- Good morning everyone. We're just waiting for everyone to join the webinar today. I'll give it a few more minutes. Good morning or afternoon or evening, wherever you're joining us from. We're gonna begin momentarily. My name is Stefani Cuschnir. I am part of the business development team here at TPGi. I am appreciative of everyone joining our webinar today. I'm gonna give it about one more minute as people are still joining, and then we'll get started. I do have a few housekeeping items to go over. Okay, well, it is 10 o'clock on the nose, Eastern time, and so thank you everyone again for joining us. This is the Accessible Consumer Products and Services for Europe. Countdown to EAA, European Accessibility Act 2025 with Mitchell Evan.

- Hello.

- Hi, Mitchell. I am going to just make a few comments about our housekeeping items and then we'll get started. For everyone to know, this session is being recorded and we will email everyone a recording after the event. We do have captions available, so feel free to use them as needed. We will have time for live Q and A at the end. Please use the Q and A box and we will answer as many of the questions as we can at the end of the presentation. If you put your questions in the chat, I will try to keep an eye, but they may get missed that way, so please try to use the Q and A box. Lastly, I'd also like to mention, if anyone needs any accessibility support training or usability testing, you can connect with us at tpgi.com or info@tpgi.com. With that, I will let Mitchell get started and provide an introduction of himself.

