Web accessibility under the European Accessibility Act: what is required, where websites fail and how to fix it

Since 28 June 2025, member states have been required to apply the rules transposing the European Accessibility Act (EAA), Directive (EU) 2019/882 on the accessibility requirements for products and services. For businesses that sell to consumers online and are not microenterprises, this has, as a rule, made web accessibility a legal obligation, overseen by a supervisory authority and backed by penalties.

The legal position set out in this article was verified as of 16 September 2026. This article is not legal advice, and the situation of any specific business should be assessed by a lawyer.

What changed on 28 June 2025

Under Article 31 of the directive, member states had to adopt national legislation by 28 June 2022 and apply it from 28 June 2025. For company websites, the key provision is Article 3(30): an e-commerce service is a service provided at a distance through websites and mobile device-based services at the individual request of a consumer with a view to concluding a consumer contract. What matters, then, is whether a website or app is used to conclude a distance contract with a consumer, not whether the company regards itself as a technology business.

Who is covered and which exemptions apply

The directive covers selected products, such as computers, payment terminals and ATMs, as well as consumer services such as electronic communications, elements of passenger transport services, consumer banking services, e-books and e-commerce. A service sold exclusively to businesses generally falls outside this framework, while mixed sales need to be assessed case by case.

Microenterprises. The directive exempts microenterprises that provide services. Under Article 3(23), a microenterprise is an enterprise that employs fewer than 10 persons and whose annual turnover or annual balance sheet total does not exceed EUR 2 million. The directive refers to the Commission Recommendation concerning the definition of micro, small and medium-sized enterprises and requires its conditions to be genuinely met, not circumvented. Microenterprise status should therefore be verified, not assumed.

Fundamental alteration and disproportionate burden. The requirements apply only to the extent that they do not require a fundamental alteration of the basic nature of the service or impose a disproportionate burden. The criteria for assessing the burden include, for example, the ratio of the net costs of compliance to net turnover. The results of the assessment must be kept for five years from the last time the service was provided, and reliance on the exemption must be notified to the supervisory authority in writing.

Transitional rules. The requirements do not apply to services provided under contracts concluded before 28 June 2025 until those contracts expire, but no later than 28 June 2030. Nor do they apply to pre-recorded time-based media (such as videos) or office file formats (such as PDFs) published before 28 June 2025, or to archives whose content is not updated or edited after that date.

The directive and national law: what applies in your country

The European Accessibility Act is binding on member states, while businesses are bound only by national law. Each member state transposes the directive through its own legislation, and the details, such as supervision and penalties, differ from country to country.

If a service does not meet the requirements, the provider must inform the supervisory authority without delay, explaining the reasons and the corrective measures, and must then implement those measures. We recommend having a lawyer assess what the national differences mean for your business.

The technical standard: EN 301 549 and WCAG

The directive does not mention WCAG, the international standard for web content accessibility developed by the World Wide Web Consortium (W3C). Instead, it sets out functional requirements: a website must be perceivable, operable, understandable and robust. The last of these means that the website can also be interpreted correctly by assistive technologies, which help people with disabilities use a computer or phone. The requirements also cover sufficient contrast and alternatives to non-text content.

The testable criteria are provided by the European standard EN 301 549. For websites, it adopts the WCAG success criteria at Levels A and AA, which corresponds to Level AA conformance. The strictest level, AAA, is included in the standard for information only. Under the directive, a service that conforms to a harmonised standard whose reference has been published in the Official Journal of the EU is presumed to meet the requirements to the extent that the standard covers them. This is known as the presumption of conformity.

Status as of 16 September 2026: EN 301 549 v4.1.1, published in September 2026, is the first version prepared specifically for the EAA, and it adopts WCAG 2.2 instead of 2.1. However, it will only confer a presumption of conformity with the directive once its reference has been published in the Official Journal of the EU. Until then, according to AccessibleEU, the European Commission’s accessibility centre, the reference version remains v3.2.1 from 2021, which is based on WCAG 2.1 Level AA and was originally prepared for the directive on the accessibility of public sector websites. There is not yet any obligation to comply with the new version.

The W3C states that content conforming to WCAG 2.2 also conforms to WCAG 2.1, so for web accessibility we recommend aiming straight for WCAG 2.2 Level AA.

Where websites most often fail

Every year, the WebAIM Million analysis automatically tests the home pages of the one million most popular websites. In the February 2026 data, WCAG failures were detected on 95.9% of home pages, and six types of error accounted for 96% of all errors found. It is not a sample of your local market, but it does show where to start.

Contrast. Low-contrast text was found on 83.9% of home pages. WCAG success criterion 1.4.3, at Level AA, requires a contrast ratio of at least 4.5:1 between text and background, or 3:1 for large text. Light grey type may look elegant, but someone with loss of contrast sensitivity, which according to the W3C typically comes with ageing, will struggle to read it.

Alternative text. Text descriptions of images were missing on 53.1% of home pages. When a screen reader, software that reads content aloud or converts it into Braille, reaches an image without a description, it reads out the file name or nothing at all. To a blind customer, a basket icon without text is just a “button”.

