European Accessibility Act: who does it apply to and where should you start?

The European Accessibility Act, commonly abbreviated to EAA, establishes common accessibility requirements for certain products and services in the European Union. The directive was adopted in 2019 and its main requirements began applying on 28 June 2025.

For a business, the important question is whether a particular service falls within scope and which digital parts are necessary to deliver that service.

Which services does the EAA cover?

The European Commission identifies areas including e-commerce, consumer banking, e-books, electronic communications, access to audiovisual media services and certain passenger transport elements.

A website or application matters when it forms part of delivering the service. For example, an online store user must be able to find a product, select a variation, add it to the basket, understand the price and complete checkout.

Does it apply to every website?

No. Having a website does not automatically place every business activity within the EAA. The nature of the service, its users, company size, national implementation and possible exceptions all matter.

The directive provides an exception for microenterprises providing services. A microenterprise generally has fewer than 10 employees and annual turnover or balance-sheet total not exceeding €2 million. The situation must still be assessed under the applicable national law and actual company data.

Disproportionate burden and fundamental alteration may also be relevant, but require a reasoned assessment and documentation rather than serving as a general reason to do nothing.

What should an e-commerce website test?

• Search, categories and filters.
• Product information, prices and variation selection.
• Basket management and quantity changes.
• Login, registration and guest checkout.
• Delivery and payment selection.
• Form errors, confirmations and order summary.
• Help, returns and contact information.

Each stage should cover keyboard operation, visible focus, clear names, error feedback, text resizing, responsive presentation and selected assistive technology scenarios.

What is the role of WCAG?

WCAG 2.2 is an international web content accessibility standard organised around content being perceivable, operable, understandable and robust. It is commonly used as a technical reference for websites and applications.

Legal compliance is not simply an automated WCAG checklist. The service, information, processes and applicable legal requirements must be considered together.

Where should a business start?

1. Define the service and its boundaries.
2. Confirm legal scope. Consider company size, service category, market and possible exceptions.
3. List critical user journeys. Purchasing, login, booking and account management are complete processes.
4. Run a technical audit. Combine automated and manual testing with clear evidence and priorities.
5. Create a remediation plan. Address task-blocking and shared-component failures first.
6. Retest. Verify both the original issue and the complete affected journey.
7. Integrate accessibility into delivery. New content and releases should not restore known failures.

What evidence is useful?

• Defined test scope and environment.
• Prioritised findings with screenshots and reproduction steps.
• Decisions and remaining limitations.
• Retest results.
• An internal process for new content and features.

Conclusion

The EAA is not a one-time website certificate. Businesses need to understand the scope of their service, remove important user barriers and maintain a process that prevents new releases from reducing accessibility.