European Accessibility Act: Does It Apply to Your Website?

In this guide, we at Talha Aslan and team focus on one practical question. Does the European Accessibility Act reach your website, and if so, what do you need to do? We cover scope, exemptions, standards, the accessibility statement, and a working checklist. Because many of our readers also sell in the United States, we add a separate section on the ADA. This article is general information, not legal advice; please talk to a lawyer about your specific situation.

The directive is in force, and EU member states have written it into their national laws. So in practice, the rules that bind you are the national rules of the country you sell into. For example, Germany implements it through a law called the BFSG. Still, every national law grows from the same directive, so the directive itself is the best place to start.

Which products and services does the European Accessibility Act cover?

Article 2 of the directive defines scope with two lists: one for products and one for services provided to consumers. According to the official text of Directive (EU) 2019/882, the services list includes:

• Electronic communications services, except transmission services for machine-to-machine services.
• Services providing access to audiovisual media services.
• Elements of air, bus, rail, and waterborne passenger transport, such as websites, apps, e-tickets, and travel information.
• Consumer banking services.
• E-books and dedicated software.
• E-commerce services.

On the product side, the list covers consumer computers and operating systems, payment terminals, ticketing and check-in machines, smartphones and similar communication devices, TV equipment, and e-readers. The European Commission summarizes the same list on its European Accessibility Act page.

For most website owners, the last line matters most. The other categories, in contrast, belong to specific industries. E-commerce, however, cuts across almost every sector. In short, a fashion brand, a furniture maker, and a spare parts shop all need to pay attention if they sell online to EU consumers.

Does your website count as an e-commerce service?

The directive defines e-commerce services with four elements. The service happens at a distance. It runs through websites or mobile apps by electronic means. It starts at the individual request of a consumer. Finally, it aims to conclude a consumer contract. When all four are present, your site is an e-commerce service.

Ask yourself these questions:

• Can visitors add products to a cart, place an order, or pay on your site?
• Do customers complete a contract on the site, such as a booking, subscription, or paid appointment?
• Are some of your buyers private individuals buying for personal use?
• Do some of those individuals live in EU countries?

If most answers are yes, you are probably in scope. On the other hand, a brochure site that takes no orders and forms no contracts may fall outside the definition. That said, the line is not always sharp. For example, a site with a quote form but no online payment deserves a closer look with legal counsel.

Once you know you are in scope, the first need is usually a technical inventory. Which templates, plugins, and checkout steps create barriers? Building that inventory and fixing issues at the design level is where professional web design services tend to save time compared with patching one plugin after another.

Why can a company outside the EU fall under these rules?

The directive defines a service provider as any natural or legal person who provides a service on the EU market or makes offers to provide such a service to consumers in the EU. So where the company is incorporated is not the deciding factor. What matters is whether the offer targets EU consumers.

So a US, UK, or Turkish brand that runs a German or French store page, shows prices in euros, and ships to EU addresses is making an offer to EU consumers. In that case, "we are not an EU company" is not a defense on its own.

Product sellers also meet the importer and distributor roles. The directive defines an importer as a person established in the EU who places a product from a third country on the EU market. As a result, your EU partners in the supply chain may ask you for documentation. This guide, however, focuses on the service side, meaning the online store experience.

Several signals strengthen the impression that you target EU consumers: pages in EU languages, euro pricing, delivery options to EU countries, EU country code domains, and ad targeting aimed at EU locations. If you are weighing domain options for new markets, our guide on .com vs country code domains walks through that decision.

Who benefits from the microenterprise exemption?

Article 4 exempts microenterprises that provide services from the service accessibility requirements and the obligations tied to them. The directive defines a microenterprise by headcount and by annual turnover or balance sheet total. Please check the current thresholds in the official text and in the national law of the country you sell into.

The limits of the exemption matter:

• It applies to services only. A microenterprise that makes or places products on the market is not automatically exempt from product requirements.
• It looks at the size of your business. Group structures, partner companies, and linked companies can affect the calculation.
• It can disappear as you grow. So review your status regularly instead of treating it as a one-time decision.