- Thanks, Stefani. Hi, my name's Mitchell Evan. I'm in Germany, Berlin. My colleagues and our clients and their customers are all around the world, including Europe. In addition to the questions as they come, we won't be taking questions during the call but at the end, but I would also love to hear just where people are and where your customers are. We may be all over the world. People who work in one place and have customers in other places, it's certainly part of what the EAA, the Accessibility Act is about. I'm a former front-end web developer. 12 years ago, I switched 100% to digital accessibility, and I've been living in Berlin, Germany for the past three years. I'm also a member of the W3C Accessibility guidelines working group, where my work is primarily in the WCAG to ICT task force. And that, will actually touch on that briefly in this webinar today. So today's agenda is pretty simple. What is the EAA? How to prepare for it, and what changes to expect compared to what we've already been doing with accessibility. I'm gonna give a perspective on the relevant technologies and the people who use them, especially for the EAA. It's not an in-depth perspective on the legal aspects, and that's certainly not specific legal advice about what is in European law. So the European Accessibility Act it's actually a European Union directive on the accessibility requirements for products and services. That's simply its name. It applies to the private sector as opposed to the public sector government that we already have in Europe. And what does it apply to, specifically? The writers of the EAA chose to regulate a specific set of consumer services and products that would otherwise be at risk of fragmenting accessibility standards across the EU. So it's not everything in the public sector, it's these specific industry sectors and products. The regulated services. The services are consumer banking, e-commerce, transportation by air, rail, water, and bus, TV and video streaming and ebook publishing. So they're targeting these specific industry areas. It also slightly dependent, but slightly independent of that list is particular hardware devices, hardware products, automated teller machines, ATMs, payment terminals that can be at any physical point of sale, not just the listed industries. Self-service kiosks. For this list of industries, that would commonly be transportation would probably be the most common, but it could be any of these. And so those first three, that's what we call self-service terminal devices. Now we get to personal devices, connected televisions, e-readers, phones, computers, and operating systems. And finally, all of the online information and apps that pertain to all of those hardware devices, probably the personal ones. And so there's a lot to this. There's some nuance to the scope. And if you wanna get that nuance, I actually recommend just reading article two of the EAA itself. And I know this deck has been shared, so there's a couple links in it. If that hasn't come through, you can respond to the invitation for this webinar, if you haven't received that already prior to the start of the call. So does a new European accessibility directive matter? On the one hand, regardless of the EAA, your users already need access wherever they are in the world, and Europe already has other accessibility laws, human rights laws in particular are universal, that protect and guarantee equal access for people with disabilities. So why the EAA? Yes, it does matter for a couple of reasons, and these are the ones that I'll highlight, is it clarifies technical measures of accessibility for the European single market. And the way it does this is moving faster, really, than many other regions of the world. It also definitely increases enforcement, it makes it really specific what happens if you don't do it in every European country. And this is happening as of June 28th, 2025. Check our watches. It's just under two years from now, so we're really coming right up. And I think this combination of things is really why we're starting to see global brands like clients of ours, a large retailer, a major video streaming company, really taking notice and taking vigorous steps to get ready for this deadline. So probably what is most of interest to a lot of folks on this webinar is how to prepare. Before we get into the details, I'm gonna step back to take a much bigger picture of what it means to prepare. And I have a picture of a chart we call our accessibility maturity model. It's similar to the W3C accessibility maturity model. And I'm not gonna get into a lot of detail here, but just to make the point that accessibility is always a journey. It takes investment of time and effort, which pays off, and we like to call that pay off "the return on accessibility." That's a great way to think about it. And perhaps some folks attending here, this may be the very first step on anything you've done for accessibility. You're at level zero. Or maybe you're well on your way and you're starting to see those returns on your investments curve upward. I'm happy to say that from my experience at TPGi, I and my colleagues can engage with organizations anywhere on this journey, from certainly audits are very common at the beginning level, and then we can advance into training and strategy and being a partner with companies and organizations to start to see those benefits. Now, what does this have to do with EAA? It has everything to do with EAA because the good news is you might have already started and not know it. Any work you're doing now on accessibility is already giving you a strong headstart on the EAA. For example, let's say you're basing your accessibility program on WCAG, the Web Content Accessibility Guidelines as