Does the European Accessibility Act Apply to Your Website?

A client forwarded an email warning that “the European Accessibility Act is now law and your website must comply or face fines”. A plugin vendor is selling an “EAA compliance” widget. Or you sell online to customers in Europe and want to know, calmly, whether this applies to you and what you actually have to do.

This guide explains the European Accessibility Act (EAA) in plain English: what kinds of websites it covers, who is exempt, what standard is used to judge compliance and what a sensible plan looks like for a small business or the designer looking after its site. This is not legal advice. The EAA is a directive, which means each EU country writes its own national law to implement it, with its own authorities, deadlines for complaints and penalties. Where national rules matter, this guide says so, and you should check locally with a qualified adviser or the national authority.

What is happening

The EAA is Directive (EU) 2019/882 on the accessibility requirements for products and services. EU member states had to apply their national rules from 28 June 2025. From that date, covered products placed on the EU market and covered services provided to consumers must meet accessibility requirements set out in the directive’s annexes.

The directive covers a fixed list of products and services. It is not a general rule that every website must be accessible. For websites, the services that matter are:

Service in scope	What it means for a website or app
E-commerce services	Selling to consumers at a distance through a website or app, with a view to concluding a consumer contract. This is the one that catches most online shops, including WooCommerce stores.
Consumer banking services	Banking, credit and payment services offered to consumers, including their websites and apps.
Passenger transport services	Websites, apps, e-tickets and travel information for air, bus, rail and waterborne passenger transport.
Electronic communications services	Phone and internet services and their websites and apps.
Access to audiovisual media services	Websites and apps that give access to TV and streaming services.
E-books and dedicated software	E-books and the software used to read them.

Products in scope include computers, smartphones, self-service terminals such as ticket machines and payment terminals, and e-readers. If you only run a website, you can usually ignore the product side.

A brochure site that describes your services and has a contact form is generally not an e-commerce service under the directive, because nobody concludes a contract through it. A site that takes bookings and payments from consumers, or sells products, probably is. Gray areas, such as booking engines run by a third party or quote forms that end in an online contract, are exactly what to ask an adviser about.

Before you start

• You need rough figures for staff headcount, annual turnover and balance sheet total, and a list of the countries where you sell to consumers.
• Tools: a desktop browser with DevTools, a keyboard, and optionally a free automated checker such as the browser extension from a well-known accessibility testing vendor or Lighthouse in Chrome. The DevTools cheat sheet shows how to open Lighthouse.
• A healthy skepticism. Emails threatening immediate fines and products promising instant compliance are sales tactics. See scary emails about your website.

Step 1: Decide whether you provide an in-scope service

Answer three questions honestly.

1. Do you sell to consumers? The directive is about services to consumers. A shop that sells only to businesses, with checks that buyers really are businesses, is generally outside the e-commerce definition. A shop open to anyone is not “B2B only” just because most buyers are companies. National laws can draw this line differently, so check locally.
2. Do consumers in the EU use it? The directive applies to services provided in the EU. Businesses based outside the EU that sell to EU consumers can be covered. Whether a particular non-EU shop is “providing services” in a given country is a legal judgment to make with an adviser.
3. Is it on the list? Selling goods or services online to consumers, consumer banking, passenger transport, communications, audiovisual access or e-books. Plenty of websites, such as a local tradesperson’s brochure site or a blog, are not on the list at all.

If the answer to any of the three is no, the EAA probably does not apply to that site, though other laws may: public sector bodies have separate EU web accessibility rules, and many countries have equality or disability laws of their own. In the US, accessibility complaints come under different laws entirely; see accessibility complaints and demand letters.

Step 2: Check the microenterprise exemption

The directive exempts microenterprises that provide services from the accessibility requirements for those services and the obligations linked to them. The directive defines a microenterprise as an enterprise that employs fewer than 10 persons and has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million.

• Both parts matter: fewer than 10 people and at least one of the financial figures at or under EUR 2 million.
• The exemption covers services. Microenterprises that make or import products in scope are not exempt in the same way, though some of their obligations are lighter: for example, they do not have to document a disproportionate burden assessment, but must give the market surveillance authority the relevant facts if it asks.
• How staff are counted (part-time staff, linked or partner companies) follows EU rules on enterprise size; check your national authority’s guidance for the details. Some national authorities have published guidelines for microenterprises, and the Commission was required to provide guidance too.
• Being exempt is not a reason to ignore accessibility. Customers who cannot use your checkout still go elsewhere, and if you grow past the thresholds the duty applies.

Designers and agencies: the exemption is about your client, not about you. A micro agency building a shop for a client with 50 staff is building an in-scope service.

Step 3: Know the yardstick

The directive sets functional requirements in its annexes: information must be perceivable, operable, understandable and robust; websites and apps must be accessible in a consistent and adequate way; and the service must provide information about how it meets the requirements. It does not itself list technical checkpoints.

