European Accessibility Act website requirements: who is covered, who is exempt, and the UK law that applies anyway

European Accessibility Act website requirements: the short answer

The European Accessibility Act's website requirements have applied since 28 June 2025. They cover websites and apps where consumers in the EU order, book or pay, wherever the seller is based. Microenterprises providing services are exempt. The Act names no technical standard, but WCAG 2.2 at level AA is the practical target.

This guide is for the founder or operations lead of a UK or EU company of 10 to 200 people. Perhaps a vendor has emailed you about "EAA compliance". Or you sell into the EU and aren't sure the law reaches you.

We build websites for companies in the UK, France and Albania, so our work sits on both sides of this line. The Act covers fewer websites than the sales emails suggest, and more UK companies than expect it. In Great Britain, the Equality Act 2010 already applies to any website that serves the public, with no exemption for small firms.

Does the European Accessibility Act cover your website?

The Act covers services, not websites as such. Your website is in scope when it's how a covered service reaches consumers. Directive (EU) 2019/882 lists the services in Article 2(2). For most companies, the one that matters is the e-commerce service.

Article 3 defines it as a service provided at a distance, through a website or app, at a consumer's request, "with a view to concluding a consumer contract". Recital 43 adds that the rules apply to "the online sale of any product or service". A consumer is a person buying outside their trade or profession.

So the test is simple to state. Do consumers buy through the site, and are any of them in the EU?

The brochure site is the grey area. Say you run a 30-person solar installer in Cork, and homeowners request a site survey through your form. No contract is concluded online, but the enquiry is arguably a step "with a view to" one.

The text doesn't settle it, and national guidance only narrows it. Germany's federal accessibility agency says a site that only informs or advertises probably isn't covered, because no service is provided at a consumer's individual request. The same page notes that the German labour ministry's guidelines treat online appointment booking as covered. A quote form sits between the two, and other countries' regulators may read it differently.

If consumers can buy or book on your site, treat it as covered. If they can only enquire, take advice, and build to the standard anyway: in Great Britain the Equality Act applies either way.

Who is exempt, and the exemptions people misread

Microenterprises that provide services are exempt from the Act's accessibility requirements (Article 4(5)). Article 3(23) defines a microenterprise as one that employs fewer than 10 people and has an annual turnover, or a balance sheet total, of no more than EUR 2 million.

At 10 or more people, you aren't a microenterprise, whatever your turnover. Group companies should check twice. Recital 53 says a firm must "genuinely fulfil" the EU's 2003 definition of small firms to benefit. The Commission's SME definition page warns that a firm in a larger group may need to count the group's figures too.

Three other provisions are often misread.

1. Disproportionate burden. Article 14 limits the requirements to what doesn't impose a disproportionate burden, but you can't simply claim it. You assess it against the criteria in Annex VI and document it. You keep the results for five years and repeat the assessment at least every five years. Unless you're a microenterprise, you must also tell the authority in each country where you provide the service.
2. Old content. Article 2(4) leaves out recorded audio and video, and office files such as PDFs, published before 28 June 2025. It also leaves out archives nobody edits after that date. Third-party content is out only if you neither fund, develop nor control it, so a checkout widget you chose and pay for is hard to fit in.
3. The year 2030. Article 32 lets service contracts agreed before 28 June 2025 run unchanged until they expire, for five years at most. Providers may also keep using products they already used for similar services until 28 June 2030. Some guides turn this into "existing websites have until 2030". Article 32 doesn't mention websites, and an order placed on your site today is a new contract. Take advice before you rely on it.

UK companies: two laws, not one

Great Britain never adopted the European Accessibility Act, because the UK left the EU before the June 2022 deadline for writing it into national law. But Article 3(4) counts as a service provider anyone who "makes offers to provide such a service to consumers in the Union". On that wording, if you sell online to consumers in Ireland or France, the Act applies to those sales.

