The European Accessibility Act (EAA) became enforceable on 28 June 2025. In 2026 the warnings have turned into consequences: a French court ordered Carrefour in June to reach full compliance within six months or pay €500 a day, Spain fined Vueling €90,000, and German businesses are receiving formal warning letters (Abmahnungen) under the national BFSG law.

If you sell online to EU consumers, accessibility is now a legal requirement as well as good UX.

Who's in scope

The EAA covers, among others:

  • E-commerce services: online shops and marketplaces selling to consumers
  • Consumer banking and payment services
  • E-books and reading software
  • Passenger transport booking and ticketing
  • Electronic communications and some audiovisual services

Microenterprises (fewer than 10 employees and €2 million or less in turnover) are exempt for services. B2B-only SaaS is generally out of scope, but enterprise buyers increasingly require WCAG conformance in procurement anyway.

The European Commission's EAA overview has the official scope.

Which standard to build to

Conformance is presumed through the harmonised standard EN 301 549, which references WCAG. WCAG 2.1 AA has been the legal floor; the newest EN 301 549 version adopts WCAG 2.2. Our advice: build to WCAG 2.2 AA and you're covered both ways.

The WCAG 2.2 additions developers miss

Criterion What it means in practice
2.4.11 Focus Not Obscured Sticky headers and cookie banners must not hide the focused element
2.5.7 Dragging Movements Every drag action (sliders, sortable lists, maps) needs a click or tap alternative
2.5.8 Target Size (Minimum) Interactive targets at least 24×24 CSS px, or adequately spaced
3.2.6 Consistent Help Help links and contact options in the same place on every page
3.3.7 Redundant Entry Don't make users re-type information they've already given, such as the shipping address
3.3.8 Accessible Authentication No cognitive tests to log in. Allow paste, password managers and passkeys

The developer checklist

Structure and semantics

  • One <h1> per page and a logical heading order
  • Landmarks: <header>, <nav>, <main>, <footer>
  • Real <button> and <a> elements, not clickable <div>s
  • Form inputs with visible <label>s, and errors linked through aria-describedby

Keyboard and focus

  • Every action reachable with Tab, Enter, Space and Escape
  • A visible focus style with enough contrast. Never outline: none without a replacement
  • Modals trap focus while open and return it to the trigger when closed
  • A "Skip to content" link

Visual

  • Text contrast of at least 4.5:1 (3:1 for large text and UI components)
  • No information conveyed by colour alone, for example in sale prices or form errors
  • Content reflows at 320 px wide and 400% zoom without horizontal scrolling
  • Respect prefers-reduced-motion for animations

Media and images

  • Meaningful alt text on product images; empty alt for decorative ones
  • Captions on video and transcripts for audio

E-commerce hot spots

  • Variant pickers (size, colour) that work with a keyboard and screen readers
  • Cart and checkout errors announced to assistive technology
  • Payment iframes from your provider tested, since you're responsible for the whole flow
  • No time-outs during checkout without warning and extension

How to test

  1. Automated: axe DevTools or Lighthouse catch about a third of issues. Add axe to CI on key templates
  2. Keyboard pass: complete the golden path (browse → cart → checkout) without a mouse
  3. Screen reader pass: VoiceOver on iOS and macOS, NVDA on Windows
  4. Real users: test sessions with disabled users for the core flows, at least once a year

Document it

Publish an accessibility statement with your conformance level, known issues, a contact route and the date of your last review. Regulators and customers ask for it first.

Bottom line

Accessibility done in the code (semantics, focus, contrast and target sizes) is cheaper than fines, better for SEO and better for every customer. Avoid overlay widgets; fix the source.

Our web and e-commerce teams run WCAG 2.2 audits and remediation sprints. Book an audit.

Frequently asked questions

Who must comply with the European Accessibility Act?

Businesses selling covered products or services to consumers in the EU, including e-commerce, banking, e-books, transport ticketing and electronic communications. Microenterprises with fewer than 10 staff and turnover of €2 million or less are exempt for services.

Does the EAA apply to UK or US companies?

Yes, if you sell covered services to consumers in the EU. Location of the company doesn't matter; the market does.

Is WCAG 2.1 or WCAG 2.2 required?

The harmonised standard EN 301 549 has referenced WCAG 2.1 AA as the legal baseline, and its newest version adopts WCAG 2.2. Building to WCAG 2.2 AA now covers both.

Are accessibility overlays enough for compliance?

No. Overlay widgets don't fix underlying code issues and have been criticised by disabled users and regulators. Fix the HTML, focus handling and contrast directly.

AccessibilityWCAG 2.2European Accessibility ActE-commerceCompliance