Gaming Industry Hub
The gaming industry's EAA obligations focus on in-game communications services and digital storefronts rather than gameplay itself. Where voice chat, messaging, and community features function as electronic communications services, they fall within EAA scope. Platform stores selling games also have obligations as e-commerce services.
- ›European Accessibility Act (Directive 2019/882)
- ›European Electronic Communications Code (EECC) — for in-game communication services
- ›EN 301 549 v3.2.1
- ›WCAG 2.2 Level AA (web/app storefronts)
- ›EN 301 549 Chapter 6 (Two-way voice communication)
- ›EN 301 549 Chapter 11 (Software/Apps)
- ›Game Accessibility Guidelines (GAG) — industry best practice
Compliance Requirements
In-Game Voice & Text Communications
Where games include real-time voice chat that functions as an interpersonal communications service (party chat, proximity voice, team comms), it must be accessible. This means: text-to-speech for incoming voice must be available as an option; speech-to-text for outgoing messages must be supported; and deaf/hard-of-hearing players must be able to participate equivalently without relying solely on voice. Push-to-talk must have a toggle (hold-free) option.
Game Menus & UI Navigation
Main menus, settings screens, in-game pause menus, HUD configuration, and inventory interfaces must be navigable via keyboard, controller D-pad, or switch access without requiring mouse/touchscreen precision inputs. UI elements must carry accessible labels for screen reader use in desktop/PC contexts. Font sizes in menus must be adjustable or at minimum comply with WCAG 1.4.4 (resize text).
Subtitle & Caption Support
All narrative dialogue, cinematics, and in-game voiced content should carry subtitles, with options for: font size adjustment, background opacity, speaker labels, and on-screen position. Subtitles should include relevant non-speech audio cues (e.g., explosion nearby, approaching enemy, ambient danger). This is best practice under EAA and essential for deaf/hard-of-hearing players.
Colour, Contrast & Visual Options
Games must not rely solely on colour to convey critical game state (health status, team membership, map objectives). Colourblind modes (protanopia, deuteranopia, tritanopia simulation) must be available in settings. UI contrast for menus and HUD must meet at least WCAG 3:1 for large text, 4.5:1 for standard text where text is critical to gameplay.
Input Remapping & Motor Accessibility
Full control remapping — for all buttons, triggers, and axes across keyboard, mouse, and controller — must be available so players with motor impairments can configure controls to their needs. Aim assist, auto-sprint, hold-to-press toggle conversions, and adjustable timing windows for quick-time events support players with motor impairments. Switch access (single or two-switch scanning) support is best practice.
Digital Storefront Accessibility
Platform storefronts (console stores, PC game launchers, web storefronts) must meet WCAG 2.2 Level AA as e-commerce services under EAA. Game listings must carry structured accessibility metadata (subtitles available, remappable controls, colourblind modes) so players can make informed purchase decisions. Purchase and download flows must be keyboard- and screen-reader-accessible.
Cloud Gaming & Streaming Services
Cloud gaming platforms that stream gameplay to browser or app must ensure: the streaming interface and launcher are WCAG 2.2 AA compliant; accessibility settings configured in the cloud environment persist for the user; latency management does not disproportionately degrade the experience for users relying on switch access or alternative input devices.
Practical Steps to Compliance
- 1
Audit your in-game chat system — does it qualify as an interpersonal communications service under EECC?
- 2
Implement full subtitle support with size and background customisation as a minimum viable step
- 3
Add colourblind modes to your game settings — test with the three major deficiency types
- 4
Implement full control remapping for keyboard, mouse, and each supported controller
- 5
Review your game storefront page against WCAG 2.2 — focus on the purchase and download flow
- 6
Add accessibility feature metadata to your game's store listing
- 7
Consult the Game Accessibility Guidelines (gameaccessibilityguidelines.com) for broader best practice
Exemptions & Proportionate Burden
Indie developers qualifying as microenterprises are exempt from product accessibility requirements. However, platform storefront operators serving EU consumers cannot rely on this exemption and must ensure their marketplace is accessible. The exemption applies to the game product, not the communications service embedded within it.
Recommended Tools for This Sector
These AccessibilityRef tools are specifically relevant to your compliance needs. Use them to test, assess, and document your accessibility posture.
Functional Performance Criteria
The 11 EAA fallback criteria — test that your game is usable without vision, hearing, fine motor control, and colour perception.
Open tool →Colour Blindness Simulator
Test game UI screenshots for colour-blind players — critical for any game using colour-coded information.
Open tool →Contrast Checker
Menu text, HUD elements, and subtitle text need sufficient contrast against game backgrounds.
Open tool →Touch Target Tester
Mobile game UI elements must meet minimum touch target sizes for players with motor impairments.
Open tool →Software Checklist
Native game applications must meet EN 301 549 Chapter 11 — accessibility API, keyboard navigation, screen reader support.
Open tool →Generic ICT Checklist
Gaming hardware (controllers, consoles) must meet EN 301 549 Chapter 5 — biometrics, operable controls, accessibility activation.
Open tool →Video & Media Checklist
Cutscenes and in-game video content need captions and audio description.
Open tool →Support & Documentation Checklist
Game documentation and support channels must be accessible — EN 301 549 Chapter 12.
Open tool →Important Legal Disclaimer
This tool is a self-assessment aid only and does not constitute legal advice or a formally certified compliance assessment. Outputs — including reports, scores, checklists, and accessibility statements — are for internal use and should be reviewed by a qualified legal representative or independent accessibility auditor before being relied upon for regulatory, procurement, or public-disclosure purposes. All assessment risk lies with the internal assessor. accessibilityref, its developers, and staff accept zero liability for losses arising from use of or reliance on these outputs. Always verify against official sources: the W3C WCAG 2.2 Recommendation, the European Accessibility Act (Directive 2019/882), and your national enforcement authority.