The European Accessibility Act (EAA) is an EU directive, Directive (EU) 2019/882, that requires many consumer-facing websites, web shops and mobile apps to be usable by people with disabilities. It has applied since 28 June 2025, including to non-EU businesses that sell to EU consumers. Service providers with fewer than 10 staff and low turnover can be exempt.
| Question | Short answer |
|---|---|
| Legal basis | Directive (EU) 2019/882, adopted in 2019 |
| Applies since | 28 June 2025 |
| Who is in scope | Providers of covered consumer products and services in the EU market, including non-EU sellers |
| Digital services covered | E-commerce, consumer banking, e-books, passenger transport ticketing, electronic communications, audiovisual media services |
| Microenterprise test | Fewer than 10 employees and turnover or balance sheet of no more than €2 million |
| Technical benchmark | EN 301 549, which draws on WCAG; aim for WCAG 2.2 Level AA |
| Enforcement | By each member state's national authorities, with national penalties |
| First practical step | Test the purchase journey with a keyboard and a screen reader |
This guide is factual and general. It is not legal advice, and you should confirm how your own national rules apply with a qualified adviser. We build websites and apps for startups and SMBs across Europe, so we focus on what the rules mean for the product you ship.
The European Accessibility Act is an EU directive that sets common accessibility requirements for selected consumer products and services. Its aim is to remove the national differences that made it hard to sell accessible products across borders. For online businesses, it turns accessibility from good practice into a market-access requirement.
The European Commission's EAA page describes it as a directive meant to improve how the internal market works for accessible products and services. The Wikipedia entry on the Act notes it dates from 2019. Member states had until 28 June 2022 to write it into national law, and obligations bound businesses from 28 June 2025.
Because it is a directive, the text is turned into national law in each country. Wording and enforcement details can differ between Sweden, Ireland, the Netherlands and Germany, even though the core requirements are shared. That is why this article stays at the level of what the directive demands and what a build team can act on.
The test is who your customers are, not where you incorporate. If you sell covered services to consumers in the EU through a website or app, you are generally treated as operating in the EU market. A London SaaS shop with a Dutch checkout page is a clear example.
The UK has its own, separate equality rules. This guide does not cover them. If you serve both markets, treat the EAA as an extra layer to check, and expect most of the technical work to overlap.
It applies to manufacturers, importers, distributors and service providers that put covered consumer products or services on the EU market. For online businesses, that mostly means anyone selling to EU consumers through a website or app. The main carve-out is the microenterprise exemption for service providers.
Business-to-business only products fall outside the consumer focus of the Act. In practice the line is blurry. If a self-serve checkout, booking form or subscription page can be used by an individual consumer, assume it is in scope and plan for it.
A microenterprise is a business with fewer than 10 employees and annual turnover or an annual balance sheet total that does not exceed €2 million. Microenterprises that provide covered services can be exempt from the accessibility requirements for those services. The exemption is aimed at services, not at companies making covered physical products.
Take two hypothetical Swedish webshops, each with €1.4 million in annual turnover. Shop A has 8 employees and qualifies as a microenterprise. Shop B has 12 employees, so it does not, even with identical revenue. Shop B must meet the requirements; Shop A can use the exemption, though it may choose not to.
Three cautions apply. Group structures and linked companies can change the headcount you count. Larger retail partners may ask for accessibility evidence in contracts regardless of the exemption. And a growing startup can lose the exemption in a single hiring round. If you expect to pass 10 staff within a year, building accessibly now is cheaper than retrofitting.
The directive also recognises that some changes could be a disproportionate burden or would fundamentally change a product or service. These are not blanket excuses. Businesses that rely on them are expected to assess and document the reasoning, so treat them as a narrow fallback and get advice before leaning on them.
The Act covers selected consumer products, such as smartphones, computers, e-readers and self-service terminals, plus services including e-commerce, consumer banking, e-books, passenger transport ticketing, electronic communications and audiovisual media services. Websites and apps that deliver those services are in scope.
For most readers of this guide, the practical list is short. The Commission's overview is the place to check the full scope. Here is how it maps to digital products we see founders build:
Pure brochure sites that sell nothing and offer no covered service sit in a grey area. Even so, a company site that links to a shop or booking page is judged by the whole journey, not the homepage alone. Our guide to web applications versus websites helps you decide which of your properties behave like services.
