European Accessibility Act requirements for websites

What the European Accessibility Act is

The European Accessibility Act, or EAA, is Directive (EU) 2019/882. It sets common accessibility requirements for a list of products and services sold in the EU. The goal is simple: people with disabilities, older people and anyone using assistive technology should be able to buy, book and pay without being locked out.

Because it is a directive, it does not apply on its own. Each member state had to write it into national law by 28 June 2022, and the rules have applied since 28 June 2025. That is why you will see national names for the same obligations: the BFSG in Germany, loi n° 2023-171 in France, Ley 11/2023 in Spain. The core requirements come from the directive, but enforcement, procedures and penalties are national.

For most small businesses the question is not the whole directive. It is one narrower point: does my website, app or online shop count as one of the services the EAA covers, and if so, what do I need to change?

Does the EAA apply to my website?

The EAA works with a closed list. If your service is on the list and you offer it to consumers, it is in scope. If it is not on the list, the EAA generally does not reach it, even if accessibility is still good practice.

According to the directive's list of services, the following consumer-facing services are covered:

• E-commerce services: any website or app where consumers buy products or services, including the cart, checkout and payment flow.
• Consumer banking services, such as online banking portals and apps.
• E-books and dedicated software for reading them.
• Electronic communications services sold to consumers, for example messaging or internet telephony.
• Services giving access to audiovisual media.
• Air, bus, rail and waterborne passenger transport services, including online ticketing.
• Self-service terminals such as ATMs, ticket machines and payment terminals.

Who is generally outside the scope

Brochure sites. A plumber, an architect or a consultancy whose website describes services and offers a contact form does not run one of the listed services. Such a site is generally outside the EAA. Accessibility still helps clients and search engines, but the directive does not require it.

Pure B2B services. The directive's recital 11 says it should not apply to products and services provided by public sector bodies only to people acting in a professional capacity. That is a narrow carve-out, not a blanket B2B exemption. Practitioner guides read the consumer-services list as generally excluding tools used only by business staff, such as an internal SaaS dashboard. This reading is not settled in the text. If your B2B tool also lets consumers buy, that purchase flow is arguably in scope.

Microenterprises providing services. The directive exempts microenterprises that provide services from the accessibility requirements and related obligations. A microenterprise has fewer than 10 employees and an annual turnover or balance-sheet total of no more than 2 million euros. Both conditions must be met at the same time. The exemption covers services only: if you also place products on the market, product accessibility requirements generally still apply, with lighter documentation duties.

Key dates

The EAA is not a future deadline any more. It has applied for more than a year. The only transition period in the directive that matters for most service providers concerns existing contracts.

What “accessible” means in practice

The directive describes functional requirements: information must be perceivable, operable, understandable and robust. In practice, the technical benchmark is the European standard EN 301 549, which is commonly mapped to WCAG 2.1 Level AA for websites and apps. The formal citation of the harmonised standard in the Official Journal was reportedly delayed, so check its current status, but WCAG 2.1 AA is the working baseline most auditors use.

Focus on the parts of the site that deliver the service. For a shop that means product pages, search and filters, the cart, the checkout, payment, account login and order confirmation emails. A beautiful but inaccessible checkout is a bigger risk than an imperfect blog post.

Accessibility statement. Some national laws require a published accessibility statement: Germany's BFSG is one clear example. Whether your country requires one, and in what form, depends on the national law, so check it. Even where it is not mandatory, a short statement explaining how your service meets the requirements and how users can report problems is good practice.

Enforcement is national. Market surveillance authorities can order you to fix problems, can restrict or ban a non-compliant service and can impose fines. Penalty levels differ from country to country, so we do not quote amounts here.

Quick self-check in 10 minutes

You do not need special software to find the most common problems. Open your site on a laptop, go to a product page and try to complete a purchase up to the payment step. Then run through these six checks.

• Keyboard navigation: put the mouse away and press Tab. Can you reach every link, button and form field in a logical order? Can you always see where the focus is? Can you leave pop-ups and menus without a mouse?
• Contrast: look at grey text on white, text over images and light buttons. If you have to squint, many users cannot read it. A free contrast checker tells you whether a colour pair meets WCAG 2.1 AA.
• Alt text: product images, icons and logos that carry meaning need a short text description. A photo of a blue linen shirt should say so, not “IMG_2034”.
• Form labels: every field in checkout and login needs a visible label, not just placeholder text that disappears when you type. Error messages should say what went wrong and how to fix it.
• Zoom to 200%: press Ctrl and + until the browser shows 200%. Text should still be readable, nothing should overlap and you should not need to scroll sideways to read a line.
• Captions: any video that explains your product or service needs captions, and audio-only content needs a transcript.

What to do now

Step 1: decide whether you are in scope. List what your site lets consumers do: buy, book, pay, open an account. Compare it with the list of services above. Write down your headcount and your latest turnover and balance-sheet figures so you can show whether the microenterprise exemption applies.

Step 2: map the service journey. Identify the pages and emails a consumer needs to complete a purchase or booking. That journey is where you start.

Step 3: test. Do the 10-minute self-check, then run an automated scan. For a shop with real revenue, commission a manual WCAG 2.1 AA audit of the main journey.

Step 4: fix in order of impact. Checkout, payment and login first, then product pages and search, then content pages. Check your theme, plugins and payment provider: many problems sit in third-party components, and you may need to ask the vendor for an accessible version.

Step 5: document. Publish an accessibility statement where your national law requires it, and keep a short internal record of what you tested, what you fixed and what is still open.

Step 6: keep it accessible. Add a quick accessibility check to every redesign, new plugin or campaign landing page. Accessibility is easy to lose with one careless update.

This is general information as of October 2026, not legal advice. Check your situation with a lawyer or your national market surveillance authority.