Running a site
The European Accessibility Act and your website: does it apply to you?
21 July 2026 · 7 min read
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There has been a lot of alarming marketing about the European Accessibility Act, much of it aimed at businesses it does not apply to. Here is the honest position.
This is not legal advice. It is a summary of how the rules are generally understood, written by people who fix websites rather than lawyers. If the answer matters commercially, take proper advice.
What it is
The EAA is Directive (EU) 2019/882. Enforcement began on 28 June 2025 for new products and services.
The technical requirement comes through the harmonised standard EN 301 549. The version currently cited in the Official Journal is v3.2.1, which references WCAG 2.1 Level AA — not 2.2. A newer version of EN 301 549 incorporating WCAG 2.2 has been published and is awaiting citation, so WCAG 2.1 AA is the operative benchmark today and 2.2 is where it is heading.
This matters because plenty of vendors are selling "WCAG 2.2 compliance" as though it were the current legal requirement. WCAG 2.2 is backwards compatible with 2.1, so aiming at it does no harm — but the standard being enforced is 2.1 AA.
The exemption most small businesses qualify for
Microenterprises are exempt from the service requirements. A microenterprise is defined as fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million. Both conditions must be met.
If you employ four people and turn over €400,000, the EAA's service obligations very likely do not apply to your website.
Three things to know about that exemption:
- It covers services, not products. A microenterprise manufacturing or distributing a covered product still has obligations.
- There is no grace period. Grow past either threshold and the exemption ends immediately.
- It is about your business, not your website. The test is headcount and turnover.
Most of the people being marketed to about the EAA are microenterprises. A lot of the urgency in that marketing is manufactured.
Who it does apply to
- Businesses above the microenterprise threshold offering services to consumers in the EU
- Ecommerce specifically, which is named in scope
- Banking, telecoms, transport ticketing, e-books, audiovisual media
- Non-EU businesses serving EU consumers. Where you are based is irrelevant; where your customers are is what counts
B2B-only services are outside scope, because the EAA is about consumers. If nobody acting outside their trade can buy from you, the service obligations do not apply.
Dates worth knowing: service contracts concluded before 28 June 2025 have until 28 June 2027. Some legacy infrastructure has until 2030.
What compliance actually involves
If it applies to you, in practice:
- Meeting WCAG 2.1 AA across the site, including the parts people need to complete a purchase
- Keyboard operability for every function — no mouse required
- Screen reader compatibility on real user journeys
- Accessible checkout, which is the one enforcement authorities have shown most interest in
- An accessibility statement published on the site. This is an administrative requirement in its own right and one of the more commonly missed
Enforcement is by national market surveillance authorities, and penalties are set by each member state, so they vary considerably. Some authorities have begun acting on ecommerce specifically.
What to do if you are exempt
Consider doing it anyway, for reasons that have nothing to do with law:
You will not be exempt forever. Retrofitting a large site is far more expensive than building accessibly.
It is required for public sector tenders regardless of your size.
It overlaps almost entirely with good practice. Proper heading structure, alt text, colour contrast and keyboard navigation also improve SEO and usability for everyone.
The population is not small. Roughly one in four adults in the EU has some form of disability, and excluding them is a commercial decision as well as an ethical one.
Be sceptical of anyone selling you EAA compliance without first asking your headcount and turnover. If they have not established whether the law applies to you, they are selling fear rather than a service.
Where to start
The five failures on almost every WordPress site are fixable in an afternoon and account for a large share of what an audit would find.
Then, if it applies to you, get a real audit — automated tools find only about a third of the issues, so a scan-only report is not a compliance assessment.
Our audit is $349 and combines automated scanning with manual keyboard and screen reader testing, which is the only way to cover the rest. We will also tell you plainly if we think the exemption applies to you.