Keyboard. People with motor impairments navigate by keyboard, and so do screen reader users. If they cannot reach the order button with the Tab key, they cannot complete the order. If the design hides the focus highlight on the active element, they cannot see where they are on the page.

Forms and error messages. Form field labels were missing on 51% of home pages. Grey placeholder text inside a field is no substitute for a label, because it disappears as soon as someone starts typing. An error marked only in red may not be recognised by someone with a colour vision deficiency, and an error message that the screen reader does not announce means an order that never goes through, with no explanation.

Captions and PDFs. A video without captions says nothing to deaf people or to anyone watching it without sound. To a screen reader, a scanned price list or set of terms and conditions is an image with no text. The transitional exemption does not apply to new files, and the description of the service in the terms and conditions must be available in accessible formats.

Why automated tests are not enough

An automated tool can check what is measurable in the code: the contrast ratio, whether alternative text and field labels are present, or a missing page language declaration, which can cause a screen reader to read text in one language with the pronunciation of another. It cannot tell whether an image description makes sense, whether the keyboard navigation order is logical, whether a pop-up can be closed or whether a purchase can be completed with a screen reader. WebAIM itself points out that automated tools do not detect all failures, so full WCAG conformance among the pages tested was certainly lower than 4.1%. Key user journeys need to be tested manually with a keyboard and a screen reader, ideally with people who use assistive technologies every day.

The business case, without exaggeration

According to Eurostat, in 2025, 24.2% of people aged 16 and over in the EU, and 26.0% in Slovakia, reported a moderate or severe limitation in usual activities due to health problems. Among those aged 65 and over, the figures were 47.5% in the EU and 58.4% in Slovakia. Not every limitation makes a website harder to use, but this is not a niche group. Moreover, according to the W3C, the number of people with disabilities is growing as the population ages.

The W3C also points out that accessibility helps in everyday situations: with a broken arm, in bright sunlight, in a noisy environment or on a slow connection.

The European Commission states that common rules are intended to reduce costs for businesses and make cross-border trade easier. We cannot reliably back up a percentage figure for how much accessibility increases revenue, so we do not promise one. Yet a visitor who fails to complete an order because of a barrier in the basket may have arrived via paid advertising. We look at how to calculate that kind of loss in the article When visitors do not understand your website.

What businesses should do: from inventory to ongoing monitoring

1. Inventory. List every point of contact with consumers: website, online shop, app, forms, PDFs and videos, as well as third-party components such as the payment gateway or chat.
2. Audit. Even an in-house team can run an automated test with a free tool. Supplement it with a manual walkthrough of key user journeys against WCAG 2.2 Level AA, and assign errors to components and templates rather than to screenshots.
3. Prioritisation. First tackle errors that block the completion of a purchase or order, then recurring errors in the most frequently used components.
4. Fix at source, not with patches. Fix each error at the point it spreads from: the template, component or design system. Contrast corrected in a colour token, that is, a centrally defined colour, takes effect everywhere at once. With an off-the-shelf e-commerce platform, it may be enough to adjust the theme or replace it with a more accessible one.
5. Accessibility information. A formal accessibility statement is an obligation for the public sector under Directive 2016/2102. Under the European Accessibility Act, service providers must use their general terms and conditions, or an equivalent document, to provide a description of the service in accessible formats, explain how it works and set out how it meets the accessibility requirements. This information must be made available in written and oral form, in an accessible format and for as long as the service is provided.
6. Ongoing monitoring. The legislation requires procedures that keep the service compliant even after changes. In practice, this means an automated test with every deployment, trained content authors and accessibility built into supplier briefs.

Accessibility from the outset versus retrofitted fixes

When web accessibility is only addressed after launch, you pay for it again and again. An illustrative example: a low-contrast button is not a single error but code copied into many templates. Every copy has to be found, fixed, tested and deployed, and every new page built from the old template repeats the error. The Cost of Friction model in the article Good design is not decoration shows how to put a figure on this kind of recurring friction.

The W3C cites a 2016 Forrester Research study commissioned by Microsoft, according to which accessibility integrated into regular development cycles can contribute to cost savings. As this is a commissioned study, it is a supporting argument, not independent proof.

That does not mean an old website has to be scrapped straight away. Errors spread across manually edited templates can be a sign that further patches no longer make economic sense, as we describe in the article When an old website starts costing your company money. Even then, adjusting the templates or theme may be enough. The choice between repair and rebuild should be driven by a diagnosis, not by what someone is selling.

Key takeaways

• Check with a lawyer whether the law applies to you: sales to consumers, the type of service, microenterprise status and exemptions. The legal position was verified as of 16 September 2026.
• For your website, aim for WCAG 2.2 Level AA. This also covers WCAG 2.1, on which the current reference version of EN 301 549 is based.
• An automated test is a filter, not an audit. Test the order and contact journeys with both a keyboard and a screen reader.
• Fix at source: in tokens, components, templates and content processes, not page by page.
• Carry out a diagnosis before choosing a tool, a supplier or a new website. Only that will show whether adjusting the theme is enough or whether the problem lies in the foundations.