MobileCheck

European Accessibility Act: What It Means for Your Website

Updated October 21, 2026

Short answer: The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025 to consumer-facing websites and apps for e-commerce, banking, passenger transport, e-books, electronic communications and audiovisual media access. Microenterprises (fewer than 10 staff and no more than EUR 2 million turnover or balance sheet) are exempt for services. In practice, sites aim for EN 301 549, which maps to WCAG 2.1 AA, and its 2026 edition to WCAG 2.2 AA.

The European Accessibility Act (EAA) is an EU directive that has applied since 28 June 2025. If you sell to consumers online, run a bank, sell e-books, or offer passenger transport or telecom services in the EU, your website and app must be perceivable, operable, understandable and robust for people with disabilities. Microenterprises that provide services are exempt. The practical benchmark is the European standard EN 301 549, whose web chapter points to WCAG 2.1 Level AA (and, in its 2026 edition, WCAG 2.2 AA).

This is not legal advice. The EAA works through each member state's own law, so details differ by country. Check the national law where you sell, or ask a lawyer.

What is the European Accessibility Act?

The EAA is Directive (EU) 2019/882 on accessibility requirements for products and services. A directive doesn't apply on its own: every member state had to write it into national law by 28 June 2022 and apply those rules from 28 June 2025. Germany did it with the Barrierefreiheitsstärkungsgesetz (BFSG), for example, and other countries passed their own acts. The aim is one set of accessibility rules across the single market instead of 27 different ones.

For websites and apps, the Act's requirements in Annex I repeat the four principles that also sit at the top of WCAG: content must be perceivable, operable, understandable and robust, including when used with assistive technology such as a screen reader.

Which websites does it cover?

The Act covers specific services provided to consumers (not business-to-business sales). Article 2 lists them:

ServiceWhat that means online
E-commerceAny website or app where a consumer can conclude a contract at a distance: online shops, booking sites, subscriptions
Consumer bankingOnline banking, payment services, credit agreements, investment services offered to consumers
Passenger transport (air, bus, rail, waterborne)Websites, mobile apps, e-tickets and real-time travel information
E-booksE-books and the software used to read them
Electronic communicationsTelecom providers' sites and apps, including customer service
Access to audiovisual mediaWebsites and apps that give access to TV and streaming services

For urban, suburban and regional transport, only the interactive self-service terminals are covered, not the website. The Act also covers products such as computers, smartphones, ATMs, ticket machines and e-readers, but this guide sticks to websites.

Some web content is excluded: pre-recorded video and audio and office documents published before 28 June 2025, online maps (if the essential information is also given in an accessible way), third-party content you don't fund, develop or control, and archives that aren't updated or edited after 28 June 2025. Because enforcement is organized by the member states where a service is provided, a company based outside the EU that sells to EU consumers should assume it is in scope.

The microenterprise exemption

Microenterprises providing services are exempt from the service accessibility requirements (Article 4(5)). The Act defines a microenterprise as one with fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million. Small and medium businesses above that line are not exempt. There is also a "disproportionate burden" defense (Article 14), but you must document the assessment, keep it for five years, renew it at least every five years and tell the authorities you rely on it. It is not a blanket opt-out.

Since when does it apply?

The transition period is about old contracts and hardware. A website or app you change after June 2025 doesn't get extra time.

Which standard should a website meet?

The Act describes outcomes, not code. Article 15 says that services meeting a harmonised standard whose reference is published in the Official Journal of the EU are presumed to meet the requirements. For digital services that standard is EN 301 549, from ETSI, CEN and CENELEC:

The practical advice is the same either way: build to WCAG 2.2 Level AA. It includes everything in WCAG 2.1 AA plus a few criteria that matter a lot on phones, such as a 24 × 24 px minimum tap target. Our WCAG 2.2 checklist for mobile websites walks through the ones that matter most on a small screen. Beyond WCAG, the Act also asks for things a standard can't test in code, such as accessible support services and information about the service.

Do I need an accessibility statement?

The Act requires service providers to publish information on how the service meets the accessibility requirements (Article 13 and Annex V). It belongs in the general terms and conditions or an equivalent document, and should include a general description of the service in accessible formats, the explanations needed to understand how it works, and how it meets the relevant requirements. Many national laws and regulators call this an accessibility statement. A clear page linked from your footer, stating which standard you follow, known gaps and how to contact you about a barrier, covers the spirit of the rule; check your country's exact wording.

Who enforces it, and what are the penalties?

Each member state designates authorities to check services, follow up complaints and verify fixes (Article 23). Consumers, and organizations acting for them, must be able to take action before courts or administrative bodies (Article 29). Penalties are set nationally and must be "effective, proportionate and dissuasive" (Article 30), so amounts vary. In Germany, for example, offering a service that doesn't meet the requirements can be fined up to EUR 100,000 under BFSG § 37. When a service doesn't comply, the provider must also fix it and inform the authorities in the countries where the service is offered.

A practical checklist for your mobile site

Most online shopping happens on phones, so start there. These checks cover the problems that show up most often on small screens:

  1. Readable text — body text around 16px, nothing important under 12px. See text too small on mobile.
  2. Contrast — at least 4.5:1 for normal text and 3:1 for large text and for icons and input borders. See low-contrast text.
  3. Tap targets — buttons and links at least 24 × 24 CSS px, ideally 44–48px. See tap targets.
  4. Zoom allowed — no user-scalable=no in the viewport tag. See zoom disabled.
  5. Large text works — nothing is clipped or overlaps when the phone's text size is raised. See large text settings.
  6. No sideways scrolling at 320 CSS px wide.
  7. Labels and names — every form field has a label, every icon button has an accessible name, every informative image has alt text.
  8. Checkout and login — work with a screen reader (VoiceOver on iPhone, TalkBack on Android), allow pasting passwords and password managers, and show errors in text, not only in red.
  9. Accessibility statement published and linked from the footer.
<!-- A viewport tag that allows zoom -->
<meta name="viewport" content="width=device-width, initial-scale=1">

How do I check my site?

Start with an automated pass. The free MobileCheck test loads your page on real iPhone (WebKit) and Android (Chromium) screens and flags small text, low contrast, small tap targets, sideways scrolling, disabled zoom and text that breaks at 150% size, plus common markup problems such as missing alt text and form labels. That finds the most frequent barriers quickly, but no automated tool can confirm conformance: keyboard use, screen reader announcements, meaningful alt text and understandable errors need a person. Test your key journeys (find a product, add to cart, pay, log in) by hand with VoiceOver and TalkBack, and keep notes for your statement.

Selling in the US too? Read ADA website compliance for how the American rules differ.

Frequently asked questions

Does the European Accessibility Act apply to my small business website?

Only if you provide a covered service, such as e-commerce, to consumers. Microenterprises with fewer than 10 employees and no more than EUR 2 million in annual turnover or balance sheet total are exempt from the service requirements; larger small businesses are not.

Does the EAA require WCAG 2.1 or WCAG 2.2?

The Act itself names no WCAG version. The harmonised standard EN 301 549 V3.2.1 points to WCAG 2.1 AA, and V4.1.1, published in September 2026, moves to WCAG 2.2 AA. Meeting WCAG 2.2 AA covers both.

Does the EAA apply to companies outside the EU?

Enforcement follows the member states where the service is provided, so a non-EU company selling to consumers in the EU should assume the national rules of those countries apply to it.

What are the fines for not complying with the EAA?

Each member state sets its own penalties, which must be effective, proportionate and dissuasive. Germany, for example, allows fines of up to EUR 100,000 for offering a non-compliant service.

Sources

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