The European Accessibility Act and your website

In this article

For years, web accessibility in the EU was a legal duty mainly for the public sector. The European Accessibility Act changed that. It extends accessibility requirements to a set of private-sector products and services, and one of those services is e-commerce. If your website sells to consumers in the EU, there is a good chance it is now covered, and that the accessibility checks in a compliance report deserve more attention than they used to get.

01What changed in June 2025

The European Accessibility Act is Directive (EU) 2019/882. Member states had to apply their implementing laws from 28 June 2025. The directive covers a defined list of products, such as computers, smartphones, self-service terminals and e-readers, and services, including electronic communications, elements of passenger transport services, consumer banking services, e-books and e-commerce services.

The directive defines e-commerce services broadly: services provided at a distance, through websites and mobile applications, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract. An online shop is the obvious case, but any website through which consumers can buy a product or service is likely to be in scope.

It is separate from the Web Accessibility Directive ((EU) 2016/2102), which has applied to public sector websites and apps in stages between 2018 and 2021.

02Who is exempt

Microenterprises that provide services are exempt from the service requirements. A microenterprise, in the directive’s definition, employs fewer than 10 persons and has an annual turnover or an annual balance sheet total not exceeding €2 million. Check the thresholds carefully, especially if your business belongs to a group.

Other providers can invoke the directive’s exceptions only on specific grounds: where meeting a requirement would fundamentally alter the basic nature of the service, or would impose a disproportionate burden. Both require an assessment based on the criteria in Annex VI, which must be documented and kept, and they are not a general opt-out. Transitional rules also allow some existing service contracts and products to continue for a limited period, ending at the latest in 2030.

03What ‘accessible’ means in practice

Annex I of the directive sets out the accessibility requirements as functional principles: services must be perceivable, operable, understandable and robust, and the information about them must be provided in accessible formats. The directive does not itself prescribe a technical checklist. Compliance with harmonised standards published in the Official Journal gives a presumption of conformity.

In practice, the reference point for websites is the Web Content Accessibility Guidelines (WCAG) at level AA. The European standard EN 301 549, which is used under the Web Accessibility Directive, incorporates WCAG 2.1 level AA for web content, and work on harmonised standards for the European Accessibility Act is under way under a Commission standardisation request. WCAG 2.2, published by the W3C in October 2023, adds criteria on focus visibility, target sizes and accessible authentication, and is a sensible target for new work.

04Information you must publish

Service providers must explain how their service meets the accessibility requirements. Article 13 and Annex V require this information to be included in the general terms and conditions, or an equivalent document, and made available in written and oral format and in a way that is accessible to persons with disabilities. It should describe the service in accessible formats and explain how it meets the relevant requirements. Many providers do this with an accessibility statement linked from every page, referenced in their terms.

Providers must also keep that information for as long as the service is in operation, and must take corrective measures if the service stops conforming.

05Who enforces it

Each member state designates authorities responsible for checking that services comply, and sets its own penalties, which the directive requires to be effective, proportionate and dissuasive. The authority, the procedure and the level of penalties therefore differ from country to country; check the implementing law in each country where you sell. Consumers and, depending on national law, consumer organisations and other bodies can also bring proceedings.

06What an automated check finds, and what it misses

Automated accessibility tools are good at finding problems that can be detected in the code of a page:

• images without a text alternative;
• insufficient colour contrast between text and background;
• form fields without labels;
• missing page language, empty links and buttons, duplicate IDs;
• skipped heading levels and missing landmarks.

Many WCAG success criteria, however, need human judgement. A tool can tell that an image has alternative text, but not whether the text describes it; it can find a focus style, but not whether keyboard focus moves through the checkout in a sensible order; it cannot judge whether captions are accurate or error messages are clear. Treat a clean automated report as a floor, not a certificate, and plan at least a manual keyboard and screen-reader pass through your key journeys.

07A practical starting order

1. Keyboard only. Put the mouse away and complete a purchase. Every control must be reachable, operable and visibly focused.
2. Forms. Every field has a visible label; errors are announced in text, not only with colour.
3. Contrast and zoom. Text meets AA contrast; the page still works at 200% zoom and at a 320-pixel-wide viewport without horizontal scrolling.
4. Structure. One main heading per page, a logical heading order, landmarks, and a skip link.
5. Media. Meaningful alternative text; captions for video; no autoplaying sound.
6. Consent banner and pop-ups. They must be operable by keyboard and screen reader too, or they block the whole site.
7. Information. Publish how your service meets the requirements and a way for users to report barriers.

08Sources and further reading

Primary legal texts and official guidance referred to above. Links go to the official publishers.

1. Directive (EU) 2019/882 (European Accessibility Act) (eur-lex.europa.eu)
2. Directive (EU) 2016/2102 (Web Accessibility Directive) (eur-lex.europa.eu)
3. W3C, Web Content Accessibility Guidelines (WCAG) 2.2 (w3.org)
4. W3C, Web Content Accessibility Guidelines (WCAG) 2.1 (w3.org)
5. ETSI EN 301 549 V3.2.1, Accessibility requirements for ICT products and services (etsi.org)