, many organizations are focusing on bringing their own digital assets into compliance. However, inaccessible third-party content used in consumer services—such as plug-ins and software integrations—can also expose organizations to regulatory risks.

But what exactly does third-party content mean, in the context of the EAA? How does the law apply to this content? And how can organizations make sure third-party resources don’t jeopardize their compliance efforts?

In this article, we’ll answer these and more questions about the EAA and third-party digital experiences, so you can plug any gaps in your approach to meeting the law’s requirements.

What is third-party content?

Third-party content refers to any digital information, product, or service that an organization does not create in-house, but makes available to users. This content may be funded by partners, developed by and purchased from vendors, or licensed from other external sources. It may include:

  • Audiovisual content: Certain types of videos, audio files (e.g., podcasts), and interactive media from third-party sources (e.g., YouTube and Vimeo) that are part of a service that is covered by the EAA. (Pre-existing pre-recorded media is exempt.)
  • Documents: Reports, e-books, PDFs, and forms created by external entities.
  • Widgets and plugins: Interactive tools such as chatbots, internal search engines, and social media feeds.
  • Software and applications: Learning management systems (LMS), e-commerce platforms, or cloud-based services integrated into a website or web application.
  • Third-party websites: External links leading to resources that may not be under an organization’s direct control, but that are required to use a product or service.

How does the EAA apply to third-party content?

Organizations are generally responsible for ensuring that all digital content, including content from third parties, meets the EAA’s functional accessibility requirements—but with some exceptions.

Third-party content that is neither funded by, developed by, nor under the control of an organization is exempt from EAA compliance requirements. If your organization does not purchase, contract for, or license the third-party content, it falls outside the EAA’s scope.

However, as soon as your organization pays for or has control over third-party content, you become responsible for its accessibility. That means the EAA covers content such as:

  • Third-party payment mechanisms integrated into an e-commerce platform.
  • Search widgets that filter products or services on a website.
  • Software tools and plugins used within your digital services.

Best practices for EAA-compliant third-party content

To ensure compliance, organizations must work closely with vendors or other third-party providers to confirm that their content conforms with accessibility standards. If a third party’s content is not accessible, your organization must either request improvements or find an alternative. The following best practices can help you get started aligning third-party tools and assets with EAA requirements.

1. Vet new vendors for accessibility

When selecting external vendors—whether for software or digital media—prioritize accessibility. If you’re purchasing a third-party digital product, request that your vendor provides a completed Voluntary Product Accessibility Template (VPAT®) documenting conformance with EN 301 549, the presumptive standard for EAA compliance. The VPAT should have good marks, indicating that the product meets accessibility requirements. Ideally, the VPAT will be created by a reputable, third-party provider, as this shows that the potential vendor is working with an accessibility expert.

In addition to requesting a VPAT, ask potential vendors for documentation that accessibility processes are in place so that new issues won’t be introduced.

If a vendor is unable to provide a VPAT, consider engaging an accessibility expert to evaluate the product you’re considering purchasing, using a demo environment. An expert can also help you review the accessibility of third-party media you’d like to incorporate into your digital experiences.

2. Audit existing products and content from third parties

While it’s best to validate that vendors and other content providers meet your accessibility requirements prior to procurement, chances are that you’re already working with many third parties. To comply with the EAA, you’ll need to make sure existing third-party content associated with your products and services is accessible.

With support from accessibility professionals, test tools and resources you’ve obtained from third-party providers for conformance with EN 301 549. This evaluation should include manual testing with assistive technologies, including screen readers and keyboard navigation, to surface potential barriers for users with disabilities.

3. Request accessibility improvements

Engage with third-party content providers and request that they address any accessibility gaps you’ve identified—whether based on the VPAT they provided or your own independent evaluation. Many vendors are willing to fix their products to meet buyers’ compliance needs, especially if multiple clients demand it, because it offers them a competitive advantage.

4. Find accessible alternatives

If third-party content you currently control, or intend to purchase, is not accessible—and the vendor or provider is unable to address barriers—the best course of action is to find an alternative solution.

Seek out other providers who offer a similar product or resource that meets accessibility standards. If you’ve already licensed or contracted for inaccessible content, you might want to look into terminating your relationship with your current provider. Consider communicating that accessibility issues were the reason for this termination. Your feedback may prompt them to prioritize accessibility in the future—in which case you can always rekindle the relationship.

5. Provide an equivalent, accessible experience if necessary

If using inaccessible third-party content is essential for your organization, and you cannot find an alternative provider that supports accessibility, offer an alternative way for users with disabilities to access the same information or functionality. Importantly, this workaround must provide an equivalent experience—meaning individuals who use it won’t miss out on any content or capabilities.

You should also add a clear disclaimer to inaccessible third-party tools or resources that informs users about their limitations and directs them to accessible alternatives.

Navigate third-party content accessibility with an expert partner

EAA compliance requirements extend beyond an organization’s internally created content. Ensuring that third-party products and resources conform with accessibility standards is essential to mitigating risk for your business. By proactively selecting accessible providers, auditing existing content, and finding accessible alternative solutions, your businesses can stay on track to meet the June 2025 enforcement deadline.

Evaluating the accessibility of third-party content—and determining next steps—can be complex. It’s a challenge best navigated in partnership with a trusted accessibility expert. With more than 25 years of experience, Level Access is well-positioned to help your organization ensure that its content—third-party or in-house—complies with global accessibility standards. To learn more about your obligations under the EAA and what you can do to achieve compliance, schedule a call with our team today.

FAQ

Does the EAA apply to all third-party content used by an organization?

No, the EAA does not apply to third-party content that is neither funded by, developed by, nor under the control of the organization. However, if an organization purchases, licenses, or integrates third-party content—such as payment gateways, search widgets, or other software tools—it becomes responsible for ensuring its accessibility. Additionally, pre-existing pre-recorded media is exempt from the EAA.

Organizations can ensure third-party content is EAA-compliant by taking actions including:

  • Choosing vendors that prioritize accessibility and provide conformance documentation (e.g., VPATs).
  • Conducting accessibility audits on third-party tools and content.
  • Collaborating with vendors to request accessibility improvements.
  • Offering alternative accessible formats if the original content is not compliant.

If a third-party provider’s content is not accessible, organizations should request accessibility improvements from the vendor and seek alternative providers that offer compliant solutions.

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