European Accessibility Act requirements: what your website has to do

It applies if you offer one of the covered services to consumers in the EU, and you are not exempt as a microenterprise. Ecommerce is explicitly covered, which is what brings most websites into scope. Business-to-business selling is not the target of the Act; selling to consumers is.

The covered services include ecommerce, consumer banking services, e-books and dedicated software, electronic communications services, services providing access to audiovisual media, and defined elements of air, bus, rail and waterborne passenger transport. The Act also covers products — computers and their operating systems, self-service terminals, e-readers, and consumer terminal equipment used for electronic communications.

Two points are commonly misread. First, the Act follows the service, not the company’s head office: if you sell to consumers in the EU, the fact that you are established elsewhere does not remove the obligation. Second, an intranet or a purely business-to-business portal is a different question — one worth putting to your legal advisor rather than assuming either way.

The Act sets functional accessibility requirements rather than a list of technical instructions. Information must be available through more than one sensory channel, presented in a way users can perceive, and written in language proportionate to the complexity of the service. Interfaces must support assistive technology and be operable without relying on a single input method.

In practice, for a website, this is where the harmonised European standard comes in. Meeting a harmonised standard gives a presumption of conformity with the legal requirements — which is why accessibility work in Europe is measured against EN 301 549, the standard that adapts the Web Content Accessibility Guidelines for European legislation.

That is the practical translation of the law: keyboard access that works, focus you can see, contrast you can read, form fields with real labels, images with meaningful alternatives, error messages that explain themselves, and a page structure a screen reader can navigate.

The 2025 date is when the obligations started applying, not a cut-off after which everything must already be perfect. The Act allows several transitional arrangements — including continued use of products that were already lawfully in service, and existing service contracts running to their term within a limited window. These provisions buy time for equipment and contracts. They do not create a general grace period for a website you can redesign at will.

Enforcement is national. Each Member State designates the authorities responsible for market surveillance and for checking service compliance, and each sets its own penalties. That means the exposure depends on where your customers are, and the same non-conformity can be handled quite differently in two countries.

There is a second consequence that arrives sooner than any authority. Consumers and representative organisations can bring complaints under national procedures, and public sector buyers increasingly ask for conformity evidence in procurement. In several markets, the first practical cost of an inaccessible site is not a fine — it is being screened out of a tender.