What the European Accessibility Act is

The EAA is an EU directive that sets common accessibility requirements for a list of everyday products and services. The official EUR-Lex summary lists the services covered: telephony, access to audiovisual media, parts of air, bus, rail and waterborne passenger transport, consumer banking, e-books, e-commerce and the 112 emergency number. Covered products include computers, smartphones, e-readers, ATMs and ticketing machines.

Member states had to write the directive into their own national law by 28 June 2022, and, as the summary puts it, "EU countries must apply the measures from 28 June 2025." The European Commission monitors how each country implements it, while enforcement sits with national market surveillance authorities. That means penalties and complaint routes vary from country to country.

Why it can reach businesses outside the EU

For most of our clients, the relevant category is e-commerce. The directive defines e-commerce services broadly as services provided at a distance, through websites and mobile apps, at the request of a consumer, with a view to concluding a consumer contract. In plain terms, that covers online shops, but also many booking flows, subscriptions and digital purchases.

Crucially, the directive talks about service providers that provide services to consumers in the Union. As this article-by-article guide to the e-commerce requirements explains, the focus is on where the consumer is, not where the seller is based. A US retailer shipping to Germany, a UK brand selling into Ireland or an Australian SaaS company taking card payments from French consumers may all need to consider it.

A few points are worth checking with your lawyer:

• Are you really targeting EU consumers? Euro pricing, EU shipping, EU-language versions and EU marketing all point that way.
• Is it business-to-consumer? The e-commerce obligations are about consumer contracts; purely B2B sales are treated differently.
• Which countries? Enforcement is national, so the rules of the countries you sell into matter.
• The UK is no longer an EU member. The EAA does not apply within the UK itself, but UK businesses selling to EU consumers may still be in scope.

Who is exempt (and who isn't)

The EAA does not apply to "microenterprises providing services". The directive defines a microenterprise as one that employs fewer than 10 people and has an annual turnover or balance sheet total of no more than €2 million. Both conditions matter. A ten-person agency with modest revenue is not a microenterprise; nor is a three-person online shop turning over €3 million.

Larger businesses can sometimes argue that a specific requirement would impose a "disproportionate burden" or fundamentally alter the service. That is a documented assessment, not a blanket opt-out, and it is exactly the kind of judgement to take legal advice on.

There is also a transition period. Under the summary, member states may let service providers keep using products that were lawfully in use before 28 June 2025 to deliver similar services until 28 June 2030. That relates to products such as terminals, not to a website you are still editing and selling through every day.

What a compliant online shop or booking site needs

The directive is written in principles — your service should be perceivable, operable, understandable and robust — rather than line-by-line technical rules. In practice, organisations use the Web Content Accessibility Guidelines (WCAG) at Level AA as the yardstick. The European harmonised standard for ICT accessibility, EN 301 549, builds on WCAG for web content.

The common problems are the same everywhere. The WebAIM Million 2026 report found detectable WCAG failures on 95.9% of the top one million home pages, with low-contrast text on 83.9% and missing form labels on 51%. For an online seller, those failures sit right in the path to purchase.

Accessible.org's guide also points to Article 13 and Annex V, which ask service providers to make information available on how their service meets the accessibility requirements, and to keep it available for as long as the service operates. Most businesses do this with a dedicated accessibility statement page.

Why a widget won't get you there

Overlay plug-ins promise one-line compliance, but they sit on top of the code rather than fixing it. In 2025 the US Federal Trade Commission approved a final order requiring accessiBe to pay US$1 million over claims that its tool could make any website compliant. The durable approach is to fix your theme, templates and content, then keep them fixed.

A 90-day plan for non-EU sellers

1. Weeks 1–2: Confirm scope. List the countries you sell to, your headcount and turnover, and whether sales are to consumers. Take this to a lawyer.
2. Weeks 2–4: Audit the money paths. Test home, category, product, cart, checkout, booking and account pages against WCAG 2.2 AA, with automated tools and manual keyboard and screen-reader testing.
3. Weeks 4–10: Fix at the source. Prioritise template and component fixes that repair many pages at once, then content fixes such as alt text and link wording.
4. Weeks 10–12: Publish and document. Write your accessibility statement, add a contact route for accessibility issues and keep a record of the audit and fixes.
5. Ongoing: Monitor. New products, apps and theme updates reintroduce problems. Re-test regularly.

Our website accessibility service follows this pattern: an audit from US$690, then monthly plans — Monitor at US$99/month, Care at US$249/month and Care Plus at US$499/month. No provider can promise you will never face a complaint, but a genuinely usable site is the strongest position to be in. If you sell into the US too, our guide to ADA website lawsuits in 2026 covers the American side.

Frequently asked questions