a key measure. Or you might be focused on the US public sector with Section 508. Or the European public sector with EN 301 549 standard. There are also some other region specific and technology specific standards in the world, any of those. And lastly, but definitely not least, you might be making inclusive design central to your program, meaning designing by and for all users, including people with disabilities. These are all great ways to make progress on accessibility. You're doing the right thing for your users, and in doing so, you're doing the right thing for EAA. So you may not be starting from scratch even if you've never heard of the EAA before. Having said that, it should come as no surprise, the most relevant currently available accessibility standard for Europe is EN 301 549. EN stands for European Norm. And the current version is 3.2.1. In fact, you could meet European accessibility regulations with other methods other than this, but only the EN gives you what is called a presumption of conformity. If you conform to this standard, by definition, you conform to the technical requirements of the laws and regulations in Europe. Today, it's recognized this way for the European public sector with the web accessibility directive. And the European standards organizations that create the EN have already said they will use it as the basis for the EAA presumption of conformity in the private sector as well. So by looking at the EAA, we're really gonna be looking at the EN 301 549 quite a bit today. It was first published in 2015. But for some people here it might be new so I'll describe it in comparison with other common accessibility standards, starting with WCAG, Web Content Accessibility Guidelines. Comparing these two, how they apply to websites, documents, and software, it's super simple. With very few exceptions, the EN is simply a copy of WCAG 2.1 level A and AA criteria. Beyond WCAG, the EN adds some more requirements, but those additions are not just for Europe. Some are more familiar with the US Section 508 standard, and the additions beyond WCAG in EN 301 549 are quite similar to those in the US. They're not identical, but they are intentionally harmonized between the US and Europe by the folks who created the EN. Most relevant to EAA are... And these are examples. We're not gonna go through every criterion, but these are really highlights, platforms for software, platform compatibility. Quite a few criteria. One prominent one is honoring users' operating systems settings for accessibility, something that is not strictly in scope for the web. For hardware, criteria include hearing aid coupling with phones, clear visibility of text and icons, and supporting users with limited reach, manipulation or strength to interact physically with the hardware. All formats of electronic documentation and support services for products like chat and phone must be themselves accessible and they must provide information about accessibility for users of those documentation and support services. So if you're familiar with Section 508 or EN 301 549, you'll know that... Or if you're new to one or the other, you've just learned about the other because they overlap and are harmonized significantly in these areas. Finally, on the topic of what is EN 301 549 today, I'll round out some relevant criteria that are available in the technical standards. EN adds a handful of requirements that are not in the US Section 508. These requirements apply to features present in some websites, software and hardware. And there's features such as video players, two-way voice communication. For example, online meetings like the one we're on now, phone devices, smartphones, game consoles, that would all be two-way voice communication. Another example is biometrics built into any product, hardware, software, potentially web, that would identify the user of that product using biometrics. These all need to be designed in an inclusive way. And now I haven't hit every criterion, but I've hit the most prominent sections of the EN, the current EN, that are most relevant to EAA. So that's a really quick introduction. Now, we're coming up onto what's changing? What updates in the technical standards are we expecting to support the EAA? Unfortunately, we don't know yet exactly what's changing. We have the EAA text itself, but the technical standards organizations for Europe like Etsy, have only just now received their mandate, just a month ago in June 2023, and have just started work. However, we have a handful of public and private communications with these organizations, in large part through our collaboration at the W3C, and so I can make some good predictions. It's extremely likely that EAA will use the latest version of WCAG, version 2.2, level A and AA criteria. It's expected to reach W3C recommendation status in August, a month from now. And the WCAG working group, the AG working group, has been coordinating with the European standards organizations to complete the WCAG update 2.2 in time for the EAA. So it's not the only reason, but it is a motivator. So this is extremely likely to... Well, but hasn't happened yet. WCAG 2.2 is adding six new criteria at level A and AA, and actually removing one is marking it obsolete. In parallel, I mentioned that WCAG to ICT taskforce, where I'm a member, we're applying WCAG 2.2 to software and documents, saying how does it apply? What are ways to apply it? 10 years ago, in 2013, the most recent prior version of WCAG to ICT was significantly relied on in the crafting of the EN. So I would expect that that's gonna occur again. And it's also occurring in coordination right now with those standards organizations. So these are very safe. It hasn't happened yet, but I would say all of these, if