Also, the exemption is not a strong reason to skip accessibility. The directive asks member states to give microenterprises guidelines and tools, which tells you lawmakers expect small businesses to move in this direction too. Moreover, an accessible store works better for older shoppers and for anyone using a phone in bright sunlight.

What about B2B sellers and exporters?

The directive defines a consumer as a natural person who buys a product or receives a service for purposes outside their trade, business, craft, or profession. Therefore, a pure B2B portal that never forms consumer contracts may fall outside the e-commerce definition.

In practice, though, pure B2B setups are rarer than people think. Consider an example scenario. A machinery parts manufacturer runs an order portal for dealers. On the same site, a shop section also lets private buyers order small parts by card. That shop section is open to consumers, so the assessment changes.

For B2B exporters, we suggest two steps. First, map every sales flow on the site by asking who can buy through it. Then add any consumer-facing flow to your accessibility plan. For a wider view of how industrial companies structure their sites, see our article on manufacturing website design for dealers and export.

Which website content is excluded?

The directive explicitly excludes some content on websites and mobile apps. Because of this list, you do not have to rework every old file. Still, you should read it narrowly.

• Pre-recorded time-based media published before the rules began to apply, such as older videos.
• Office file formats published before the rules began to apply, such as older PDFs.
• Online maps for navigation, if the essential information is also available in an accessible digital form.
• Third-party content that the business neither funds, develops, nor controls.
• Archived content that is no longer updated or edited.

Here is the catch: a third-party component that you choose and control does not fit the exclusion. For example, if a payment widget you selected sits inside your checkout, users experience it as part of your store. Likewise, new product catalogs you upload today do not benefit from the old-file exclusion. That is one more reason to publish key information as HTML pages instead of PDF downloads.

How does the European Accessibility Act relate to WCAG and EN 301 549?

The directive itself does not list technical details. Instead, it says that products and services that follow EU standards referenced in the Official Journal are presumed to conform. In Europe, the core standard for ICT accessibility is EN 301 549, and its web requirements build on WCAG success criteria.

The W3C European Union policy page lists WCAG 2.2 as the WCAG version used for the European Accessibility Act. Also, standards get updated over time, so check the Official Journal of the EU for the currently referenced version.

The practical takeaway is simple. If you design and test your site against WCAG 2.2 Level AA, you stay close to both the directive's "perceivable, operable, understandable, and robust" principle and the standards-based approach that auditors use. We explain the WCAG principles and levels in detail in our guide to web accessibility and WCAG standards, so we will not repeat them here.

What does accessible mean in practice for an online store?

The directive's general service requirements ask that websites and mobile apps be perceivable, operable, understandable, and robust in a consistent and adequate way. They also call for information through more than one sensory channel, alternatives for non-text content, and sufficient contrast with adjustable spacing.

Translated into store terms, it looks like this:

• Perceivable: meaningful alt text on product images, captions on videos, and enough contrast between text and background.
• Operable: menus, filters, cart, and checkout that work with a keyboard alone, plus a visible focus indicator.
• Understandable: clear form labels and error messages that say what went wrong and how to fix it.
• Robust: correct HTML structure so that screen readers and other assistive tools recognize each component.

To check contrast quickly, try our color contrast checker. For keyboard navigation and focus order, our article on website keyboard navigation and focus order covers the steps in detail.

What should you check in checkout, login, and authentication?

The directive adds extra requirements for e-commerce services. Most importantly, identification, authentication, security, and payment functions that you provide as part of the service must be perceivable, operable, understandable, and robust. In addition, if the responsible economic operator supplies accessibility information about the products you sell, you should show it on the sales page.

In our field experience, stores most often get stuck at these points:

• Image puzzles for bot protection with no alternative method, which block some users completely.
• One-time code screens with a time limit and no clear way to extend the time or resend the code.
• Focus loss inside a payment provider pop-up, so keyboard users cannot enter or leave it.
• Card field errors shown by color alone, so screen reader users never hear what is wrong.

Many of these steps, in practice, come from third-party services. Even so, you chose the provider. So before arguing about responsibility, ask the provider for accessibility documentation and test the flow yourself.

