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 (Directive (EU) 2019/882) has applied since June 28, 2025. It covers e-commerce and several other consumer services, wherever the business is based, if it sells to people in the EU.
- Microenterprises that provide services, meaning fewer than 10 employees and no more than €2 million in annual turnover or balance sheet, are exempt from the service requirements. The exemption does not cover products.
- In practice the technical benchmark for websites is EN 301 549. The version currently cited uses WCAG 2.1 AA; version 4.1.1, published in September 2026, moves to WCAG 2.2 AA.
- Enforcement and penalties are set by each member state, so the details differ by country. The work on your site does not: meet WCAG AA, publish accessibility information, and keep evidence.
What the European Accessibility Act is
The European Accessibility Act, usually shortened to EAA, is an EU directive adopted in 2019 to give the single market common accessibility rules for key products and services. You can read the legal text of Directive (EU) 2019/882 (opens in a new tab) on EUR-Lex, and the European Commission keeps an overview of the act (opens in a new tab).
Because it is a directive, each member state wrote it into national law. Germany's version, for example, is the Barrierefreiheitsstärkungsgesetz. The obligations are broadly the same everywhere, but enforcement bodies, procedures and penalties are national.
Its requirements have applied since June 28, 2025. For businesses that sell online, that date turned accessibility from good practice into a legal obligation across the EU.
Who has to comply
The act lists specific products and services. For most businesses reading this, the relevant item is e-commerce services: any website or app that sells products or services to consumers at a distance.
- Services in scope include e-commerce, consumer banking, electronic communications, e-books and their reading software, and websites, apps and ticketing for passenger transport.
- Products in scope include computers and operating systems, smartphones, e-readers, payment terminals, ATMs, ticketing and check-in machines, and TV equipment with interactive features.
Location does not get you out. A company outside the EU that sells to consumers inside it is covered for those sales. A U.S. store shipping to customers in France, Germany or Spain should treat its checkout as in scope.
Purely business-to-business sales, and websites that only provide information without selling, fall outside the e-commerce definition. Many such sites are still covered by other rules, and customers increasingly ask for accessibility regardless, so check with counsel before relying on that line.
The microenterprise exemption and transition periods
Article 4(5) exempts microenterprises that provide services from the service accessibility requirements. A microenterprise has fewer than 10 employees and annual turnover or annual balance sheet total of no more than €2 million.
There are also transition arrangements. Member states may allow service providers to keep using products that were lawfully in use before June 28, 2025 until June 28, 2030, and self-service terminals such as ATMs can stay in service for longer. These provisions help with hardware; they are not a general grace period for websites.
If you are close to the microenterprise thresholds, plan as if you will cross them. Retrofitting accessibility later is always more expensive than building it in.
The technical standard: EN 301 549 and WCAG
The EAA describes what products and services must achieve in functional terms: information must be perceivable, operable, understandable and robust. It relies on harmonised European standards to say how.
For websites and apps the reference in practice is EN 301 549 (opens in a new tab), the European standard for ICT accessibility. The version currently cited, V3.2.1, incorporates WCAG 2.1 Level AA for web content and adds requirements for documents, software and support services. Version 4.1.1 (opens in a new tab), published in September 2026, moves to WCAG 2.2 AA and becomes the reference once the EU formally cites it in the Official Journal.
WCAG 2.2 AA includes everything in 2.1 AA, so building to 2.2 meets today's reference and already meets the updated version. Our explainer on the nine new WCAG 2.2 criteria covers what that adds, and the EAA page summarizes how ComplyMo helps.
What your website must provide
For an online store or booking site, compliance comes down to three things.
1. An accessible journey from landing to confirmation
Every step a consumer takes has to work with a keyboard, a screen reader and zoom: browsing, search, product details, cart, account creation, login, payment, and order confirmation. Payment and identification steps are explicitly called out in the act.
2. Accessibility information
Service providers must explain how their service meets the accessibility requirements, in the general terms and conditions or an equivalent, in an accessible format. In practice most businesses publish an accessibility statement that describes the standard targeted, known limitations, and a contact route. The W3C provides a statement generator (opens in a new tab) you can adapt.
3. Ongoing conformity
The act expects accessibility to be maintained, not achieved once. New products, templates, campaigns and third-party scripts all need to keep meeting the standard, and you should be able to show authorities how you check.
Enforcement and penalties
Each member state designates market surveillance or enforcement authorities and sets its own penalties, which the directive says must be effective, proportionate and dissuasive. Member states must also let consumers, or organisations acting for them, bring complaints or legal action.
Because the rules are national, fines and procedures vary. The consistent expectation is that you can demonstrate conformity: a documented audit, a remediation record, an accessibility statement and a way for users to report problems.
| What an authority may ask for | What to have ready |
|---|---|
| Which standard you meet | A statement naming WCAG 2.1 or 2.2 AA via EN 301 549 |
| How you checked | Dated audit reports for your key templates |
| What is not accessible yet | A list of known issues with target dates |
| How users can report problems | A monitored contact route in your statement |
A practical plan for your site
- Confirm scope. Do you sell to EU consumers, and are you above the microenterprise thresholds?
- Audit the purchase journey. Run an automated WCAG check on every template, then test the checkout with a keyboard and a screen reader. The ComplyMo Agent schedules the automated part and ranks fixes.
- Fix in the code. Start with contrast, form labels, button and link names, focus visibility and error messages.
- Check third parties. Payment widgets, cookie banners, chat and review plugins are part of your journey. Ask vendors for their conformance information.
- Publish your accessibility information. Standard, known issues, contact route, and date of last review.
- Keep evidence. A dated record of scans and fixes is what you will show an authority or a customer.
If you also sell to U.S. customers, the same work covers most of what the ADA expects; see our guide to ADA website compliance in 2026. And since EU visitors also need a lawful cookie banner, the same install can handle GDPR cookie consent. You can start a free trial and scan your store today.
This article is general information, not legal advice. Requirements vary by jurisdiction and change over time, so confirm your obligations with counsel.
