Does your website need to comply with the European Accessibility Act?

Yes, if you sell to consumers in the EU through a website or app, the European Accessibility Act applies to you, wherever your company is registered. The rules have applied since 28 June 2025, and the size exemption only helps microenterprises: businesses with fewer than 10 staff and either annual turnover or a balance sheet total of €2 million or less.

Most of what you'll read about this law comes from companies that sell accessibility software, so the answer usually arrives with a widget attached. The legal text is shorter and plainer than those guides make it look. It settles the two things a store owner in Toronto or Bengaluru wants to know first: am I covered, and what do I fix before anything else?

What the European Accessibility Act covers

The European Accessibility Act is an EU law that sets accessibility rules for a fixed list of products and services, and online selling is on that list. Directive (EU) 2019/882 defines e-commerce services as services provided at a distance, through websites and mobile apps, at a consumer's request with a view to concluding a consumer contract.

In plain terms, if a shopper can buy from you on your site or in your app, you run an e-commerce service. The Dutch government's business portal gives web shops, online marketplaces and platforms for booking hotels or ordering meals as examples. The directive's recitals go further: the rules apply to the online sale of any product or service, so a store selling handmade candles is covered on the same terms as one selling laptops.

E-commerce sits on the European Commission's list next to banking, e-books, telephony and passenger transport services, while products such as computers, smartphones and ticket machines have their own rules.

The dates are already behind you. EU countries had to write the directive into national law by 28 June 2022 and apply it from 28 June 2025, so the rules you face are the French, German or Irish versions of one template. For a store that was trading in June 2025, the clock isn't about to start. It has been running for more than 16 months.

A brochure site that describes your services and asks visitors to phone you sits outside the e-commerce definition in our reading, because nothing is bought through it. Add a booking form that takes payment and the answer changes.

Does it apply if your business is outside the EU?

Yes. Where your company is registered is not part of the test. The directive defines a service provider as anyone who provides a service on the EU market or makes offers to provide such a service to consumers in the EU, so a store in Canada, the US, India or Australia that sells to EU shoppers is covered on the same terms as one in Lyon.

Two words do the work here: "makes offers". The directive doesn't list signals, so our practical test is simple: if you ship to EU addresses, price in euros, run a French or German version of your store, or advertise to EU shoppers, assume you are making that offer. A site that blocks EU delivery addresses at checkout is hard to describe as offering anything to EU consumers.

Picture a homeware brand in Melbourne with 14 staff and €3 million in yearly sales, a fifth of it shipped to Ireland and the Netherlands. It has no EU office and no EU employees. It is still in scope: it offers an e-commerce service to consumers in the EU, and at 14 staff it is too big for the microenterprise exemption.

Distance makes enforcement slower. It does nothing to the legal position, and the bigger your share of EU revenue, the worse that bet looks.

A four-question test for your website

Four answers settle whether the European Accessibility Act covers your site, and most store owners can give all four from memory. Work through them in order and stop at the first answer that takes you out of scope.

1. Do you sell to consumers? The directive defines a consumer as a person buying outside their trade or profession, so a wholesale portal open only to trade accounts is not an e-commerce service.
2. Can people in the EU buy from you, through delivery to EU addresses or digital services they use there?
3. Does the sale happen on a website or in an app? Checkout, booking, ordering and paid sign-ups all count. A phone-only sales line does not.
4. Are you a microenterprise, with fewer than 10 staff plus turnover or a balance sheet total of €2 million or less? If so, the service rules don't apply to you.

Yes, yes, yes and no means you are covered. Stores that sell to both trade buyers and the public should treat the consumer side as in scope, even when most revenue comes from trade accounts.

How the microenterprise exemption works

A microenterprise, in the directive's words, employs fewer than 10 persons and has an annual turnover or an annual balance sheet total not exceeding €2 million. Article 4(5) exempts microenterprises providing services from the accessibility requirements for services and from every obligation tied to them. For an online store that meets this test, the service rules do not apply at all.

Headcount and money both count. A store with 10 employees is not a microenterprise, no matter how small its turnover. A store with 6 employees still has to pass one of the €2 million tests.

