Accessibility (EAA 2025) for websites

The European Accessibility Act (Directive (EU) 2019/882) is the first EU law that makes accessibility a market requirement for private companies. Its rules have applied since 28 June 2025, through national laws in every Member State. For many businesses the website or app is where the Act bites first.

Who is covered

The Act lists specific products and services rather than covering “all websites”. The services in scope (Article 2(2)) are:

• e-commerce services, meaning services provided at a distance through websites or apps for concluding consumer contracts;
• consumer banking services;
• electronic communications services and services providing access to audiovisual media;
• elements of air, bus, rail and waterborne passenger transport services, such as websites, apps, electronic ticketing and real-time travel information;
• e-books and dedicated reading software.

Public-sector websites were already covered by the Web Accessibility Directive (EU) 2016/2102; the EAA extends similar expectations to the private sector.

The microenterprise exemption

Microenterprises that provide services are exempt from the accessibility requirements (Article 4(5)). A microenterprise is one that employs fewer than 10 persons and has an annual turnover or an annual balance-sheet total not exceeding €2 million (Article 3(23)). The exemption covers services only; microenterprises that place products on the market are not exempted the same way, although they benefit from lighter obligations.

Larger businesses can invoke a disproportionate burden or a fundamental alteration of the service (Article 14), but only after a documented assessment, which they must keep and provide to authorities on request.

What “accessible” means in practice

Annex I of the Act sets functional requirements: information must be perceivable, operable, understandable and robust. Until standards harmonised under the EAA are referenced, the practical benchmark for web content is EN 301 549, whose current version references WCAG 2.1 at level AA. WCAG 2.2, published by the W3C in October 2023, adds criteria on focus visibility, target size and accessible authentication; meeting it is a sensible forward-looking target.

The most frequent failures on commercial websites are well known:

• text and interface contrast below the required ratios (4.5:1 for normal text);
• images and icon buttons without text alternatives;
• form fields without programmatic labels, and error messages that are not announced;
• components that cannot be reached or operated with the keyboard, or that trap focus;
• missing or invisible focus indicators;
• cookie banners that are not keyboard-accessible or that hide page content from screen readers, a point where accessibility and consent law meet.

Accessibility information

Service providers must publish information on how their service meets the accessibility requirements (Article 13(2) and Annex V), in their general terms and conditions or an equivalent document, in written and oral format where appropriate and in an accessible way. Most businesses do this with an accessibility statement linked from the footer that describes the standard applied, known limitations and a contact point.

Transitional periods

Article 32 gives limited breathing room: service contracts agreed before 28 June 2025 may continue unaltered until they expire, but for no longer than five years from that date, and services may continue to use products that were lawfully used before that date until 28 June 2030. New websites, redesigns and new features are expected to meet the requirements now.

What automated testing can and cannot do

Automated checkers reliably find a meaningful share of WCAG failures: contrast, missing alternative text, missing labels, empty links and buttons, missing language attributes and some ARIA misuse. They cannot judge whether alternative text is meaningful, whether the reading order makes sense, whether a custom widget really works with a screen reader, or whether the checkout can be completed with the keyboard alone. Treat an automated score as a floor, then test the core journeys by hand.

Only some of the services we rate include an accessibility check; filter for it on the ratings list or see the comparison matrix.