EAA 2025: is your website accessible under EU law?

The European Accessibility Act applies since 28 June 2025. Who must comply, what WCAG 2.1 AA actually requires, and how to check your site — without the legal jargon.

Key takeaways

Key takeaways: The European Accessibility Act (EU Directive 2019/882) applies since 28 June 2025. For websites it means meeting WCAG 2.1 level AA via EN 301 549. It covers B2C e-commerce and similar services, exempting service microenterprises (under 10 staff and up to EUR 2M turnover). Overlay widgets do not deliver compliance. Final legal assessment belongs to a lawyer.

What the European Accessibility Act actually is

The European Accessibility Act (EAA, EU Directive 2019/882) is the EU law requiring many digital products and services to be accessible to people with disabilities. It has applied since 28 June 2025. For websites the practical question is simple: can a person using a screen reader, keyboard-only navigation or high-contrast mode actually use your site and complete a purchase?

The EAA does not invent a new technical standard. It points to WCAG 2.1 level AA through the European standard EN 301 549. So "EAA compliance" for a website means, in practice, meeting WCAG 2.1 AA. That single mapping is the most useful thing to remember: when someone asks whether your site is "EAA compliant", they are really asking whether it passes WCAG 2.1 AA.

Does the EAA apply to your website?

The short version: if you sell online to consumers (B2C) in the EU and you are not a microenterprise, it most likely applies to you. The scope is defined by what you sell and how large you are, summarised below:

CategoryStatusDetail
E-commerce, online banking, ticketing, e-booksCoveredConsumer-facing digital services
Service microenterprisesExemptFewer than 10 people and up to EUR 2 million annual turnover
Pure B2B sitesGenerally outside scopeLine blurs once you also sell to consumers

Enforcement and fines are set by each member state, not by the directive itself. The amounts and the responsible authority differ by country. For your specific exposure, confirm with a qualified lawyer in your jurisdiction. We confirm the technical side in a free mini-audit.

What does "accessible" mean in practice (WCAG 2.1 AA)?

WCAG is built on four principles: content must be Perceivable, Operable, Understandable and Robust. For a typical business site or shop, AA compliance comes down to a concrete checklist rather than abstract theory:

  • Colour contrast — text vs. background at least 4.5:1 (3:1 for large text).
  • Keyboard operability — every function usable without a mouse, with a visible focus indicator.
  • Text alternatives — meaningful alt text on images, labels on form fields.
  • Structure — correct heading order (one H1, logical H2/H3), landmarks, lists marked up as lists.
  • Forms — errors announced clearly, fields associated with labels, no colour-only error signalling.
  • Media — captions for video, no content that flashes more than three times per second.

None of this is exotic. It is mostly disciplined HTML and CSS, which is why a clean rebuild often costs less than retrofitting a messy template.

What are the most common accessibility failures?

Most sites fail on the same handful of points, and most are cheap to fix once identified. In our audits these six issues appear again and again:

  • Low-contrast grey-on-white body text and light placeholder text.
  • Buttons and icons with no accessible name, so a screen reader reads "button, button, button".
  • Images carrying meaning with empty or missing alt text.
  • Forms where the error state is shown only by a red border.
  • Custom dropdowns and modals that trap or skip keyboard focus.
  • Multiple H1s or skipped heading levels that break navigation for screen-reader users.

The pattern is consistent: the problems are in the markup and the styling, not in some special "accessibility layer". Fix the source and most of the failures disappear at once.

Why are overlay widgets not compliance?

Overlay widgets do not deliver compliance. You have probably seen the floating "accessibility" button that promises instant conformance. It sits on top of the page and does not fix the underlying HTML. Accessibility advocates and several regulators have repeatedly warned against relying on these tools.

The risk is not only that overlays fail to help. Some have been the subject of lawsuits rather than a defence against them, so a widget bought for protection can become a liability. Real compliance means fixing the source: the markup, the contrast, the focus order and the form labels. That is what survives an audit and an actual user with assistive technology. There is no shortcut button for it.

How do you check your site?

A useful check has two layers, because automated tools alone are not enough. Scanners catch the mechanical issues; a human catches everything that depends on real interaction:

  • Automated scan (e.g. axe-core) catches roughly 30-40% of WCAG issues: contrast, missing alt text and basic structure.
  • Manual expert review covers the rest: real keyboard navigation, screen-reader behaviour, focus management and meaningful sequence.

The output you want is a prioritised list: what fails, which WCAG criterion it maps to, and the specific fix, not a generic score. Our own site scores 100/100 in this audit, and we run the same process on yours. The point is not a badge but a clear, costed path to conformance you can actually hand to a developer.

Where to start

If you sell to consumers in the EU, the safe move is to know where you stand before someone else points it out. Start with a check: an automated scan plus a manual review, a prioritised fix list and a clear scope for remediation.

See our EAA / WCAG 2.1 AA accessibility audit for e-commerce, or open our services and pricing. We fix the source, not a bolted-on widget. The technical audit gives you certainty on the code; the final legal assessment of your specific obligations belongs to a qualified lawyer in your country.

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