The Equality Act 2010 applies anyway. Section 29 puts a duty to make reasonable adjustments on anyone providing a service to the public, whether paid or free. The Equality and Human Rights Commission's Code of Practice for services came into force on 5 August 2026. It says the obligation "also applies to the provision of services on a website".

The duty is owed to disabled people generally (Schedule 2, paragraph 2), so it applies before anyone complains. The Code says it applies whether or not you know a customer is disabled. Its example is a legal services firm whose website text is all embedded in images. The Code says the firm must adjust the site, and that the practice is indirect discrimination unless the firm can justify it.

The Equality Act covers Great Britain (section 217). In Northern Ireland, the Disability Discrimination Act 1995 sets the duty instead.

What the Act asks of a website in scope

The core requirement is one line in Annex I: make websites and apps "perceivable, operable, understandable and robust". WCAG is built on the same four principles, which is why it's the usual way to meet the Act.

Around that line, the Directive adds duties most summaries skip.

• Information about the service must reach more than one sense, come as text that assistive technology can read, and offer an alternative for anything that isn't text.
• For online sales, you pass on the accessibility information about the products you sell when their maker supplies it. Login, security checks and payment must work for disabled people.
• A help desk or call centre, if you have one, must be able to explain the service's accessibility.
• You explain how the service meets the requirements (Article 13 and Annex V). The explanation goes in your general terms or an equivalent document, in written and oral format.
• You keep procedures that hold the service to the requirements as it changes.
• If it falls out of compliance, you fix it and immediately tell the national authorities where you provide the service.

The simplest form for that explanation is an accessibility page linked from your terms. A good one says what works, what doesn't yet, and how to reach a person who can help.

WCAG 2.2 AA: the standard to build to

The Directive presumes a service complies if it meets a harmonised standard cited in the EU's Official Journal (Article 15). None has been cited under the Act yet: the Commission's 2026 standardisation plan still calls them upcoming. For websites, the standard to watch is EN 301 549.

Its version 4.1.1 was published in September 2026. The Commission's AccessibleEU centre says it adopts WCAG 2.2 and is the first version written with the Act in mind. Until it's cited, AccessibleEU treats version 3.2.1 as the reference. That's the 2021 version already cited for public sector websites, based on WCAG 2.1 level AA.

That makes the choice easy. The W3C says later WCAG versions add success criteria without changing existing ones, apart from one criterion made obsolete. A site built to WCAG 2.2 AA meets 2.1 AA today and covers the WCAG part of the new version.

Several of the new criteria land where the Act's e-commerce rules point: login and checkout.

• Accessible Authentication: don't make logging in depend on solving a puzzle, or on remembering and retyping something.
• Redundant Entry: don't ask twice in one session for something, such as a delivery address, already given.
• Target Size: buttons and links at least 24 by 24 CSS pixels, with some exceptions.
• Consistent Help: a contact route in the same place on every page.
• Focus Not Obscured: a sticky header or cookie banner mustn't completely hide the element a keyboard user has moved to.

Name WCAG 2.2 AA in your website brief and in the contract, with who tests it and when.

Who enforces it, and what the first cases show

Each member state names its own authority and sets its own penalties. The Directive asks only that penalties be "effective, proportionate and dissuasive" and reflect how many people are affected (Article 30). Consumers can complain to the authority or go to court. Associations with a legitimate interest can act on their behalf or in their support (Article 29).

In Germany, the 16 federal states set up one body for the job, the MLBF in Magdeburg, and consumers can report barriers to it directly.

In the Netherlands, the ACM tested about 100 of the country's largest webshops and telecom and energy sites. It reported in March 2026 that at 61% of the largest webshops, a person using assistive technology couldn't place an order. Its examples were an order button the keyboard can't reach and an inaccessible CAPTCHA. Companies that don't improve risk enforcement, it added.

France shows how quickly associations can move. Two disability associations (ApiDV and Droit Pluriel) sent formal notices to Auchan, Carrefour, E.Leclerc and Picard on 7 July 2025 about their online grocery sites and apps. In November 2025, they took all four to court in urgent proceedings.