The directive states outcomes: content must be perceivable, operable, understandable and robust. The harmonised standard EN 301 549 turns those outcomes into testable criteria, and its web section draws on WCAG. In practice, meeting WCAG 2.2 Level AA is the safest working target for websites and apps.
The EN 301 549 version most teams use, 3.2.1 from March 2021, is built on WCAG 2.1 Level AA. WCAG 2.2 adds criteria on top of 2.1 and is designed to be backward compatible, so a build that meets 2.2 AA also covers the 2.1 AA baseline. A newer EN 301 549 version is in circulation, so check which one your market refers to.
Beyond the interface, the Act expects providers to describe how their service meets accessibility requirements and to keep that description available. Many teams publish an accessibility statement that lists the standard used, known gaps and a contact route for feedback. Treat it as living documentation, updated after each release that changes the user journey.
Enforcement happens at national level. Each member state appoints authorities to check compliance, handle complaints and set penalties, so consequences differ by country. There is no single EU fine. Typical actions include corrective orders, restrictions on selling, and national penalties, which should be confirmed locally.
Three things drive risk in practice: a complaint from a user or advocacy group, a market surveillance check, and a buyer asking for evidence during procurement. You cannot predict which of these will reach you first. The common thread is documentation: test results, a dated remediation plan and a published statement carry more weight than a promise to fix things later.
One point remains unsettled. National transposition and the way authorities prioritise checks are still developing, and we cannot say how strictly any single country will act against small foreign sellers. Plan for the standard, not for the odds of being checked.
Some vendors sell a script that promises instant compliance. In our view, a widget is not a substitute for accessible code. It can mask problems in a quick scan while leaving real barriers in forms, focus order and screen reader output. If you use one at all, treat it as an add-on to fixed code, never the fix.
A workable EAA checklist covers six areas: structure and semantics, keyboard use, colour and text, forms and errors, media alternatives, and mobile-specific behaviour. Test the full purchase journey first, record every failure, fix by severity, then publish an accessibility statement and retest after each release.
Native and cross-platform apps are held to the same outcomes. We build cross-platform apps with React Native, one codebase for two platforms, which means accessibility properties are written once and tested on both iOS and Android.
If you are scoping an app, our guide to choosing a mobile app development agency lists the questions to put to any supplier, including how they test with assistive technology. You can also see how we approach app development and our work on web development with React, Next.js, Node.js and Supabase.
Begin by confirming scope, then test the journey that earns revenue. Check whether you sell a covered service to EU consumers and whether you pass the microenterprise test. If you are in scope, audit checkout and sign-up, fix blockers first, and publish a statement. Defer cosmetic fixes to later sprints.
Here is the order we would follow, and the one we recommend if you have a small team and a fixed budget:
Our firm view: if you are in scope, do not wait for a complaint. Retrofitting accessibility into a finished product costs more than designing it in, and a redesign is the moment to fix the foundations.
Our breakdown of website redesign cost by feature and scope helps you budget for that work. If you are exempt as a microenterprise and have no EU enterprise customers, a lighter pass is reasonable, but the checklist above is still cheap insurance.
We work in four steps: Discovery and Planning, Design and Prototyping, Development and Testing, then Launch and Support. Accessibility belongs in each.
Accessibility also overlaps with your data duties, since many forms collect personal data. Our GDPR-compliant web app development FAQ covers that side of European compliance.
Yes, if the company sells covered products or services to consumers in the EU. The Act looks at where your customers are, not where you are registered. A UK business with no EU consumer customers is not caught by the EAA, though separate UK rules may apply.
No. An overlay adds a layer on top of your page but does not repair the underlying code. Barriers in forms, keyboard order and screen reader output usually remain. Fixing the source code and testing with real assistive technology is the dependable route, with any widget as an optional extra.
The Act does not name a mandatory audit for every business, but you need evidence your service meets the requirements. An independent audit against WCAG 2.2 AA is the clearest evidence, and it is worth commissioning before a major launch or when a large customer asks.
The European Accessibility Act rewards teams that treat accessibility as a build requirement rather than a late patch. If you want a clear view of where your site or app stands, contact our team. We reply within 2 hours during business hours, and you can email hello@axire.in. Our team in India overlaps with CET afternoons, so working with European clients is straightforward.
To see how we build, browse our projects, which include Media Mates, MustQR, Sign Out, Solace Sofas, Nextn and Pehchaan, or look through all our services. More practical guides are in our article library.
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