you wanna see what might come in the next version of EN, you could look to these places. And so let's look at some other likely changes that are coming. In general, we've heard from the standards organizations that EAA is their priority for the next revision of EN. So if there's something in the EAA that addresses a specific technical area, then that's the area that we're most likely to see an update in the EN standard. I mean, yes, they could also make changes for other priorities that aren't the EAA, but this would be their first priority at this point. And here's some examples of those areas of overlap; ebooks and e-readers. And obviously, relevant to that would be the June recommendation status of the new EPUB Accessibility 1.1 standard from the W3C. I would expect that we'll see that referenced or incorporated into a European standard. Other areas where some kinds of updates I believe are likely are for phones, computers, operating systems, television equipment, self-service terminals. These are relevant to close functionality. Hardware in general or close functionality, specifically the sections of the EN. The documentation and support services. I can't say what would update, but I can say that the EAA has many requirements about documentation and support services, where I could anticipate they might add specificity, we don't know for sure yet. I'll briefly mention two others, although they're not exactly digital accessibility. The 112 universal emergency service phone number in Europe is part of the EN standard. The built environment standards are not part of the EN, but they will both certainly need standards updates in Europe to support specific EAA requirements for these. I'll mention that built environment applies to the listed services and it is voluntary by country. So a country may or may not. Unfortunately, we have not seen a lot of opting in for the built environment at this time. If a country does, they'll be asked to follow this particular standard. So, again, as I mentioned, to avoid fragmentation, a key goal of the EAA. When we look at hardware devices, hardware products specifically, all of these new requirements I'm mentioning are mostly in Annex 1 of the EAA. It has general requirements like perceivable and operable, but then it also has some specific ones, some rather specific ones. And for hardware devices, it's predictable that these are... Well, I would predict that these would need to appear in an EN revision because they're not there right now. One of the things that the EAA specifies is flexible time for interaction. This is familiar from WCAG, but it would be new to hardware. Another one like that, user control of audio speed. Similarly, EN already has volume control but not speed control of audio playback. These next two might be familiar if you're very familiar with the EN. Alternative to vocal input, using your voice to control software or hardware. And privacy while using accessibility features. We have these in the EN, but only as functional performance where they are advisory and the EAA appears to make them normative requirements. So I expect updates in all of these areas. And now for specific, we talked about hardware, now we're talking about on the services side. Annex 1 also has for specific service sectors, it has some new requirements. I'm again, calling out the ones that look new. For banking websites and apps, the content needs to be understandable at the B2 language level. Very interesting. Not exactly a plain language requirement, but in that direction and sort of achieving some of the same intents. For e-commerce. E-commerce websites and apps need to provide information on the accessibility of the products and services being sold through the e-commerce. And these next few, you're gonna see this as a pattern. They're kind of like the documentation requirements, but they're actually like, you use this... A person who uses the e-commerce website wants to understand whether the product they're buying is itself accessible and that's gonna be a new requirement. Similarly, on the transport sector, websites and apps need to provide information on the accessibility of the transport vehicles and the built environment around them, train stations, bus terminals. Need to be able to go onto those websites and find out, can I use this transportation as a person with a disability? Video program guides or electronic program guides, EPGs, need to provide information on the accessibility of the video content on the platform. And finally, similarly ebooks do it a little bit differently. You can put metadata in the ebook itself that describes the accessibility of the content of that ebook. And all of these are required. Now, because each of these is industry sector specific, I don't know whether we'll see all of these added in the EN, which I don't know what the mechanism would be, to say, "hey, this is required but it's industry specific." But whether or not they're added to the end, the EN, they are still direct... Any of these that we've talked about, if they're not added to the EN, they are still direct requirements from the EAA itself. I think it would just be more convenient if we have the kind of formal technical and testable definitions that come when putting them into a technical standard like the EN. So we'll see, either way they will be required. They're included in the EAA. Now, that's it for the technical updates for today. I'm gonna move on to some process and... I'm not a lawyer, but I can talk about the accountability and process that the EAA places on content creators and manufacturers. Places clear responsibility on anybody doing business in Europe in these sectors and products. One type of responsibility is reports and disclosures. That's one of the