European Accessibility Act in 2026: Who the EAA Applies To and What to Check on Your Website

From 28 June 2025, EU Member States have applied national rules implementing the European Accessibility Act — Directive (EU) 2019/882 on accessibility requirements for certain products and services.

This is an important development for digital businesses, but the EAA is often described too broadly.

You may encounter claims suggesting that every website available in Europe must now meet one specific accessibility standard or that any accessibility problem automatically creates an enormous fine.

The reality is more nuanced.

The European Accessibility Act covers specific categories of products and services. It does not automatically make every inaccessible website on the internet unlawful.

For businesses that genuinely fall within the scope of the EAA, however, accessibility can no longer be treated purely as an optional UX improvement.

This article provides a general overview for business websites. It is not legal advice. Specific obligations and penalties should be checked against the national legislation of the relevant EU Member State.

What is the European Accessibility Act?

The European Accessibility Act, or EAA, is EU Directive 2019/882, designed to harmonize accessibility requirements for selected products and services across the European Union.

The Directive was adopted in 2019, while Member States apply their national implementing measures from 28 June 2025.

Its purpose is to reduce barriers faced by people with disabilities while creating a more consistent accessibility framework across the European internal market.

For website owners, the important point is that several services within the scope of the EAA are provided through websites and mobile applications.

Does the EAA apply to every website?

No.

This is one of the most important distinctions to understand.

The European Accessibility Act does not create a simple rule stating that every corporate website in the European Union falls within its scope.

The Directive lists specific categories of products and services.

For digital businesses, relevant services include:

• e-commerce services;
• consumer banking services;
• e-books and dedicated software;
• electronic communications services;
• services providing access to audiovisual media services;
• certain digital elements of passenger transport services, including websites, mobile applications and electronic ticketing.

A basic informational B2B website and an online store through which consumers enter into distance contracts therefore represent very different situations.

What does e-commerce mean under the EAA?

For many online businesses, e-commerce is the most relevant category.

Under the EAA framework, e-commerce services involve services provided at a distance through websites or mobile services, at the individual request of a consumer, with a view to concluding a consumer contract.

In practical terms, if consumers can use the website to select a product or service and proceed toward a remote purchase or contract, the applicability of the EAA deserves particular attention.

This may include:

• online stores;
• online booking systems;
• certain services involving remote payment;
• platforms through which consumers enter into contracts with a business.

The presence of a simple “Contact us” button on an informational corporate website does not automatically turn the entire website into an e-commerce service for EAA purposes.

Can the EAA affect businesses outside the EU?

Being established outside the European Union does not automatically mean European accessibility requirements can be ignored.

Where a company provides consumers in the EU with a service that falls within the scope of the EAA, the applicable national rules and the specific business model should be reviewed.

For example, a Ukrainian online retailer actively selling to consumers in EU countries is in a different position from a Ukrainian B2B company whose informational website can simply be viewed from Europe.

The useful question is therefore not:

“Can people in Europe open our website?”

It is:

“Do we provide EU consumers with a service that falls within the relevant national rules implementing the EAA?”

The microenterprise exemption

The Directive contains an important exemption for microenterprises providing services.

Under the EAA, a microenterprise is an enterprise that:

• employs fewer than 10 people;
• and has annual turnover not exceeding €2 million or an annual balance-sheet total not exceeding €2 million.

Microenterprises providing services are exempt from the Directive's service accessibility requirements.

That exemption should still be assessed carefully.

Company structure, linked enterprises and applicable national rules can affect the legal analysis.

Accessibility obligations may also arise from other legislation, contractual requirements or customer expectations even where the EAA exemption itself applies.

Are there other EAA exemptions?

Yes.

The Directive contains several exclusions and transitional provisions.

Depending on the circumstances, excluded website or app content can include:

• pre-recorded time-based media published before 28 June 2025;
• office file formats published before that date;
• certain third-party content that is not funded, developed or controlled by the economic operator;
• websites or sections qualifying as archives because their content is not updated or edited after 28 June 2025;
• certain online maps where essential navigational information is provided in an accessible digital form.

The EAA also provides mechanisms relating to fundamental alteration and disproportionate burden.

These should not be interpreted as permission for a business simply to declare accessibility too expensive.

Whether an exception applies requires a proper assessment under the relevant rules.

Is there a single €100,000 EAA fine?

No.

The European Accessibility Act does not establish one fixed penalty that applies throughout the European Union.

The Directive requires Member States to create their own rules on penalties.

Those penalties must be effective, proportionate and dissuasive, but the actual amounts, procedures and enforcement authorities are determined nationally.

A statement such as “an inaccessible website carries a €100,000 EAA fine” is therefore misleading unless it identifies a particular country and legal provision.

Depending on the jurisdiction, enforcement may involve:

• administrative fines;
• orders to remedy non-compliance;
• court procedures;
• other national enforcement mechanisms.

Legal exposure should therefore be reviewed country by country.

What does an accessible website look like in practice?

Accessibility cannot be reduced to a single automated score.

The objective is to allow people with different abilities and interaction methods to use a digital service effectively.

A practical website accessibility review commonly considers areas such as the following.

1. Keyboard accessibility

Users should be able to operate important interactive functionality without relying on a mouse.

This includes:

• navigation;
• links;
• buttons;
• forms;
• modal dialogs;
• other interactive components.

It should also be possible to identify which element currently has keyboard focus.

2. Meaningful HTML structure

Headings, lists, buttons, form controls and other interface elements should have appropriate semantics.

A generic div styled to look like a button may not behave like a real button for assistive technology.

3. Text alternatives for meaningful images

Where an image communicates important information, people who cannot see that image need an alternative way to receive its meaning.

