European Accessibility Act: What It Means for Your Website (2026)

The short answer: the European Accessibility Act (EAA), Directive (EU) 2019/882, sets common accessibility requirements for a closed list of products and services. Its service rules apply to services provided to consumers after 28 June 2025, such as online shops, consumer banking and e-books. If you offer one of these to consumers in the EU and are not a microenterprise, your website and app have to be perceivable, operable, understandable and robust, which in practice means WCAG level AA. This is general information, not legal advice.

What the European Accessibility Act is

The EAA is an EU directive from 2019. A directive does not bind businesses directly: each member state had to adopt its own law by 28 June 2022 and apply it from 28 June 2025. Germany did so with the Barrierefreiheitsstärkungsgesetz (BFSG) and Austria with the Barrierefreiheitsgesetz (BaFG); the core requirements are the same across the EU.

For websites and apps, Annex I asks for one thing: making them accessible “by making them perceivable, operable, understandable and robust”. Those are the four principles of the Web Content Accessibility Guidelines (WCAG). The Directive names no WCAG version; the link runs through the standard EN 301 549, explained below.

Which products and services are covered

The EAA covers a closed list, and its service rules are tied to consumers: a site that sells only to businesses generally falls outside them, while a site where private customers can buy is in scope. National laws may word this differently.

Who is exempt, and what is left out

Microenterprises that provide services are exempt from the service requirements. The Directive defines them as companies with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. The exemption covers services only; a microenterprise that makes or imports a covered product still has to meet the product rules.

Some website content is excluded even for companies that are covered:

• pre-recorded audio and video published before 28 June 2025;
• office documents published before 28 June 2025;
• navigation maps, if the essential information is also available in an accessible digital form;
• third-party content that you neither paid for, developed nor control;
• archived content that is not updated or edited after 28 June 2025.

A company may also claim a disproportionate burden, but only with a documented assessment under Annex VI that is kept for five years, renewed at least every five years and reported to the authorities. It is a narrow exception, not an opt-out.

Transitional periods

Service providers may keep using products they lawfully used before 28 June 2025 until 28 June 2030, and service contracts agreed before that date may run unchanged until they expire, for no more than five years. Member states may let self-service terminals already in use run to the end of their useful life, up to 20 years; Germany caps this at 15 years. The Directive gives websites and apps no general grace period, and how the rules apply to a particular case depends on national law.

What “accessible” means technically

A product or service that meets a harmonised standard whose reference is published in the Official Journal of the EU is presumed to meet the requirements that standard covers. For websites and apps, that standard is EN 301 549, and the version used as the reference today, V3.2.1 from 2021, is based on WCAG 2.1 level AA.

In September 2026, ETSI published EN 301 549 V4.1.1, which adopts WCAG 2.2. When AccessibleEU reported it, the new version was not yet cited in the Official Journal and brought no new deadline. The practical answer is the same either way: aim for WCAG 2.2 AA. W3C states that content conforming to WCAG 2.2 also conforms to 2.0 and 2.1; only the removed criterion 4.1.1 Parsing may still need testing where a policy requires 2.1. Our WCAG 2.2 AA checklist lists all 55 criteria.

The accessibility information you have to publish

The EAA does not say “accessibility statement”. It asks service providers to explain, in their general terms and conditions or an equivalent document, how the service meets the requirements. Under Annex V, that includes:

• a general description of the service in accessible formats;
• the descriptions and explanations needed to understand how the service works;
• a description of how the service meets the relevant accessibility requirements in Annex I.

The information must be public, in written and oral form, accessible to persons with disabilities and kept for as long as the service is offered. Providers also need procedures that keep the service accessible when it changes, and must fix any non-conformity and inform the authorities. Many companies publish this as an accessibility page; our free checker drafts one from its results for you to complete and have reviewed by your lawyer.

Enforcement and fines

There is no EU-wide fine. Each member state sets penalties that the Directive requires to be “effective, proportionate and dissuasive”, with remedial action, weighing how serious the failure is and how many people it affects. Two examples:

• Germany (BFSG): the market surveillance authority sets a deadline for corrections, warns that it may prohibit the service and can finally order it to stop. Offering a non-compliant service can be fined up to €100,000; other offenses, such as failing to provide required information, up to €10,000.
• Austria (BaFG): the government's business service portal states that fines of up to €80,000 apply.

Other countries set their own amounts; we list only what we could verify at the source.

Does the EAA apply to companies outside the EU?

The Directive defines a service provider as anyone who provides a service on the EU market or offers it to consumers in the EU, wherever the company is registered. A US or Bosnian company selling covered services to EU consumers therefore falls within the definition. How a country would enforce its law against a company with no presence there is a matter of national law, so get legal advice for your markets. For products made outside the EU, duties also fall on the EU-based importer.

Bosnia and Herzegovina is not an EU member state; it has been a candidate country since December 2022. The Directive does not apply as law there, and this guide does not describe Bosnian law. For a company based in Bosnia and Herzegovina, the market decides: selling covered services to EU consumers means following those countries' rules, and EU clients of web and software studios will expect accessible work.

A 10-step plan

• Map your scope: which services you offer to EU consumers, in which countries, and whether you are a microenterprise.
• Pick representative pages: home, search, a product page, sign-up, checkout and contact.
• Run an automated scan, for example with our free accessibility checker.
• Audit all 55 WCAG 2.2 A and AA criteria by hand, with the keyboard and screen readers such as NVDA and VoiceOver.
• Fix templates and components first: one fixed form field corrects every page that uses it.
• Fix content: alternative text, headings, link texts, captions and new documents.
• Re-test every fix, including on a phone and at 400% zoom.
• Publish the Annex V accessibility information and link it from your terms and footer.
• Build it into your process: design reviews, an editor checklist, tests before each release and a way for users to report barriers.
• Monitor: rescan regularly, re-audit after a redesign and keep the information current.

The most common failures

These are the problems that come up most often, on small sites and large ones alike:

• Low contrast: light gray text, text over photos and placeholder text below 4.5:1 (1.4.3); input borders and icons below 3:1 (1.4.11).
• Missing or meaningless alternative text, such as “image1.jpg” (1.1.1).
• Forms that rely on placeholder text, show errors only in red or do not say how to fix them (1.3.1, 3.3.1–3.3.3).
• Menus, sliders, cookie banners and chat widgets that cannot be used or closed without a mouse (2.1.1, 2.1.2).
• Focus outlines removed in CSS, or the focused element hidden behind a sticky header (2.4.7, 2.4.11).
• Tap targets smaller than 24 by 24 CSS pixels without enough space around them (2.5.8).

Why an overlay widget does not make a site accessible

Overlays add a script and a toolbar on top of the page; the code underneath stays as it was. In January 2025, the US Federal Trade Commission announced an order requiring accessiBe, maker of the accessWidget plug-in, to pay $1 million. The FTC alleged that accessiBe claimed its tool could make any website WCAG-compliant when it did not, and that it presented paid reviews as independent. The final order, approved in April 2025, bars such claims without evidence. Accessibility is fixed in templates, components and content, not in a layer on top.

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