mechanisms for enforcement. For the services sectors, that first column that I listed, this means adding a statement in the terms and conditions for the service, where you disclose publicly how you meet the accessibility requirements. For hardware devices, there's a bit more to it. You need to keep internal technical records of your accessibility, like what you've done and the results of your testing of your accessibility of your product. And separately, document where in the supply chain you've sold it to or bought it from. There, you'll see in a moment why that is. Which leads to an EU declaration of conformity. This is something that's not new or specific to accessibility, this is something that product companies must do. Both of these that I've listed have a five-year retention. So you don't need to publish these, these are on request, but you have to have them. And they're required for the familiar CE marking. Without the CE marking it's illegal to sell a product in Europe. So that means you don't have these things? Your product goes off the market, forcibly. That's a lot of consequence. So I think we're gonna have... Well, we've already seen a lot of serious attention because this is real. As we saw, if you think back to the technical requirements, they weren't gigantic changes from what we've seen before. This, in a way, is the bigger change. It says, yes, the good things you've been doing are now required. Congratulations. It will be regulators in each country. Each European country in June, 2025, will start responding to customer complaints. And as well, proactively monitor the market to enforce compliance, ensure compliance. And so these reporting techniques are one of the tools that will be accountable to those regulators in each country. Okay, that's a part of the how, now we'll talk about the who. Who are the responsible hard parties specifically for hardware? Okay, so I mentioned that on services, it's pretty clear. So it's generally quite clear. If you have a website, it's clear who owns it, and that's who is responsible for making it accessible and disclosing the level of accessibility. On the hardware side, there's a little more to it. First, there's the manufacturers of hardware products who are responsible to make the hardware product itself accessible and also responsible to prepare the reports and disclosures we talked about on the previous slide. However, there's another group of parties involved here, that's the importers and distributors. If you're one of these... And so you actually also have the responsibility to confirm that the manufacturer has provided you the required reports and disclosures and make sure that those are present. And this is very interesting, as an importer or distributor, if you functionally change the product or even just rename it, you become the manufacturer and become responsible for making it accessible and preparing these reports. So I mean, how you would do that if you just rename it, is you would really need to ensure not just that the sort of physical manufacturer handed you the report, but you really might wanna verify that as a distributor 'cause you're on the hook for that. So we've talked a bit about the how, the who, and now the when. I've mentioned the times already, but we'll kind of look backwards and forwards a little bit here. The timeline is moving fast. It's been four years since the EAA became law for the EU, then that began a six year rollout process. So it's already law, and it's said by these dates these things will occur. One of those things was, last year all EU countries were required to update their national laws to match the EU directive. It's not a hundred percent yet. There are some that are late and they're in hot water. That's been covered, I won't get into that today. But it's gonna all happen, there's no going back that this won't happen but we do have some lateness there. And now of course, as we've said, June 28th, 2025. Deadline's less than two years away for services and new hardware products to meet the EAA requirements. Grandfathered self-service terminals. So self-service terminals, not all hardware, just the things like kiosks and payment terminals that are already in use before June, 2025, can remain in use for another 20 years. But every new piece of hardware, including payment terminals that's put in place and every new or existing service must be accessible by the 2025 deadline. So that is the major update. Who's ready for action on this? There's a lot that we've covered, but it kind of boils down to some simple ideas. How to start. It's what we've seen over the years. I mean, if you want to read the entire EAA, you can add a lot of detail to this, but the big picture is that if we concentrate on building a great experience for our users, then you're doing what we need to do for the EAA and for all other global standards. Now, we can measure that as progress toward the EAA using the latest WCAG version 2.2 and the latest available EN 301 549. As you saw, this will cover the vast bulk of what the EAA has. You may want to look at the slides if you think that you fall into those particular categories of particular services that have a plus for the EAA. But big picture, if you're doing these things, building a great experience for users measured with the latest standards, you're doing the right thing. And if you haven't started at all for accessibility or there's a next step that you're ready to start, start it right away. We can do it together. I love partnering with companies in whatever step they're ready to do the next thing and so are my very dedicated colleagues. At TPGi, we love to help you succeed. So we're just at the half hour of an hour long schedule and we have time for questions and answers.

