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Accessibility3 min readBy ComplyMo Team

The European Accessibility Act: what your website needs to do now

Who the EAA covers, who is exempt, which standard applies, and a practical plan for your website.

Key takeaways

  • The European Accessibility Act has applied since June 28, 2025. It covers e-commerce and other consumer services sold to people in the EU, wherever the business is based.
  • Service microenterprises are exempt from the service rules, not the product rules.
  • The benchmark is EN 301 549: WCAG 2.1 AA today, WCAG 2.2 AA in version 4.1.1. Penalties vary by country; the work on your site doesn't.

What the European Accessibility Act is

Directive (EU) 2019/882 (opens in a new tab) sets common accessibility rules for key products and services; see the Commission's overview of the act (opens in a new tab). Each member state wrote it into national law, such as Germany's Barrierefreiheitsstärkungsgesetz, so enforcement is national.

Who has to comply

For most businesses the relevant item is e-commerce services: any website or app that sells to consumers at a distance. The act also covers banking, telecoms, e-books, transport ticketing and devices like ATMs.

Non-EU companies are covered for their EU sales. Purely B2B and information-only sites fall outside the e-commerce definition, but check with counsel before relying on that.

The microenterprise exemption and transition periods

Article 4(5) exempts service microenterprises: fewer than 10 employees and annual turnover or balance sheet total of no more than €2 million.

The exemption is for services only. A microenterprise that makes or imports a covered product still has to meet the product requirements.

Member states may let products lawfully in use before June 28, 2025 stay in service until June 28, 2030, and ATMs longer. That covers hardware, not websites.

The technical standard: EN 301 549 and WCAG

The cited version of EN 301 549 (opens in a new tab), V3.2.1, incorporates WCAG 2.1 Level AA. Version 4.1.1 (opens in a new tab), published in September 2026, moves to WCAG 2.2 AA once the EU cites it.

Building to WCAG 2.2 AA meets both. See the nine new WCAG 2.2 criteria, and our EAA page.

Enforcement and penalties

Each member state sets its own penalties, and consumers can complain or sue.

What an authority may ask forWhat to have ready
Which standard you meetA statement naming WCAG 2.1 or 2.2 AA via EN 301 549
How you checkedDated audit reports for your key templates
What is not accessible yetA list of known issues with target dates
How users can report problemsA monitored contact route in your statement

A practical plan for your site

  1. Confirm scope. Do you sell to EU consumers, above the microenterprise thresholds?
  2. Audit every step to payment. The ComplyMo Agent runs the automated WCAG checks; test checkout with a keyboard and screen reader.
  3. Fix in the code. Contrast, labels, names, focus and error messages first.
  4. Check third parties. Payment, cookie, chat and review widgets are part of your journey.
  5. Publish a statement and keep evidence. The W3C has a statement generator (opens in a new tab); keep dated scans and fixes.

The same work covers most of ADA website compliance in 2026, and the same install handles GDPR cookie consent. Start a free trial and scan your store.

General information, not legal advice. Confirm your obligations with counsel.

Frequently asked questions

Does the EAA apply to businesses outside the EU?

Yes, for products and services offered to EU consumers. A non-EU store selling to EU customers should treat its checkout as covered.

Is my small business exempt from the European Accessibility Act?

Only if you provide services with fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total. Products aren't exempt.

What standard should my website meet for the EAA?

EN 301 549, which uses WCAG 2.1 AA today and WCAG 2.2 AA in version 4.1.1. Building to WCAG 2.2 AA meets both.

What are the penalties for not complying with the EAA?

Each member state sets its own, so they differ by country. Authorities can require corrective action, and fines are possible under national law.

Sources

  1. EUR-Lex: Directive (EU) 2019/882 on accessibility requirements for products and services (opens in a new tab)
  2. European Commission: European Accessibility Act (opens in a new tab)
  3. ETSI: EN 301 549 V3.2.1, accessibility requirements for ICT products and services (opens in a new tab)
  4. AccessibleEU: EN 301 549 has been updated (September 2026) (opens in a new tab)
  5. W3C: Web Content Accessibility Guidelines (WCAG) 2.2 (opens in a new tab)
  6. W3C: Developing an accessibility statement (opens in a new tab)

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