European Accessibility Act
The European Accessibility Act: a practical guide for websites and online shops
Updated 23 October 2026 · 4 min read
Since 28 June 2025, many products and services sold to consumers in the EU must be accessible to people with disabilities. For most businesses the part that matters is the website, the online shop or the app. This guide explains who is covered, what is required and how to get there.
What the European Accessibility Act is
The European Accessibility Act (EAA) is EU Directive 2019/882. Every EU member state has written it into national law, for example the Barrierefreiheitsstärkungsgesetz (BFSG) in Germany. The national laws have applied since 28 June 2025.
Unlike earlier rules that applied only to public sector websites, the EAA applies to private businesses.
Who it covers
The act covers specific products and services offered to consumers in the EU. The services include:
- E-commerce: online shops and any website or app where consumers can buy products or services
- Consumer banking services
- E-books and the software used to read them
- Passenger transport services by air, bus, rail and water, including websites, apps and ticketing
- Electronic communications services and access to audiovisual media services
Products such as computers, smartphones, e-readers, ATMs, ticket machines and check-in kiosks are also covered.
The act applies to businesses outside the EU too, if they sell to consumers in the EU. Services offered only to other businesses (B2B) are generally not covered.
The microenterprise exemption
Microenterprises that provide services are exempt from the service requirements. A microenterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros. The exemption does not apply to products, and it is worth checking your national law for details.
Even when exempt, an accessible shop reaches more customers, and many exempt businesses choose to follow the same standard.
What the technical standard is
The act describes requirements in general terms: services must be perceivable, operable, understandable and robust. In practice, conformance is shown through the harmonised European standard EN 301 549, which adopts WCAG 2.1 level AA for web content and apps.
WCAG 2.2 AA includes everything in 2.1 AA, so working to WCAG 2.2 covers the current requirement and prepares you for the next update of the standard.
What you need to do
- Find out whether you are covered: what you sell, to whom, and whether the microenterprise exemption applies.
- Check your website or app against WCAG 2.1 AA, ideally 2.2 AA: an automated scan plus manual tests of your key journeys, such as product search, basket, checkout and account.
- Fix the problems at the source, in the theme, templates and content. Start with anything that blocks a purchase.
- Publish accessibility information: describe how your service meets the requirements, usually in an accessibility statement linked from every page or included in your terms. Name a contact for feedback.
- Keep it accessible: test new features and content, and re-check after theme or plugin updates.
- Document any exception: if a requirement would be a disproportionate burden, you have to assess and document that, and in many countries tell the authority. It cannot be claimed lightly.
Checklist for online shops
These are the problems that most often block customers in shops:
- Product images without alt text, and image-only links to products
- Colour and size pickers that are not buttons and cannot be used with a keyboard, or that show the selected option by colour only
- Low contrast in prices, sale badges, placeholder text and buttons
- Basket and filter drawers that do not trap focus while open and cannot be closed with Escape
- Checkout fields without labels, error messages that are not announced, and address entered twice
- Cookie banners and newsletter pop-ups that cannot be reached or closed with a keyboard
- Logins that need a puzzle or block pasting passwords
- Help or contact links that move around from page to page
Transition periods
Service contracts agreed before 28 June 2025 may continue unchanged until they expire, for at most five years, until 28 June 2030. Self-service terminals already in use may stay in use until the end of their economic life, for up to 20 years. New websites, new features and redesigns should meet the requirements now.
Enforcement and penalties
Each member state names market surveillance authorities that can check services, require fixes and, in the end, stop a service from being offered. Penalties are set nationally; in Germany, for example, fines can reach 100,000 euros. Consumers and associations can also complain to the authorities.
In practice, the most common first step is a complaint or a request to fix a specific barrier. A shop that has tested its site, fixed the main problems, published a statement and answers feedback is in a much better position.
Questions and answers
Does the European Accessibility Act apply to my small business?
If you sell services such as e-commerce to EU consumers and have 10 or more employees or more than 2 million euros turnover and balance sheet total, it very likely applies. Microenterprises that provide services are exempt. Check the national law in your country or ask a lawyer for your specific case.
Does the EAA apply to companies outside the EU?
Yes, if they offer covered products or services to consumers in the EU.
Which WCAG version does the EAA require?
The harmonised standard EN 301 549 adopts WCAG 2.1 level AA. WCAG 2.2 AA includes all of it, so it is a good target.
Is an accessibility overlay enough to meet the EAA?
No. An overlay adds a script on top of the site but does not fix the underlying code, and many disabled users find overlays get in the way. Authorities look at whether the service itself is accessible.
Do I need an accessibility statement?
Service providers must provide information on how their service meets the accessibility requirements. Most do this with an accessibility statement. AccessibilityBrief can generate a draft statement from your scan results.
This guide is general information, not legal advice. Automated tests cover only part of WCAG; combine them with the manual checks described here.