Decorative images do not require long keyword-filled descriptions.

Alternative text is primarily an accessibility feature, not an SEO field to fill with keywords.

4. Contrast and readability

Light grey text on a white background may look elegant in a design mock-up while remaining difficult for many people to read.

Reviews should consider:

• contrast;
• text size;
• zooming;
• reflow at increased sizes;
• whether content or functionality is lost.

5. Accessible forms

Form controls need understandable labels, and errors should explain what needs to be corrected.

Colour alone should not be the only indicator of an error.

A user should be able to understand:

• what information is required;
• whether a field is mandatory;
• what went wrong;
• how to correct it.

6. Accessible multimedia

Where video or audio contains important information, captions, transcripts or other alternatives may be necessary depending on the context.

7. Accessible interactive components

Custom dropdowns, tabs, carousels, modal dialogs and similar components need to be operable and understandable, not merely visually attractive.

Is WCAG 2.2 compliance enough?

WCAG is one of the most useful technical references for designing and auditing accessible websites.

However, the legal question of EAA compliance is broader than the result of a WCAG scanner.

The assessment can depend on:

• the type of service;
• national implementing legislation;
• applicable technical standards;
• accessibility of the full user journey;
• information that the service provider is required to provide.

For this reason, “our website passes WCAG checks, therefore EAA legal compliance is guaranteed” is also too simplistic.

WCAG can provide a strong technical framework while legal compliance still requires a broader review.

An automated accessibility score is not a compliance certificate

Tools such as Lighthouse and axe are extremely useful for initial diagnostics.

They can identify some issues involving:

• contrast;
• missing form labels;
• certain ARIA errors;
• missing text alternatives;
• some structural problems.

Automated tools cannot fully evaluate an actual user journey.

They may fail to determine, for example, that:

• focus order is confusing;
• a modal cannot practically be closed using a keyboard;
• alternative text exists but is meaningless;
• a form error gives the user no useful guidance;
• checkout technically passes an automated scan but is extremely difficult to use with a screen reader.

A strong accessibility audit therefore combines automated and manual testing.

E-commerce should test the entire purchase journey

An online store cannot focus only on making its homepage accessible.

The complete critical journey may include:

1. search or product catalog;
2. filters;
3. product pages;
4. product variations;
5. add-to-cart actions;
6. shopping cart;
7. authentication or checkout;
8. address entry;
9. payment;
10. error handling;
11. order confirmation.

One inaccessible critical step can make the overall purchasing service unusable for some customers.

Does an existing website need to be rebuilt completely?

Not necessarily.

An accessibility audit may show that most issues are local.

For example, a team may only need to:

• correct heading structure;
• add form labels;
• improve focus states;
• rebuild several custom components;
• improve contrast;
• fix keyboard navigation;
• provide appropriate multimedia alternatives.

On another project, accessibility problems may be systematic: the entire component library lacks semantic structure, checkout cannot be completed with a keyboard and the same problems are repeated across dozens of templates.

In that case, rebuilding part of the component system may be more efficient than continuously applying individual patches.

How should a business begin preparing for the EAA?

1. Determine whether the service falls within the scope of the EAA.
2. Identify the EU countries in which the service is provided to consumers.
3. Check possible exemptions, including microenterprise status.
4. Review the applicable national implementing legislation.
5. Audit accessibility across key user journeys.
6. Prioritize issues by impact and severity.
7. Fix shared systemic components first.
8. Retest manually and automatically.
9. Document relevant decisions where required.

A practical website accessibility checklist

• Can primary navigation be used without a mouse?
• Is keyboard focus visible?
• Do form controls have meaningful labels?
• Are form errors understandable?
• Is text and interface contrast sufficient?
• Can text be enlarged without losing functionality?
• Do meaningful images have appropriate alternatives?
• Do custom components work with a keyboard?
• Can users complete mobile checkout accessibly?
• Does important multimedia provide appropriate alternatives?
• Is important information communicated by more than colour alone?
• Can the primary business action be completed without a mouse?

Accessibility still matters when the EAA does not apply

Legal compliance is not the only reason to improve accessibility.

Many accessibility practices make websites easier to use for a much broader audience.

For example:

• clear form labels help everyone complete forms;
• good contrast helps people reading a phone outdoors;
• captions are useful when video is watched without sound;
• predictable navigation improves the experience for all users;
• larger interaction targets work better on smartphones;
• semantic HTML creates more robust interfaces.

Accessibility therefore makes sense as part of professional UX and development even where a particular EAA obligation does not apply.

The TimeKairos approach

At TimeKairos, we do not believe accessibility should be sold through fear: “your website is breaking the law, therefore you urgently need a new one”.

The first step is determining whether the relevant legislation actually applies to the particular business and service.

The next step is understanding the current state of the website.

Automated accessibility checks can form part of a technical audit, but they should be combined with manual review of important components and user journeys.

If existing architecture can be corrected, there is no reason to recommend a complete redesign purely for its own sake.

If the problems are systemic, then a deeper component or technical rebuild can be evaluated based on evidence.

Conclusion

The European Accessibility Act is an important development for digital businesses operating in Europe, but it is not a universal “law for every website”.

From 28 June 2025, accessibility requirements apply to defined categories of products and services through national legislation in EU Member States.

E-commerce is one of the most relevant categories for online businesses. The Directive also includes an exemption for microenterprises providing services, alongside other exclusions and transitional provisions.

There is also no single EU-wide “€100,000 fine for an inaccessible website”. Penalties are determined by Member States.

The best first step is not to panic or rebuild a website blindly. Determine the legal scope first, then identify the accessibility barriers that actually need to be fixed.