Here is an example scenario. A shoe store offers guest checkout, but the postal code field has no real label, only gray placeholder text. Once the user starts typing, the hint disappears, and the screen reader announces an unnamed field. That tiny detail can stop a purchase. Therefore, test how each field sounds, not only how it looks.

Where should your accessibility statement live, and what goes in it?

Article 13 and Annex V ask service providers to prepare information that explains how the service meets the accessibility requirements. You include it in your general terms and conditions or an equivalent document, make it public, and present it in a form people with disabilities can access. You keep this information for as long as the service runs.

Under Annex V, the information should include, where applicable:

• A general description of the service in accessible formats.
• Descriptions and explanations needed to understand how the service operates.
• A description of how the service meets the relevant accessibility requirements in Annex I.

In practice, most stores publish a separate accessibility page linked from the footer and reference it in their terms of sale. Write it in plain language: the standard you target, known gaps, a contact channel, and how you last assessed the site. Our own accessibility page shows one way to structure it. Some national laws also require extra details, such as the name of the market surveillance authority, so check the law of each country you sell into.

How do the disproportionate burden and fundamental alteration exceptions work?

Article 14 says the accessibility requirements apply only to the extent that compliance neither fundamentally alters the basic nature of the product or service nor imposes a disproportionate burden on the business.

However, this is not an easy exit. The business makes the assessment itself, documents it, and hands a copy to the authority on request. A service provider that relies on the burden argument must renew that assessment when the service changes, when an authority asks, and at regular intervals. A business that receives outside funding to improve accessibility cannot rely on the burden argument at all.

Also, the assessment follows the criteria in Annex VI. "It felt expensive" is not enough. Our advice is to keep this article out of the center of your design decisions. On a modern e-commerce platform, most accessibility comes from the right templates, the right components, and good content habits. Cases that truly require a fundamental alteration are rare.

Who enforces the European Accessibility Act?

In the EU, the directive leaves enforcement to member states. Each country designates authorities that check whether services comply. If a service does not comply, the provider must take corrective action and inform the competent authorities in the countries where it offers the service.

On penalties, the directive requires them to be effective, proportionate, and dissuasive. They must also reflect how serious the non-compliance is and how many people it affects. The specific type and amount of penalties sit in national law and differ by country. For that reason, we do not quote figures here; check the current rules of each country you sell into on official sources.

Furthermore, the directive lets consumers and qualified organizations take action before national courts or authorities. In other words, risk does not come only from official inspections. Complaints can also start a process, which is why the contact channel on your accessibility page needs to actually work.

How does the ADA apply to business websites in the United States?

The ADA is a separate US law, and it works differently from the EAA. According to the Department of Justice guidance on web accessibility and the ADA, businesses open to the public are covered by Title III, and the department has consistently taken the position that ADA requirements apply to goods and services offered on the web.

However, the guidance also notes that the department has no regulation setting detailed technical standards for business websites. Businesses have flexibility in how they comply, but they still need to make their online offerings accessible. The guidance points to WCAG and the Section 508 Standards as helpful references. It also states that guidance documents have no legally binding effect on their own.

Also, the barriers it highlights will look familiar: poor color contrast, missing alt text, videos without captions, forms without labels or clear errors, sites that do not work with a keyboard, and information shown by color alone. So a store that meets WCAG 2.2 AA for its EU customers is also addressing the issues US guidance names most often. For state and local governments, separate Title II requirements apply, which this article does not cover.

EAA vs ADA: how do the two frameworks compare?

The table below compares the two frameworks and adds a quick scope check for sellers. It is only a starting point, so treat it as a guide and not a legal opinion; in borderline cases, consult a lawyer.

In short, one solid build can serve both markets. You will still need separate legal reviews, because documentation and enforcement differ.

Compliance checklist: what should you test on your site?

If you think you are in scope, work through the list below in order. It is a starting framework and does not replace a full WCAG audit.