- So Mitchell, in the Q and A chat, there are a couple of questions if you wanna take a peek there.

- Yes, I've got it. I'll take them from the top. Since people have the option to put their name or not, or to remain anonymous, I will read the names of whoever puts it in. Nicholas Carlson asks, not all consumer banking services are covered by the directive. For example, pension and insurance is not covered. Should those services instead be seen as C-commerce if provided via the web or a smartphone? I think that meant to be e-commerce. It's interesting. I don't think anybody right now is the expert on deciding whether or not something meets the definitions of, I believe it's article one of the EAA. Questions like this I've seen come up frequently on conversations with the EU commission. And they say, defer to the national authorities on this or just read the EAA, it says it's clear enough. I don't think it's clear enough, I think this is a great question. And I don't think we know. There is a specific definition of e-commerce and it has to do with selling something... It basically says you sell things online. In a couple of sentences, it defines that in some way. So you could look at that and say, does a particular aspect of a pension or insurance company meet the definition of e-commerce? Yes, it might. You're selling something and then it could, I would think. But I'm not the expert on this, I don't think anybody's the expert on this answer right now. I think it's unfortunately gonna get determined by... A lot of people ask, would like to know what will the regulating authorities say? That's gonna have to be set by precedent, some of it, that's if it really exists in gray areas. Yes. The next... One moment. Marking. See if I did that. See if I know how to use Zoom here. Very good. Okay, so the next question comes from an anonymous contributor. Can you briefly state the difference between the EAA and the EN? That's a good distinction. So the EAA is a regulation which comes from the EU, the European Union. And then it gets transposed into laws by every country in the EU. So think of it as a law or a regulation. The EN is a technical standard and has been identified for the public sector as providing presumption of conformance to the regulation. That's a bundle of words, so I'll unpack that a little bit differently. The effect is that if you meet the EN technical standard, by definition or by agreement, it has been determined that that is all you need to do to meet the regulation. So that's the relationship between them. Also, another difference between them is just the way they're written. The EAA, the regulation is meant to be kind of permanent. So it's written in some ways to... It can be vague at times as to what you have to do to meet it. And it says there should be an agreed upon technical standard, please write one. So everything else I said about the EN is my strong, strong prediction that that will be the chosen standard for EAA, everybody says so. That becomes the definition of how you meet the EAA. I welcome other questions on that. It's an important distinction. Israel Duke asks, I know main topic, but do you know if Section 508 will update to match WCAG 2.2? Yeah, that's not a European question, but as we pointed out, companies are doing business around the world and with governments, with public sector, private sector. So I think any question about standards of large or small markets is relevant to each other. The answer that I will give, and this is not original, I'm not making this up, this is sort of consensus as I've heard it, is that Section 508 just moves rather slowly and it took them 10 years to update. It took them almost 10 years after WCAG 2.0 came out to incorporate it by reference into Section 508. So I think that eventually someday they will update Section 508. You can't not update it, but they tend to be on a much slower timeline. Next question is from an anonymous attendee. For e-commerce services, do only customer-facing apps need to be compliant with the EAA or are backend apps for vendors, do they fall under the scope of the definition of the EAA? My understanding, well, first I'll answer this two ways. First, directly answer it. My understanding is no, intranets, internal apps, business to business apps would not meet the definitions of the services covered under the EAA. I think that's a no. Again, read it carefully yourself if you think there might be some gray area, you wanna be on the right side of that. I'll answer it a little differently though, a little off of the question, is that in the private sector, intranets are covered. So government websites for their own employees and for each other. If you had an intranet or an intranet and it was private sector, then it would be. That wasn't quite the question, but perhaps there might be an e-commerce service that isn't covered by the EAA but is covered by the web accessibility directive for the private sector. So something to think about. Just because of the constraints of this platform, the way we're doing it, we don't have the chance to come back and forth here, but if anything that I'm asking, if you wanna have a follow on question, it looks like we'll have time for that. I'll mention now as well that you'll be able to communicate back with TPGi through the webinar communications you've already had, and ask follow up questions if you think of them later or if we don't have time today. I'm very happy to do that and engage with you in those ways.