The first two rulings went opposite ways. On 5 May 2026, the court in Lille recorded serious failures on Auchan's online service. It still dismissed the claim, on a narrow reading of which French law applied, and the associations have appealed. On 4 June 2026, the court in Caen ordered Carrefour France to make its website and app fully accessible within six months, on pain of a daily penalty.

Carrefour had argued, according to the associations, that it already met 71% of the accessibility criteria. The judge replied that an e-commerce site can't be only a little accessible; it has to be fully accessible. Until the appeal courts settle the law, plan for the stricter reading.

Why an overlay won't make you compliant

An overlay is a script added to a site, often with a toolbar, sold on the claim that software fixes accessibility for you. The European Commission's web accessibility page says overlays, or any tools that leave the site itself short of the standard, "are not an appropriate solution". It advises fixing problems at their source.

The same claim has already been tested in the United States. In April 2025, the Federal Trade Commission approved a final order against accessiBe, maker of the accessWidget overlay. The FTC had alleged that the widget did not make all its users' websites WCAG-compliant, as the company claimed. The order bars accessiBe from claiming its automated products can make any website compliant unless it has evidence.

A fallback that makes a broken feature look finished is worse than the broken feature, because nobody goes back to fix it. The real barriers sit in the templates: a form field with no label, or a button that's only an icon. Fix them there, once.

A checklist for your website

The first two items decide whether the Act applies. The rest apply either way.

1. List every place consumers buy from you online, including apps, booking engines and payment pages.
2. Check the microenterprise test honestly, counting the rest of your group.
3. Go from the home page to a paid order or a sent enquiry with the keyboard alone.
4. Do the same with a screen reader. VoiceOver is built into Macs and iPhones; NVDA is free for Windows.
5. Run the W3C's Easy Checks on your top pages. Automated tools find some failures, not all.
6. Fix the templates and shared components first, then individual pages.
7. Make image descriptions and heading levels fields in the content model, so editors fill them in rather than remember them.
8. Test what you embedded: the cookie banner, the chat widget, the checkout. The banner is the first thing most visitors must operate; our guide to cookie consent requirements covers what else it must do by law.
9. Write the accessibility information, link it from your terms, and name a way to reach a person.
10. Re-test after every release that changes a template, a form or the checkout.

When you don't need to do anything new

Some companies can stop here.

• You're an EU microenterprise providing services. The Act exempts you, though member states must offer you guidelines and tools. If you also serve the public in Great Britain, the Equality Act still applies.
• You sell only to businesses. The Act's e-commerce rules turn on consumer contracts.
• Your site already meets WCAG 2.2 AA and you publish the information. Keep testing after each release.

You may not need a new website either, or us. WebAIM's February 2026 scan of the top million home pages found detectable WCAG failures on 95.9% of them, led by low-contrast text. Failures like that are fixed on the site you have, usually by your current developer. Our guide to the signs a website needs a redesign explains why accessibility is usually a fix, not a rebuild.

When a site is too tangled to fix, we start with an audit and a written recommendation. It makes the case for rebuilding only when rebuilding is genuinely better.

This week, put the mouse away and try to buy something or send an enquiry on your own site with the keyboard alone. Where you get stuck is the first thing to fix, whichever law applies to you.

Questions

Our shop runs on Shopify, WordPress or Wix. Doesn't the platform take care of this?

No. The Directive puts the duty on the service provider, which is you. The platform supplies the base. Your theme, the apps you add and your own content decide whether a customer using a screen reader or a keyboard can buy. Ask for your theme's accessibility claims in writing, test the checkout yourself, and remove any app that breaks it.

Do UK companies have to publish an accessibility statement?

Public sector bodies must, under the UK's 2018 accessibility regulations. A private company serving only customers in Great Britain has no duty to publish one. A short page is still worth having, because it tells a customer who hits a barrier how to reach a person. Selling to EU consumers brings the Directive's own information duty.

How we wrote this: drafted with AI, then checked and edited by the people who build our projects. Figures come from our own work or from the linked sources.