The money test has two routes. Under the directive's wording, a seven-person store turning over €3.5 million still qualifies if its balance sheet total stays at €2 million or below, because turnover and balance sheet are alternatives. National laws don't all repeat that wording. The Netherlands' business portal asks whether you have more than 10 employees, turnover above €2 million, or both, and says nothing about the balance sheet. Check the version used where most of your EU customers live.

The exemption lasts only while you qualify. A nine-person store that makes its tenth hire moves into scope once it crosses the line, and so does a fast-growing brand that passes both money limits. Plan for that point rather than discovering it after the fact.

Products are handled differently. Microenterprises that make, import or distribute covered products, such as smartphones or computers, get lighter obligations instead of a full exemption. A small store selling clothes or furniture online is on the services side, where the exemption is complete.

Being exempt doesn't stop a customer using a screen reader from abandoning your checkout. The directive encourages microenterprises to comply anyway, and our advice to small stores is to fix the six common errors listed further down, because they cost little and every shopper benefits.

What the law asks your website to do

Annex I of the directive asks for websites and apps that people can perceive, operate and understand, and that work with assistive technology such as screen readers. Online stores carry extra duties on top: pass on the accessibility information that the responsible business provides about the products you sell, and make identification, security and payment steps accessible.

Payment is where most stores rely on someone else's code, and the annex names it directly. A checkout that only works with a mouse, or a passcode screen that a screen reader can't announce, is a direct gap in your compliance.

You also have to publish how your service meets the rules. Annex V asks for this information in your general terms and conditions or an equivalent document: a description of the service in accessible formats, an explanation of how it works, and how it meets the requirements in Annex I. Article 13 adds that this information must be public, in written and oral form, for as long as the service runs.

The directive itself doesn't name a technical standard. The W3C, which publishes the Web Content Accessibility Guidelines (WCAG), notes that most organisations address the Act through WCAG and the European standard EN 301 549. Ireland's National Disability Authority reports that EN 301 549 V4.1.1 was published on 2 September 2026 and references WCAG 2.2 Level AA instead of WCAG 2.1. Once the Commission cites it in the Official Journal, expected on 16 December 2026, meeting it gives a presumption of conformity with the Act.

Our recommendation is to build to WCAG 2.2 Level AA now. WCAG 2.2 has been a W3C standard since 5 October 2023, and fixing to 2.1 today means reopening the same templates within months.

Under this law, accessibility is a maintenance duty rather than a launch task. Article 13 requires procedures that keep the service compliant as it changes, and every new theme, plugin or landing page can undo what you fixed.

What is excluded, and which deadlines come later

A handful of website content types sit outside the European Accessibility Act, and the directive allows extra time in two narrow cases. None of these exclusions covers a live product page or checkout. Article 2(4) puts this content out of scope:

• pre-recorded audio and video published before 28 June 2025
• office files, such as PDFs and spreadsheets, published before that date
• online maps, as long as the information people need to find their way is also given in an accessible form
• third-party content that you neither fund, develop nor control
• archives, meaning content that is not updated or edited after 28 June 2025

Read the third-party line narrowly. A payment widget, review app or chat tool you pay for is funded by you, so don't rely on that exclusion for your checkout or your reviews section. It fits content like an embedded post from someone else's social media account.

Article 14 offers a different route: you can skip a requirement if meeting it would fundamentally alter your service or impose a disproportionate burden. The bar is procedural as well as financial. You assess the burden against the criteria in Annex VI, which weigh the net cost of compliance against your total costs and the benefit to people with disabilities, then document it, keep it for five years and hand a copy to the authorities if they ask.

Article 32's dates get quoted out of context, so take them one at a time. Service contracts agreed before 28 June 2025 may continue unchanged until they expire, for no more than five years. Products you already used to deliver a service before that date may stay in use until 28 June 2030. A website is not a product under the directive, which defines products as goods produced through a manufacturing process, so 2030 is not the deadline for your online store.

What happens if you ignore it

Each EU country sets its own penalties, and Article 30 requires them to be effective, proportionate and dissuasive, scaled to how serious the failure is and how many people it affects. A provider that knows its service falls short must also correct it and tell the national authorities in each country where the service is provided.

The courts have already tested this. On 4 June 2026, the Tribunal judiciaire de Caen ordered Carrefour France to make its website and app fully accessible within six months, with a penalty of €500 for every day of delay, according to French disability news site Faire Face. Two associations, ApiDV and Droit pluriel, brought the case. Carrefour argued that its site was already 71% accessible for blind and partially sighted users. The court held that an online store cannot be only a little accessible. It has to be accessible in full.

