European Accessibility Act: does it apply to my business?

What is the European Accessibility Act?

The European Accessibility Act (EAA) is Directive (EU) 2019/882 ↗ of 17 April 2019. It sets accessibility requirements for a list of products and services, and every Member State has applied it since 28 June 2025 (Article 31).

Until then, digital accessibility rules in most EU countries mainly covered the public sector. The EAA extends them to a large part of the private sector, as soon as it serves consumers.

Each country transposes the directive into its own law. In France, for example, it sits in the Consumer Code, detailed by Decree no. 2023-931 and an order of 9 October 2023, and the DGCCRF (the consumer protection authority) carries out the checks.

Which services are covered?

Article 2 of the directive lists the consumer services that must be accessible:

E-commerce is the category that affects the most businesses. The directive defines it as a service provided at a distance, through a website or an app, at the request of a consumer, with a view to concluding a contract. So it isn't limited to the checkout page: search, product pages, account creation, the basket and order tracking are all part of the journey.

Is my business exempt?

There is only one general exemption for services: micro-enterprises (Article 4(5)). Article 3 defines them as businesses with:

• fewer than 10 employees,
• and an annual turnover or a balance sheet total of no more than €2 million.

Both are needed: the headcount, and one of the two financial ceilings. A 4-person shop with €600,000 in turnover is exempt. A 12-person online travel agency isn't, whatever its turnover.

Everyone else has two possible exceptions, and both have to be justified: a fundamental alteration of the service, and a disproportionate burden (Article 14). In both cases, the business must carry out and document an assessment, renew it at least every five years for a service, and inform the authorities if it relies on it. It's not an automatic exemption.

My business is outside the EU. Am I covered?

Yes, if you sell to consumers in the Union. The text looks at the service provided, not at where the company is registered. A shop based in Mauritius or Dubai that delivers to France, or a booking platform selling to Belgian customers, falls within its scope.

Outside the EU, many accessibility laws and policies also point to WCAG. An audit against that standard is therefore common ground, whatever market you serve.

What should I do in practice?

In the order I'd do it:

1. Check your status: headcount, turnover, balance sheet, and the services you offer to consumers.
2. Map the journey: from the home page to the order confirmation, including the customer account and online after-sales support.
3. Have that journey audited against a recognised standard. At EU level, the technical reference is the EN 301 549 ↗ standard, which incorporates WCAG at level AA. Some countries have their own framework, such as the RGAA in France.
4. Inform your customers: Article 13 and Annex V require you to explain, in your terms and conditions or an equivalent document, how the service meets the accessibility requirements. Many businesses do this with an accessibility statement.
5. Fix, then keep it up: the directive requires procedures so that the service stays compliant as it evolves. Every new feature is a chance to regress.

On the Sea Kayak Adventures website, accessibility was built in during the redesign rather than fixed afterwards: 96/100 for accessibility on Google PageSpeed. That's almost always cheaper than reworking an existing website.

Do existing websites have until 2030?

It's the claim you read most often, and the text doesn't quite say that. Article 32 provides a transition period until 28 June 2030, but for services provided using products already in use before 28 June 2025, such as kiosks or terminals. Service contracts signed before that date may also continue unchanged until they expire, for five years at most.

Does that cover an existing website? Readings differ, and it's up to each national authority to decide. Personally, I wouldn't advise anyone to count on it to wait: evolving journeys, a redesign, a new payment module or a new app clearly fall under the new rules.

What are the risks of non-compliance?

Each Member State sets its own penalties and its own enforcement authority. In France, for example, the DGCCRF carries out checks and can impose the penalties set out in the Consumer Code. The amounts quoted online vary a lot from one article to another: rely on your national authority's official guidance rather than a figure copied from blog to blog.

The most immediate risk is commercial. A form you can't fill in with a keyboard, or a button a screen reader doesn't announce, is an order that doesn't happen.