European Accessibility Act: does it apply to your website?

Reviewed 30 September 2026. General information, not legal advice.

Short answer: If you sell products or services to consumers in the EU through a website or app, and your business is not a micro-enterprise, the European Accessibility Act very likely applies to you. It has applied since 28 June 2025, wherever your business is based. A micro-enterprise employs fewer than 10 people and has an annual turnover or balance sheet total of no more than €2 million.

What the European Accessibility Act is

The European Accessibility Act (EAA) is Directive (EU) 2019/882. It sets common accessibility requirements for a defined list of products and services sold to consumers in the EU. Each member state has written it into national law — in Germany, for example, as the Barrierefreiheitsstärkungsgesetz (BFSG) — and appointed authorities to supervise it. The requirements have applied since 28 June 2025.

It is separate from the Web Accessibility Directive (EU) 2016/2102, which covers the websites and apps of public-sector bodies.

Which services are covered

Article 2 lists the services. For most website owners the important one is the last:

electronic communications services, such as telephony and messaging;
services providing access to audiovisual media;
parts of air, bus, rail and waterborne passenger transport services: websites, apps, electronic tickets and travel information;
consumer banking services;
e-books and the software for reading them;
e-commerce services.

The Directive defines e-commerce services as “services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract” (Article 3(30)). That is broad: an online shop, a booking or appointment system, a subscription sign-up, or any other website on which a consumer can conclude a contract.

Two limits follow from the definition. The service must be aimed at consumers, so an offer that is strictly business-to-business is outside it. And it must lead towards a contract, so a website that only presents a company, with no way to order, book or sign up, is generally not regarded as an e-commerce service. Where exactly the line runs is a legal question that depends on your offer.

The Directive also covers products such as computers, smartphones, e-readers, payment terminals and ticket machines. This guide is about websites.

Who is exempt

Micro-enterprises that provide services are exempt from the accessibility requirements for those services (Article 4(5)). A micro-enterprise is “an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million” (Article 3(23)). Both parts must hold: with ten or more staff the exemption is gone, whatever the turnover.

The exemption is for services only. A micro-enterprise that manufactures, imports or distributes covered products still has to make sure those products comply.

Disproportionate burden. Article 14 lets a business depart from a requirement where meeting it would fundamentally alter the service or impose a disproportionate burden. It is not an opt-out that can simply be claimed. The business has to carry out an assessment against the criteria in Annex VI, document it, keep it for five years, inform the market surveillance authority, and repeat the assessment when the service changes and at least every five years.

Some content is excluded (Article 2(4)): pre-recorded audio and video published before 28 June 2025; office file formats published before that date; online maps, provided essential information is given in an accessible form where a map is meant for navigation; third-party content that you neither fund, develop nor control; and archived content that is not updated after 28 June 2025.

What your website has to do

Annex I requires websites, online applications and mobile apps to be made accessible “by making them perceivable, operable, understandable and robust”. Those are the four principles of the W3C’s Web Content Accessibility Guidelines (WCAG). The technical detail comes from the European standard EN 301 549, which for web content adopts WCAG at levels A and AA: WCAG 2.1 in the version used until now, and WCAG 2.2 in V4.1.1, published in September 2026.

In practice that means, among other things:

text alternatives for images, icons and controls;
enough colour contrast for text and interface elements;
everything usable with a keyboard alone, with a visible focus indicator;
form fields with labels, and error messages a screen reader announces;
a correct structure: headings, landmarks, page titles and the page language;
captions for video;
pages that still work at 200% zoom and on a small screen.

For e-commerce services Annex I adds specific points: give the accessibility information about the products and services you sell where the manufacturer or provider supplies it, and make identification, security and payment functions accessible.

Beyond the website itself, Article 13 requires a service provider to:

publish information on how the service meets the requirements — see the accessibility statement guide;
have procedures that keep the service conformant when it changes and when the standards change;
take corrective action if the service does not conform, and inform the competent authorities.

Deadlines and transition periods

The requirements have applied to services provided to consumers since 28 June 2025. Article 32 contains two transitional rules that run until 28 June 2030: service providers may keep using products they lawfully used before 28 June 2025 to deliver their services, and service contracts agreed before that date may continue unchanged until they expire, for at most five years.

This is often misread as a five-year grace period for existing websites. The wording is about products used to deliver a service and about running contracts. A website on which consumers can conclude new contracts today is generally understood to have to meet the requirements today.

Penalties and enforcement

The Directive leaves penalties to the member states and only requires them to be “effective, proportionate and dissuasive” (Article 30). The amounts therefore differ widely from country to country, and what matters is the law of each country whose consumers you sell to. In Germany the BFSG provides for fines of up to €100,000 (section 37). Some member states have set considerably higher maximums. Check the national law for each of your markets rather than relying on a comparison table: published summaries contradict each other.

Supervision usually starts with a demand to fix the problem, not with a fine. In Germany the market surveillance authority first asks the provider to bring the service into line within a reasonable period, and can ultimately prohibit the service from being offered (section 29 BFSG). Under Article 29 of the Directive consumers, and organisations acting for them, must be able to take a complaint to a court or authority.

How to check your website

Run an automated scan. It finds the machine-detectable defects — missing text alternatives, low contrast, unlabelled form fields and buttons, broken ARIA — across many pages in minutes. Automated testing reliably covers roughly 30–40% of the requirements, so it is the first step, not the last.
Fix what it finds, blockers first: anything that stops someone completing a purchase, a booking or a sign-up.
Test by hand. Go through your main journeys using only the keyboard; with a screen reader (NVDA and VoiceOver are free); at 200% zoom; and on a phone. Check that form errors are announced and understandable.
Write and publish your accessibility information, including the barriers you know about and are still working on.
Keep it up. Re-test after redesigns and new features. Accessibility regresses quietly.

Every automated check RampCheck runs is explained here, with who it affects and how to fix it.

Questions

Does the EAA apply to businesses outside the EU?

Yes. It applies to anyone who offers a covered service to consumers in the EU, wherever the business is established. A shop in the UK, Switzerland or the US that sells to EU consumers is in scope unless it is a micro-enterprise.

Does it apply to B2B websites?

The covered services are those offered to consumers. A strictly business-to-business offer is outside the definition of e-commerce services; a shop that also sells to consumers is inside it.

Is WCAG 2.1 AA enough, or do I need WCAG 2.2?

WCAG 2.1 AA was the benchmark in EN 301 549 V3.2.1. V4.1.1, published in September 2026, moves to WCAG 2.2 AA. What that changes.

Can an accessibility overlay or widget make my website compliant?

No. An overlay adds a script on top of the page; it does not repair the underlying code that assistive technology reads. The European Disability Forum and the International Association of Accessibility Professionals said so in a joint statement in 2023, and in January 2025 the US Federal Trade Commission ordered an overlay vendor to pay $1 million over claims that its product could make any website WCAG compliant.

Does a good automated score mean my website complies?

No. A score from automated testing reflects the defects a machine can detect. Conformance also needs manual testing with assistive technology. A clean scan means the machine-detectable problems are gone: a necessary step, not the finish line.

Check your own website

The free scan tests 3 pages against WCAG 2.2 A and AA in about 30 seconds. No sign-up.

Scan my website — free