1. Define the critical paths: home page, category, product detail, search, cart, account, checkout, and contact.
2. Complete each path from start to finish with a keyboard only. Make sure the focus indicator stays visible.
3. Listen to the same paths with a screen reader. Buttons and links should have meaningful names.
4. Check that alt text on product images actually describes the product.
5. Measure text and button contrast. Back up color-only warnings with text.
6. Look for visible labels, clear required field markers, and error messages that explain the fix.
7. Zoom the page and confirm that content stays visible without horizontal scrolling.
8. Check captions, pause controls, and an option to stop autoplay on videos and animations.
9. Test checkout and authentication, including third-party components, with the same methods.
10. Publish your accessibility information and link it from your terms of sale and footer.

This way, you capture both technical gaps and missing documents in one place. When you prioritize the findings, put anything that blocks a sale, such as checkout or login issues, at the top.

Which tasks can your team handle, and which need a specialist?

In practice, your team can handle most content work. For instance, writing meaningful alt text, adding captions, using a logical heading order, and replacing vague link text all require little technical skill.

Template and component issues, however, are different. A menu that ignores the keyboard, a filter panel that never announces its state, focus that vanishes in a checkout pop-up, or theme colors with weak contrast all need code and design changes. A small mistake at that level repeats on every page at once.

Testing also takes expertise. Automated scanners catch only part of the problems. Manual testing with a keyboard and a screen reader shows which issues actually stop a user. So we suggest you build content habits inside your team and leave template work and testing to experienced specialists.

If you use a chat assistant for customer support, include it in scope. An AI chatbot should open and close with the keyboard, announce new messages to screen readers, and never trap users inside a window.

Should you rebuild your site or remediate the current one?

We look at three questions here. First, does the current theme or platform allow accessible components? Second, do the problems cluster in a few templates, or are they spread across the whole site? Third, were you already planning a redesign soon?

If the issues sit in a handful of templates, remediation is usually enough. If the theme fights accessible patterns, however, every patch creates a new problem. In that case, a redesign gives a faster and cleaner result. Hotel sites with booking engines face this choice often, and our article on hotel website design for direct bookings shows how to build the booking flow right from the start.

Whichever route you choose, treat accessibility as a normal quality bar rather than a one-off project. When you add a new campaign page or payment method, run the same checklist again.

What else should you check on a multilingual store?

Stores that sell across Europe usually run several languages, so translation matters. Testing only one version and copying it to the others is not enough. During translation, alt text can go missing, button names can shrink, and error messages can stay in one language.

For each language version, we recommend these checks:

• Declare the page language correctly, because screen readers use it to choose pronunciation rules.
• Translate product image alt text as well. An English description does not help a French shopper.
• Write form labels, required field notes, and error messages in each language with the same clarity.
• Publish accessibility information in every language you sell in and link it to the matching terms of sale.

Also, long German words may not fit narrow buttons, which can cut text off or break layouts when users zoom. In short, every language is a small stress test for your design.

How do you keep compliance from slipping over time?

The directive asks service providers to have procedures that keep the service compliant. In other words, one audit and one report are not enough. When the service, the requirements, or the standards change, you need to take those changes into account.

Set up a light but steady routine:

• Give your content team a short writing guide for alt text, headings, and link text.
• Make keyboard and contrast checks a required step before any new template or plugin goes live.
• Track reports from your accessibility contact channel in a ticket system.
• Retest the critical paths at regular intervals and keep dated results.

Also, connect your privacy work with your accessibility work. For example, a cookie banner that cannot be closed with a keyboard hurts both accessibility and user experience. We cover the privacy side in our guide on how to build a GDPR compliant website.

Where should you start today?

To sum up, if you sell online to EU consumers and you are above the microenterprise line, the European Accessibility Act is not a theoretical topic for you. First, clarify your sales flows and company size. Next, test the critical paths for keyboard use, screen reader output, and contrast. Finally, publish your accessibility information.

Put simply, your team can run the content side. Templates, components, and checkout flows, however, benefit from an experienced eye. If you want to review your current site against WCAG 2.2 AA or build an accessible store for EU and US customers from day one, Talha Aslan and team can plan it with you as part of our business website design work. No team can guarantee legal compliance, but the right method makes the risk visible and reduces it step by step.