European Accessibility Act 2025: does your website have to comply?

The European Accessibility Act (EAA) has been enforceable since 28 June 2025, and it changes what "good enough" means for business websites across the EU. If you sell to European consumers online, your site may now be legally required to meet a specific accessibility standard — and a handful of member states have already started chasing non-compliant companies. Here is what the law actually says, who it applies to, and how to know whether you need to act.

What the European Accessibility Act is

The EAA is Directive (EU) 2019/882, adopted in 2019. Its goal is to harmonise accessibility rules for products and services across the single market so that people with disabilities can use them on equal terms — and so businesses stop facing 27 different national rulebooks.

Member States had to write it into national law by June 2022, and the obligations for businesses took effect on 28 June 2025. New products and services placed on the market from that date must comply immediately. Some existing service contracts and self-service terminals get transition periods running up to 2030, but you cannot assume your website qualifies for a grace period — active, consumer-facing digital services do not.

Who has to comply

The Act applies to a defined list of products and services. On the digital side, the ones most SMBs care about are:

• E-commerce — any website or app selling goods or services to consumers
• Banking and payment services
• Telecommunications services
• E-books and dedicated reading software
• Passenger transport ticketing and information (air, bus, rail, water)
• Access to audiovisual media services (streaming interfaces)

Crucially, scope follows the customer, not your registered office. If you sell in-scope products or services to consumers in the EU, you are covered — even if your company is based outside the Union. A UK or US shop shipping to EU buyers is in scope for those sales. This is the same cross-border logic that makes a multi-language website worth considering when you sell across Europe: the moment you serve EU consumers, EU rules follow.

The micro-enterprise exemption

There is one meaningful carve-out. Micro-enterprises that provide services are exempt from the service-accessibility requirements. A micro-enterprise is defined as a business with fewer than 10 employees AND an annual turnover (or balance sheet total) of no more than €2 million — both conditions must be met.

Two catches worth flagging:

• The exemption covers services only. If a micro-enterprise manufactures, imports or distributes products in scope (say, a self-service terminal), it still has product obligations.
• "Fewer than 10 staff and under €2M" is a low ceiling. Plenty of small but growing online shops sit just above it, and a good e-commerce year can push you over. Treat the exemption as temporary breathing room, not a permanent pass.

The standard: WCAG 2.1 AA via EN 301 549

The EAA sets goals rather than a line-by-line technical spec, but in practice compliance is measured against EN 301 549, the EU's harmonised standard for ICT accessibility. For websites and apps, EN 301 549 incorporates the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA.

Note the version: although WCAG 2.2 exists, it is not yet folded into the harmonised standard, so WCAG 2.1 AA remains the operative benchmark. Meeting it means, among other things:

• Every image, control and form field has a meaningful text alternative
• The whole site works by keyboard alone, with a visible focus indicator
• Text has sufficient colour contrast (at least 4.5:1 for normal text)
• Content is structured with proper headings, labels and landmarks so screen readers can navigate it
• Error messages and form instructions are clear and programmatically associated

You can get a first read on where your site stands with our EAA accessibility checker — it flags the common WCAG 2.1 failures before you commit to a full audit.

Enforcement and penalties

Each Member State sets its own penalties and appoints its own market-surveillance authorities, so the exact numbers vary by country. Enforcement typically starts with notification and a deadline to fix problems rather than an instant fine — but the fines behind that process are real.

France is the clearest cautionary tale. For services covered by the EAA, enforcement sits with authorities such as the DGCCRF, ARCOM, ACPR and ARCEP depending on the sector. After a formal notice and deadline, a business can face a fine of €7,500 (rising to €15,000 for a repeat offence) combined with an enforcement order carrying a daily penalty (astreinte) of €3,000 per day, capped at €300,000 until the barriers are fixed. Separately, French disability organisations issued formal legal notices to several major grocery retailers within days of the June 2025 deadline, escalating to emergency injunctions later in the year — a reminder that pressure can come from advocacy groups and courts, not just regulators.

Beyond fines, authorities in various countries can order services suspended, products removed from the market, and non-compliance made public. The reputational and litigation exposure often outweighs the headline fine.

This is general information, not legal or tax advice — rules vary by country and change; confirm with a qualified professional before acting.

A practical compliance checklist

If you are not sure where you stand, work through this:

1. Check your scope. Do you sell in-scope products or services to EU consumers? If yes, you are likely covered.
2. Check the exemption. Are you a service provider with under 10 staff and under €2M turnover? If so, you have relief today — but plan ahead if you are growing.
3. Run an automated scan. Use the accessibility checker to surface obvious WCAG 2.1 AA failures (missing alt text, contrast, labels, keyboard traps).
4. Test manually. Automated tools catch perhaps a third of issues. Navigate your key journeys — homepage, product page, cart, checkout — using only a keyboard, and try a screen reader.
5. Fix the checkout path first. Prioritise the flows that make you money and that a regulator would test first.
6. Publish an accessibility statement. Several jurisdictions expect one, and it signals good faith.
7. Bake it into your build process. Accessibility is far cheaper designed in than retrofitted — which is one more thing to weigh when you choose a web design agency. Ask any prospective partner how they test for WCAG 2.1 AA.

Accessibility compliance is now part of the baseline for starting and running an online business in Europe, alongside tax registration and data protection. The good news: an accessible site is also a better site — faster, clearer, easier to use, and better for SEO.

Get your site compliant

If a scan turned up problems, or you would rather build it right from the start, that is exactly the kind of work we do. See our web development service — we build sites to WCAG 2.1 AA as standard — or book a free consultation and we will tell you honestly whether you are in scope and what it would take to get compliant.

Sources: European Commission (Directive 2019/882); EUR-Lex; EN 301 549 harmonised standard; DGCCRF / French enforcement guidance.