In practice, the European standard EN 301 549 is the yardstick. Its web requirements align with the Web Content Accessibility Guidelines (WCAG) at Level AA. Meeting a harmonized standard referenced for the EAA gives a presumption of conformity. Which version of EN 301 549, and therefore which version of WCAG (2.1 or 2.2), is formally referenced for the EAA at the time you read this is worth checking, because a revision aimed at the EAA has been in progress. The European Commission publishes the list of harmonized standards referenced for the EAA. If you build to WCAG 2.2 Level AA, you cover WCAG 2.1 AA as well.

The practical takeaway: test against WCAG 2.2 Level AA and fix what fails. The fixes are the same ones covered in this site’s accessibility guides:

• keyboard navigation, focus and skip links;
• color contrast and readability;
• images, icons, links and buttons for screen readers;
• accessible forms, error messages and CAPTCHA.

Step 4: Test the journeys that matter

For an online shop, the EAA is about whether a disabled consumer can find a product, understand it, buy it and get help. Test those journeys end to end, not just the home page.

1. Keyboard only. Put the mouse away. Press Tab from the top of the home page. Can you reach the menu, search, a product, the add to cart button, the cart, every checkout field, the payment step and the order confirmation? Is it always clear where focus is?
2. Zoom to 200 percent and narrow the window. Text must remain readable and nothing essential should be cut off or require sideways scrolling.
3. Run an automated check on each page type: home, category, product, cart, checkout, account. In Chrome, open DevTools, the Lighthouse panel, check Accessibility and run it. Automated tools catch a minority of issues, such as missing labels, contrast and missing alt text, so a clean score is a start, not proof.
4. Check third parties. Payment pop-ups, cookie banners, chat widgets and review widgets are part of the journey. If a payment iframe traps keyboard focus, raise it with that vendor and keep their response.
5. Try a screen reader on checkout. NVDA on Windows and VoiceOver on Mac and iPhone are free. Listen for unlabeled fields and error messages that are only shown in color.

Record what you tested, when, with which tools and what you found. That record is the start of the documentation the directive expects.

Step 5: Publish the information the directive asks for

Service providers must make information available about how their service meets the accessibility requirements, in the general terms and conditions or an equivalent document, in an accessible form. For a website this usually becomes an accessibility statement page linked from the footer, covering:

• a general description of the service in accessible formats;
• how the service meets the requirements, and the standard you test against;
• known limitations and what you are doing about them, with target dates;
• how to contact you about a barrier, and an alternative way to buy or get help;
• the national authority responsible for enforcement in the relevant country (each member state names its own).

Keep it honest. Claiming full conformance after one automated scan is riskier than describing real progress.

Step 6: Decide what to fix first

Fix in order of impact on a consumer completing a purchase:

1. Anything that blocks checkout completely: keyboard traps, unlabeled payment fields, CAPTCHAs with no accessible alternative, timeouts with no warning.
2. Navigation and search: menus that only open on hover, search with no label, focus that is invisible.
3. Product information: images with no text alternative where the image carries information, low contrast prices, color-only stock or size indicators.
4. Content and help pages: headings in a logical order, link text that makes sense out of context, accessible PDFs or HTML alternatives.

Overlay widgets that promise one-line compliance do not fix underlying code, and accessibility specialists widely criticize them; the accessibility complaint guide explains why.

Step 7: Understand the transition rules and exceptions

• Existing contracts. The directive allows service contracts agreed before 28 June 2025 to continue unaltered until they expire, but for no longer than five years from that date, so not beyond 28 June 2030. This mainly matters for long-running service contracts, not for a shop’s next sale to a new customer.
• Disproportionate burden. A provider can claim that meeting a requirement would fundamentally alter the service or impose a disproportionate burden, but must make and document an assessment using the criteria in the directive, keep it, and renew it. The bar is high, and there are rules on informing the authority when you rely on this, so check what applies where you operate.
• Content you do not control. The directive’s web requirements focus on the service you provide. Third-party content, archived content and pre-recorded media may be treated differently in the standards and in national law, so check the rules where you operate.

Advanced: what enforcement looks like

Each member state designates authorities to check that services comply, handle complaints, and order corrections. Penalties are set nationally and must be effective, proportionate and dissuasive; the amounts and the process differ by country, so check the national law where you operate. In practice, early enforcement tends to start with complaints and requests to fix, but do not rely on that. If you receive a letter from an authority, read the deadline, reply in writing, and get advice from someone who knows that country’s implementing law.

Designers: put the EAA question into your discovery process. Ask new shop clients about staff numbers, turnover band and where they sell. Write the agreed accessibility target (for example WCAG 2.2 AA for the purchase journey) into the proposal, and price testing and fixes as part of the build. Third-party themes and plugins that publish accessibility conformance reports make that promise much easier to keep.

If none of that answers your question

Where you are unsure whether you are in scope, or whether the exemption applies, ask:

• the national authority or business support service in the main country where you sell, many of which publish EAA guidance for small businesses;
• a lawyer familiar with consumer and accessibility law in that country;
• your trade association, which may already have taken advice for your sector.

Bring your test results, a list of the third-party services in your checkout, and your headcount and turnover figures. If the problem is a specific barrier a customer reported, start fixing it now: that is useful whatever the legal answer turns out to be. The official text is published on EUR-Lex as Directive (EU) 2019/882.