What the European Accessibility Act means for a website that sells into the EU

Since 28 June 2025, the European Accessibility Act has required e-commerce sites and several other consumer services offered to people in the EU to be accessible to people with disabilities. It applies to any business offering those services to EU consumers, including businesses based outside the EU, and exempts microenterprises (fewer than 10 staff and no more than 2 million euros in annual turnover or balance sheet). In practice, that means meeting the European standard EN 301 549, which currently points to WCAG 2.1 Level AA, and publishing information on how your service meets the requirements.

This is general information, not legal advice. The Act is enforced through each member state's own law, so check the rules in the countries you sell into.

What is the European Accessibility Act?

It is Directive (EU) 2019/882, adopted in 2019. Member states had to write it into national law by 28 June 2022 and apply those laws from 28 June 2025 (Article 31). Germany's version, for example, is the Barrierefreiheitsstärkungsgesetz (BFSG). France added the obligation to its Consumer Code.

It covers certain products, such as computers and e-readers, and certain services. For website owners the services part is what matters.

Does it apply to us if we are not based in the EU?

Very likely, if you sell to EU consumers. The Directive defines a service provider as anyone "who provides a service on the Union market or makes offers to provide such a service to consumers in the Union" (Article 3). Where your company is registered does not appear in that test. A shop in India, the US or the UK that sells to customers in France or Germany is covered by that wording.

Which websites are covered?

Article 2 lists the services covered when provided to consumers after 28 June 2025:

e-commerce services
consumer banking services
e-books and dedicated software
electronic communications services
services providing access to audiovisual media services
websites, apps, e-tickets and travel information for air, bus, rail and waterborne passenger transport

The Directive defines e-commerce services as services provided at a distance "through websites and mobile device-based services" at the request of a consumer "with a view to concluding a consumer contract." An online shop plainly qualifies. So do booking and subscription sites where consumers sign up and pay.

A consumer is a person buying outside their trade or profession. A purely business-to-business service falls outside the definition. A brochure site that does not sell anything is harder to call, so take advice if yours sits on the line.

Are small businesses exempt?

Microenterprises that provide services are exempt from the accessibility requirements (Article 4(5)). The Directive defines a microenterprise as one that "employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million."

A business above that size can also rely on Article 14 if full compliance would fundamentally alter the service or impose a disproportionate burden. That is a formal assessment, using the criteria in Annex VI, and it has to be documented and kept for five years after the service was last provided. Authorities can ask to see it. It is a narrow route, and it does not work as a general opt-out.

What content on the site is excluded?

Article 2(4) leaves some website content out of scope:

pre-recorded audio and video published before 28 June 2025
office files such as PDFs and Word documents published before 28 June 2025
online maps, if the essential information is provided accessibly for maps used for navigation
third-party content you neither fund, develop nor control
archived content that is not updated or edited after 28 June 2025

New or updated material after that date is in scope.

Is there a transition period?

Article 32 has two transitional measures. Service contracts agreed before 28 June 2025 may continue unchanged until they expire, for no longer than five years from that date. Service providers may also keep providing services using products they were lawfully using before that date, until 28 June 2030. Neither measure is a general grace period for websites, and member states implement the details.

What standard does our website have to meet?

The Directive sets functional requirements. For services, Annex I asks providers to make websites and apps "perceivable, operable, understandable and robust," which are the four principles WCAG is built on. It does not name a WCAG version.

Article 15 says a service that conforms to a harmonised European standard is presumed to meet the requirements. That standard is EN 301 549. According to the European Commission's AccessibleEU centre, a new version, v4.1.1, was published in September 2026 and adopts WCAG 2.2. Until the Commission cites it in the Official Journal, the current reference remains v3.2.1, which is based on WCAG 2.1 Level AA.

For a website being built or rebuilt now, WCAG 2.2 Level AA is the sensible target. It includes everything in 2.1 and matches where the European standard is heading.

What do we have to publish?

Article 13 and Annex V require service providers to explain how their service meets the accessibility requirements. The information goes in the general terms and conditions "or equivalent document" and should include a general description of the service in accessible formats, an explanation of how it works, and a description of how the relevant requirements are met. It must be available in a way that disabled people can use, and kept for as long as the service runs.

What happens if we do not comply?

Each member state sets its own penalties. Article 30 requires them to be "effective, proportionate and dissuasive" and to take into account how serious the failure is and how many people are affected.

Two examples:

Germany. Section 37 of the BFSG allows fines of up to 100,000 euros for the most serious breaches and up to 10,000 euros for others.
France. On 4 June 2026 the Caen judicial court ordered Carrefour France to make its grocery website and app fully accessible within six months, with a daily penalty for delay, in a case brought by the disability associations apiDV and Droit Pluriel. Carrefour had argued it already met 71% of the accessibility criteria. The court's reply, as reported by Droit Pluriel, was that an e-commerce site "cannot be only somewhat accessible, it must be totally accessible." In a similar case, a Lille court found that Auchan's e-commerce company was not subject to the obligation, and the associations have appealed.

What should a business selling into the EU do now?

Confirm whether you are in scope: consumer sales, the services listed in Article 2, and your headcount and turnover.
Have the site audited against WCAG 2.2 Level AA, covering the full purchase journey from landing page to payment confirmation.
Fix the blocking issues in checkout, account and contact flows first, then shared templates, then content.
Publish the Annex V information and link it from your terms and your footer, with a way for customers to report problems.
Build accessibility checks into how new pages, products and campaigns are published.

Questions people also ask

Does the European Accessibility Act apply to UK or US companies?

Yes, when they offer covered services to people in the EU. The Directive looks at where the service is offered, and a company's home country is not part of that test.

Is WCAG 2.1 AA enough for the European Accessibility Act?

For now it matches the current reference version of EN 301 549. The updated version published in September 2026 adopts WCAG 2.2, so a site built to 2.2 AA is better placed once that version is formally cited.

Do B2B websites have to comply?

The Act covers services provided to consumers, meaning people buying outside their trade or profession. A site that sells only to businesses generally falls outside it, though a site that sells to both is in scope for its consumer sales.

Who enforces the European Accessibility Act?

Each member state names its own authorities and sets its own penalties. Courts can also hear cases brought by others, as the French cases filed by disability associations show.