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European Accessibility Act: what small teams actually have to do

Updated October 24, 2026. By All the Possibles.

The law has applied since 28 June 2025. Most small teams know that much and little else, so this page sticks to what the text of the Directive says and marks what I could not confirm.

What the law is

The European Accessibility Act is Directive (EU) 2019/882. Member States had to adopt and publish national laws by 28 June 2022 and apply them from 28 June 2025 (Article 31). That means the rule that binds you is your country's implementing law, and the authority that checks you is a national one. Article 30 leaves penalties to each Member State, with the only constraint that they be effective, proportionate and dissuasive. I am not going to quote fine amounts, because they differ by country and I have not verified them for any.

What it covers

Article 2(2) lists the services provided to consumers: e-commerce services, consumer banking services, e-books and dedicated software, electronic communications, services that give access to audiovisual media, and the websites, apps, e-tickets and travel information of air, bus, rail and waterborne passenger transport. Article 3 defines e-commerce services as services provided at a distance, through websites and mobile apps, by electronic means. Article 2(1) covers products such as payment terminals, e-readers, consumer computers and the operating systems on them, and self-service terminals like ticket machines and cash machines.

The scope is consumers. Article 3 defines a consumer as a natural person who buys the product or receives the service. If every customer you have is a company, the services provision does not obviously reach you, but I would not stake a launch on my reading of that sentence. Ask a lawyer in the country where you sell. Whether the Act reaches businesses established outside the EU that sell to EU consumers is also a question I did not verify against the official text, so I make no claim either way.

Who is exempt

Article 4(5) exempts microenterprises that provide services from the service accessibility requirements and the obligations that go with them. Article 3(23) defines a microenterprise as an enterprise that employs fewer than 10 people and has either annual turnover or an annual balance sheet total of no more than EUR 2 million. The exemption is for services. A microenterprise that makes products does not get it.

Article 14 adds a second route for anyone: you do not have to meet a requirement if doing so would fundamentally alter the basic nature of the product or service, or impose a disproportionate burden. You have to run the assessment against the criteria in Annex VI, document it, keep it for five years, and for services renew it when the service changes and at least every five years. You also have to tell the national authority you are relying on it, except that microenterprises do not have to notify. Money you received to improve accessibility closes this route.

Article 32 gives a transition for service contracts agreed before 28 June 2025, which may continue unchanged until they expire and for no more than five years, and a longer one for self-service terminals. Neither helps a web shop with new customers.

What you have to publish

Under Article 13 and Annex V, a service provider prepares information on how the service meets the Annex I requirements and puts it in its terms and conditions or a similar document. Where relevant that includes a general description of the service in accessible formats and the explanations needed to understand how it works. Annex I, Section III, says websites and apps must be accessible "in a consistent and adequate way" and that support channels must give accessibility information in accessible ways. Section IV adds that identification, security and payment functions in e-commerce have to be perceivable, operable, understandable and robust.

The Directive does not hand you a template called an accessibility statement. The public-sector rules have one; this law asks for information in your terms. Write it as a plain page and link it from the footer and the terms.

Annex V also lets you apply harmonised standards referenced in the Official Journal. The standard people reach for is EN 301 549, which draws on WCAG. I could not confirm from an official source which version is currently cited for this Directive, so treat "WCAG 2.2 AA means compliant" as a working assumption and not a legal guarantee.

A checklist for one month

  1. Decide whether you are in scope: consumer customers, one of the Article 2 service types, and above the microenterprise line. Write the answer and the date down.
  2. Run an automated audit on your home page, product page, cart, checkout, sign-in and contact page. The Designers page audit is free and names the WCAG criterion behind each finding.
  3. Fix the template-level failures first: page language, document titles, alt text, form labels, link and button names, heading order, a skip link.
  4. Keyboard-test checkout and account sign-in yourself, unplugged mouse, start to finish. Automated tools cannot do this for you.
  5. Check contrast and target size on the real design (the WCAG 2.2 checker does both in the page).
  6. Check that support is reachable through an accessible channel and that the contact details appear on every page in the same place.
  7. Publish the accessibility information in your terms, with a working way to report a barrier and a date.
  8. Put a repeat of the audit in your release routine so the page stays true.

Where the tools stop

An automated scan reads markup. It cannot judge keyboard behaviour, focus order, captions, or whether alt text is any good. Most WCAG criteria need a person (54 of the 55 rows in the sample report are Not Evaluated), which is why the draft conformance report marks most rows Not Evaluated. Use it to organise the manual testing, not to replace it.

The page audit is free. The conformance report and the multi-page site crawl are part of Designers Pro, $5 a month with a 7-day trial; that is the one place paying changes what you can do here.

If you want a finished draft rather than the tools, the Accessibility Readiness Report is $149 once: one site, up to ten pages, a findings list by WCAG 2.2 criterion, a VPAT-style table, a fix list and a statement draft, delivered as a private link. It is an automated draft, not legal advice or a certification.

Sources

This is a reading of the text by a tool builder, not legal advice.

Questions people ask

Does the European Accessibility Act apply to my small business?

It applies to the products and services in Article 2 of Directive (EU) 2019/882, such as e-commerce, consumer banking, e-books, electronic communications and passenger transport websites. Microenterprises that provide services (fewer than 10 people and turnover or balance sheet total of EUR 2 million or less) are exempt from the service requirements under Article 4(5). Product manufacturers are not covered by that exemption. National law and national authorities decide enforcement, so check your country.

Do I need a published accessibility statement?

The Directive does not use the phrase. Article 13 and Annex V require service providers to put information about how the service meets the accessibility requirements into their terms and conditions or a similar document, in accessible formats. A page that says so, and says how to report a problem, is the practical way to do it.

Is WCAG 2.2 AA enough to comply?

The Directive sets functional requirements in Annex I and does not name WCAG. The European standard EN 301 549 is the one commonly used to demonstrate them, and it builds on WCAG. Whether a given standard version gives a legal presumption of conformity depends on its citation in the Official Journal; confirm the current status before you rely on it.