- Mitchell?

- Yeah.

- Since you took a little break there in the questions, and I'm sure you'll get to the Q and A questions. There was one question in the chat from Isabella Roche, I'm not sure how to pronounce her last name. She asks if parking meters are included in this kind of accessibility regulation.

- That's an interesting question. I'm gonna think on my feet here. I haven't thought about that particular one yet. Parking meters that I see these days have point of sale capabilities. I know I can use my credit card or an app to pay. And so in that sense, yes. I doubt that an old coin operated one would meet it and there could be things in the middle that would be... If you are responsible for parking meters and want to bring us some examples and we'll have a chat about that, that would be interesting.

- I definitely think just on that topic, it's such an interesting question. There are so many apps now in cities that they use for parking.

- Yeah.

- That certainly would be included, wouldn't it?

- My hunch says yes, but the app for... Yeah, I have to go back and check. That might be a good follow-up question. Stefani, do we have a mechanism to communicate back out, like to give a follow up answer after this call?

- Yes.

- Because I'm curious to look into that.

- Yeah, we do. As long as the person puts their name, and Isabella did.

- Yeah. Apps connected with a point of sale. That's interesting question. I will say that it's not... Even though it's called transport, transport is specifically defined to common carriers of air, water, rail, and bus. So the fact that you're... I mean we love to have, let's say rideshare apps directly covered. It's not by the EAA. They still need to be accessible. One could still... A consumer could still complain and say, my civil rights have been violated by this. So like everything really to the public in Europe and many other countries, all the signatories of the UN convention on the rights with persons with disabilities. I mean, we all need to have everything accessible. But which of those things, which of those services like rideshare apps or things that don't meet the strict definitions of the EAA, which of those are gonna be regulated in this very proactive way? That's a shorter list right now. Okay. And I think that gets to this. I actually might have accidentally started answering this next question from anonymous. It says, for e-commerce services, do only... No, sorry, that was the one we just did. Next question from anonymous. Does a web overlay comply to meet these standards? So these days, overlay often refers to third parties that advertise inserting a single line of code in your website in order to make the website accessible or in order to make it comply with regulations. There have been both legal and technical challenges to this that make it look like there are zero overlays of that type today that actually deliver what they say. The overlay providers we've seen in their own legal terms and compliance, say they don't actually solve the problems that their advertisements say they solve. And so I'm gonna have to say, today that's a no. That I would not take an overlay and put it in and believe that we're done with accessibility for EAA, any other standards or any other regulations. And this is the last question we have for now. So folks have another question you've been looking to ask. I'll read this last one and then if you have any others, please give us a quick note. And I mean at this point, either the chat or the QA 'cause we're emptying the QA. If an organization is based in the US but offers services in EU locations, does EAA apply? Excellent question. And we could expand that to any place in the world, US or other places in the world that offer services in EU locations. So that's services. Well, I'm gonna answer for services and for hardware products. Hardware products is very easy to answer because the product is being sold into the EU. And if you pull out your phone or your phone packaging or any hardware device, you'll see it has these marks on it like underwriters laboratories in the United States and CE in Europe. Like the same product that's sold around the world, if you're legally allowed to sell the hardware product in Europe, it needs that CE mark. And in order to have that CE mark, it's gonna need to comply with the EAA when it's in these particular categories of hardware. So hardware is really cut and dry. So I think it's a little less clear what it means to offer services in EU from outside. I think that's gonna be interesting to find out. I can say that I've watched in Norway. Norway has a private sector web accessibility regulation, not public but... Well, both public and private. And I think in practice, they seem to be better at going out after.... But what do I mean by going after? That sounds antagonistic. It should be. It is, and it should be a process that doesn't result in fines and punishment, but results in fixing problems. And I think in practice, I think it would tend to be that a regulator in a particular country is going to tend to go after companies that are based in that country. But there's nothing in the EAA that says that that's what services means. It means services offered in that country. So I think there's some nuance to that. I think if you consider... Well, again, I think I'll go back to the original point, is that accessibility is required throughout the world. So if you're doing business anywhere in the world, you need to make things accessible. And for services like websites and apps, the requirements around the world are quite similar. There's not a lot that EAA adds or changes. So I mean, you need to be working on accessibility anyway. So I think it's at this point, this close to the deadline, I would say that if you feel as a service you are providing your service into an EU country, I would absolutely treat it as required. And if it turns out that it's not, well, you just did an excellent job of everywhere else in the world that you're doing business. And that's my answer. We have a couple more questions come in. Great. Are there any references that outline the overlap and differences between EAA, the other European law and WCAG? I think the other European law could refer to the web accessibility... Sorry, the web accessibility directive for private sector in Europe. That's the most commonly cited one. There are also national laws, could be also an aspect of this question. I haven't seen a different or better publicly available breakdown of the differences from some of those that I looked at here. See, the differences with WCAG that's also... I mentioned that, I'm not sure how to... There's many ways to answer this question. Difference between the law and WCAG. Well, okay, I'll answer the question kind of narrowly, but I don't know if I'm getting to the intent of it. Okay, I have looked at the EU, I've looked at individual laws, countries in the EU and outside of the EU everybody's referring to... If they're referring to any standard at all, they're either referring directly to a version of WCAG or they're referring to a national standard that itself refers to WCAG or incorporates WCAG. WCAG is pretty much universal, certainly for the web. Now, we get to things that aren't the web. We get to hardware, yeah, no, WCAG doesn't apply. So that maybe gets at the intent of the question. So it would be also questions of versions of WCAG, 2.0, 2.1, 2.2 are another variation of that question. And so if there's another aspect to this, it might be specific to some particular country or some particular product or service and we can break it down. But I think that's probably the overview you're looking for. Please let us know if there's a more specific question. And finally, what are the penalties for the companies not complying with EU regulations? I think the answer is that each country sets it. That each country regulates. I'm not aware of the EU commission itself somehow imposing penalties down onto the companies. It would be handled at a national level. And if you're doing business in a dozen EU countries, are you gonna have to deal with a dozen authorities? It looks like, yes. Just the trouble of dealing with those authorities might be disincentive to even push any lines. We just wanna do a good job and not have any of them bother you. Just as we said, make it accessible, make it work great for people with disabilities and not have to deal with the penalties. But if let's say, yeah, you know I need to make it accessible, but you need to convince somebody in your company that they should fund you and make it seriously. That'd be my suggestion is no, you don't... You not only don't want to get the penalties, you don't even want to have to engage with potentially multiple national authorities where you've egregiously not been accessible. That would be a mess. Predictions; we don't know. It hasn't happened yet, but that's what the EAA suggests. It says that it's the national authorities that would provide them and determine them as well. I think we haven't set the numbers. I don't know. Yes. Okay, I can add to that question in one way. It does say that the size of the penalties should be sufficient to motivate the companies to actually fix the problems, so they shouldn't be small. But it also doesn't set a billion euros and say we wanna put you out of business. The point of the penalties is to fix the problem, is to motivate companies to fix the problem. It should perform that action. I believe that's all that the EAA says about the size of the penalties. We don't have any other questions right now. I'm gonna take a quick look at the chat.

- No, other questions, Mitchell. Thank you so much. It was a really informative, I thought, webinar. Just thanking our attendees for being here today. If anyone needs any accessibility training, testing, testing tools, information about kiosks, I know Mitchell talked a little bit about self payment type devices or services around how to meet these regulations. You can schedule an appointment with our team on our website or email us after the webinar. And if that's it, I think we have a few minutes to give back to our audience here. A lot of thank yous and great webinar. Appreciate that. Thank you everybody.

- Very welcome. Take care.

- Bye-bye.