Short answer: The European Accessibility Act has applied since 28 June 2025 to e-commerce and certain other services provided to consumers in the EU, including their websites and apps. Microenterprises providing services, with fewer than 10 people and no more than EUR 2 million annual turnover or balance sheet, are exempt. This is general information, not legal advice.
The European Accessibility Act has been applying since 28 June 2025, and a lot of business owners still aren't sure whether it concerns them. Some have heard it applies to every website in Europe. Others have heard it's only for banks and airlines. Neither is quite right.
This article explains what the law says about websites and online shops, in plain words, based on the text of the directive itself. It is general information, not legal advice. If you need to know exactly where your business stands, talk to a lawyer who knows the national law in the countries where you sell.
What the law is
The European Accessibility Act is Directive (EU) 2019/882. It sets common accessibility requirements for certain products and services across the EU. Because it's a directive, each Member State had to write it into its own national law, and the deadline for that was June 2022. The rules apply from 28 June 2025 (Article 31). Enforcement, and the penalties for not complying, are set at national level, so the details vary between countries.
Which websites does the European Accessibility Act cover?
The Act doesn't cover every website. It covers websites and apps that are part of specific services provided to consumers. The ones most relevant to small and mid-size businesses are:
- E-commerce services. The directive defines these as services provided at a distance, through websites and mobile apps, by electronic means, at the consumer's request, with a view to concluding a consumer contract (Article 3). In practice: if consumers can buy from you online, your shop is likely in scope. That applies to selling services online as well as products.
- Consumer banking services.
- Passenger transport services by air, bus, rail and water, including their websites and apps.
- Electronic communications, access to audiovisual media services, and e-books.
A brochure site that describes what you do, with a contact form and no way to buy anything, is not an e-commerce service in the sense the directive uses. A site that sells only to other businesses is also, on the face of the definition, outside it, because the definition talks about consumer contracts. Both of these are areas where national law and your specific setup matter, so treat them as a starting point for a conversation with a lawyer, not a conclusion.
Are very small businesses exempt?
Microenterprises that provide services are exempt from the service requirements (Article 4(5)). The directive defines a microenterprise as one that employs fewer than 10 people and has an annual turnover, or an annual balance sheet total, of no more than EUR 2 million (Article 3).
Two things to note. First, the exemption covers services, which includes e-commerce. It doesn't change the rules for physical products. Second, businesses grow. If you're close to either threshold, it's sensible to build accessibly now rather than retrofit later.
What "accessible" means here
For websites and apps, the directive says they must be made accessible by making them "perceivable, operable, understandable and robust" (Annex I, Section III). Those four words will be familiar to anyone who has read the Web Content Accessibility Guidelines (WCAG), which are built on the same four principles. The directive also allows businesses to rely on harmonised standards to show they comply.
In everyday terms, that means things like:
- Images that carry meaning have text alternatives a screen reader can read out.
- Everything works with a keyboard, not only a mouse.
- Text has enough contrast against its background and can be enlarged without the layout breaking.
- Forms have proper labels, and error messages say what went wrong and how to fix it.
- Videos have captions.
- The code is built properly, so assistive technology can make sense of it.
Extra points for online shops
For e-commerce, the directive adds a few specific requirements (Annex I, Section IV):
- Accessibility information about the products and services you sell, where the responsible operator provides it.
- Identification, security and payment functions that are themselves accessible, when they are delivered as part of the service.
That last point matters. A shop where the product pages are accessible but the checkout can't be completed with a keyboard has not solved the problem. The checkout is usually where it goes wrong.
What you have to publish
Service providers must prepare information explaining how their service meets the accessibility requirements, and make it available to the public, including in accessible formats (Article 13 and Annex V). The directive says this goes in your general terms and conditions or an equivalent document. It should include a general description of the service in accessible formats, the explanations needed to understand how it works, and a description of how it meets the relevant requirements.
Many businesses publish this as an accessibility statement linked from the footer, alongside the terms.
The "disproportionate burden" exception
The directive says the requirements apply only where they don't fundamentally change the nature of the service or impose a disproportionate burden on the business (Article 14). This isn't a blanket opt-out. You have to make the assessment yourself, document it, and for services renew it when the service changes, when authorities ask, and at least every five years. The recitals are blunt about it: lack of priority, time or knowledge isn't a legitimate reason.
What about businesses outside the EU?
The Act is about services provided to consumers in the EU. If you're based in the UK, the US, Canada or Moldova and your online shop sells to consumers in EU countries, it's worth taking seriously and checking with a lawyer how the national rules apply to you. Separately from the law, an accessible site is simply usable by more people, which is a reasonable thing to want from a shop.
Where to start
- Work out whether you're in scope. Do consumers buy from you online? Are you above the microenterprise thresholds?
- Test the main journeys. Finding a product, adding it to the basket, checking out, logging in, contacting you. Try them with only a keyboard, and with a screen reader.
- Check the parts you didn't build. Payment widgets, cookie banners, chat tools and booking calendars from third parties are a common source of problems.
- Fix the biggest blockers first. Something a customer can't get past matters more than something that's merely awkward.
- Write the accessibility information and keep it current.
- Build it into how you work. Every new page, feature and campaign should be checked before it goes live, not audited once a year.
Sources
This article is based on the text of Directive (EU) 2019/882 on EUR-Lex and the European Commission's page on the European Accessibility Act. National laws implementing the directive may add detail, so check the rules in the countries where you sell.
If you'd like your shop or site checked against these requirements, a technical website audit includes that check. If you'd like it built accessibly from the start, our web development page explains how we work, and product design covers the screens themselves. Or book a free call. We can tell you where the obvious problems are. Whether you're legally in scope is a question for your lawyer.