The ruling applied French law rather than the directive directly, but it shows how a European court reads "accessible" for an online store. Six months from the ruling date falls in early December 2026.

National details still decide individual cases. On 5 May 2026, a court in Lille rejected a similar claim against Auchan's online business because its revenue fell below a €250 million threshold in the French rule the claim relied on. The version of the rules in each of your markets matters as much as the directive.

Which accessibility fixes to make first

Fix the steps a customer takes to pay before anything else, then the six errors that appear most across the web. WebAIM's February 2026 scan of the top 1,000,000 home pages found detectable WCAG 2 failures on 95.9% of them, with an average of 56.1 errors per page, and 96% of those errors fell into six categories.

This is the order we would work in for a typical online store:

1. Complete a purchase using only the keyboard. Search, open a product, add it to the basket, check out, pay and reach the confirmation page. Every point where focus disappears or a pop-up traps you is a blocker for someone using a screen reader.
2. Raise text contrast. Low-contrast text turned up on 83.9% of home pages, and in stores it hides in sale badges, pale grey prices and placeholder text.
3. Write alt text for product images, which was missing on 53.1% of pages. Describe what a shopper needs to decide: colour, pattern, what comes in the box.
4. Label every form field. Missing labels showed up on 51% of pages, and placeholder text that vanishes once someone starts typing does not count.
5. Give every link and button a name. Empty links (46.3%) and empty buttons (30.6%) are classic store problems: icon-only basket, search and close buttons that a screen reader announces as "button" and nothing more.
6. Set the page language, missing on 13.5% of pages. It is one attribute, and it decides whether a screen reader reads your French storefront with a French voice.
7. Publish your accessibility information in your terms and conditions, as Annex V requires, with a contact route for reporting a barrier.
8. Add an accessibility check to every release, so a new theme or app can't quietly undo the work.

Skip the overlay widget that promises compliance from one line of script. It sits on top of templates that still contain the errors, and after the Carrefour ruling, a site that is partly accessible is a weak position to defend.

Picture a store with 2,000 product pages built from one product template, one basket and one checkout. Fixing contrast, labels and button names in those three templates repairs most of the site in one round of work, rather than 2,000 separate fixes.

Pros and cons of complying now

For a store that earns a real share of its revenue in the EU, complying now is worth the cost, and that cost is lowest before a complaint or a court order sets the timetable for you.

What you gain. The national laws share one directive and one European standard, so the same fixes count in every EU country you sell to. Shoppers who use screen readers, magnifiers or keyboard-only access can buy from you. Clear labels, readable contrast and named buttons also help the shopper squinting at a phone in bright sunlight, and alt text and proper headings give search engines a clearer picture of each page.

What it costs. Audits and fixes take developer time, and the work never fully ends because every release can break something. Parts of your store belong to other companies: your platform's checkout, your payment provider's card form, your review app. You can push those vendors and switch away from the worst ones, but you can't fix their code yourself. The move to WCAG 2.2 also leaves a site built only to WCAG 2.1 with some catching up to do.

There is one honest exception. A non-EU store with a handful of EU orders a year can decide the EU isn't worth serving and stop shipping there. That is a legitimate business choice. For the Melbourne brand earning a fifth of its revenue in Europe, it would be an expensive one.

Who should act now, and who can wait

• Online stores, marketplaces and booking platforms that sell to EU consumers and have 10 or more staff, or that pass both €2 million limits, should be fixing now. They have been in scope since 28 June 2025.
• Microenterprises are exempt from the service rules. Fix the six common errors anyway and plan for the day you outgrow the exemption.
• B2B-only sellers sit outside the e-commerce definition. Check whether any part of the site takes orders from individuals, such as a retail section.
• Agencies and developers building stores for clients who sell into Europe should make WCAG 2.2 Level AA the default specification for every new build.

A court gave one of Europe's largest retailers six months to finish the job. Most smaller stores can fix their checkout and main templates in less time than that, as long as they pick the start date themselves. Start with the checkout.

If you want a second pair of eyes on your store before an EU customer or a court finds the gaps, send us the URL through the Get a Quote form on our contact page, or email info@technomantraa.com.