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What a Ukrainian web studio needs to know about the EAA

· 7 min read

The European Accessibility Act (EAA, Directive 2019/882) has applied to services since 28 June 2025 and covers B2C services in specific sectors: online shops, banking services, passenger transport, e-books and electronic communications. It matters to a Ukrainian studio not because it applies to the studio itself, but because EU clients are already asking: "Does our site meet the EAA?" Below is what you need to know to answer honestly, quickly and without unnecessary fear.

The EAA for Ukrainian studios in brief

  • Who must meet the requirements: the company that provides the service to consumers in the EU. That is your client, not the studio. But they will most likely come to you to fix the site.
  • What the law requires: that the website and app are accessible to people with disabilities. In practice this is measured against the European standard EN 301 549, which builds on WCAG.
  • Who it does not apply to: micro-enterprises (fewer than 10 employees and annual turnover up to €2 million or a balance sheet up to €2 million), B2B sites and sites outside the EAA sectors.
  • What must be published separately: the "information on accessibility" of the service (Article 13 and Annex V of the directive). In Germany this is §14 and Annex 3 of the BFSG.
  • How it is enforced: through market surveillance inspections, consumer complaints and court cases. Each EU country has its own national law and its own supervisory authority.

More on the law in our EAA guide.

Filter first: does the client's site fall under the EAA

The most common mistake is telling every client that the EAA applies to them. Before any conversation about the law, answer three questions:

  1. B2C? The site sells goods or services to private individuals, not only to other companies.
  2. An EAA sector? E-commerce, banking services, passenger transport, e-books, electronic communications, access to audiovisual media.
  3. Not a micro-enterprise? A company is not a micro-enterprise if it has 10 or more employees or at the same time a turnover above €2 million and a balance sheet above €2 million.

The last point is often confused. A high turnover alone is not enough: a drop-shipping store with four employees, €3 million turnover and a €0.4 million balance sheet is exempt. If even one answer is "no" or you are not sure, do not talk to the client about the EAA. Talk about the quality of the site: usability, conversion, SEO and older people among their customers. Examples and a step-by-step filter are in the article who the EAA applies to.

What exactly is checked on the site

For the web, EN 301 549 refers to the WCAG level AA criteria. For an online shop, it most often comes down to these things:

  • contrast of text and buttons;
  • text alternatives (alt) for product images;
  • labels for form fields, especially in the cart and checkout;
  • buttons and links with a clear name, not just an icon;
  • keyboard operation and visible focus;
  • a logical heading structure and the correct page language;
  • the size of tap targets on mobile.

The harmonised version of the standard is still EN 301 549 V3.2.1 (based on WCAG 2.1). Version V4.1.1, based on WCAG 2.2, was published in September 2026, and its citation in the EU's Official Journal is expected in late 2026. That is why we check against WCAG 2.2 AA: it covers both the old and the new criteria. What changed in 2.2 is in the article WCAG 2.2 for online shops.

What automation finds and what it doesn't

Automated tools based on axe-core (including the free Lighthouse, Unlighthouse and Pa11y) find only part of the issues: a missing alt, low contrast, an unlabelled field, an empty button. They will not tell you whether the alt actually describes the product, whether the checkout is easy to complete with a keyboard, or whether an error message makes sense to a screen reader.

So any automated report is an automated check, not a full audit, and not legal advice. Say this plainly to the client. Honesty works in the studio's favour here: a client who was promised "full conformance in one click" will stop trusting you later.

What the studio should give the client

When a client asks "what about the EAA?", they don't need a list of errors for a developer, but a document a business owner can understand:

  • Summary: how many critical issues there are, which three matter most and what they mean for customers.
  • Priorities: what to fix first so that a customer can get to payment.
  • Mapping to the standards: which clause of EN 301 549 and WCAG each issue belongs to.
  • Before / after trend: every week you see what has been fixed and what appeared after an update.
  • The client's language: German, Polish, Czech or Romanian, not English for developers.
  • A draft of the accessibility information: text based on the client's questionnaire, which they agree with their lawyer. How it is structured is in the accessibility information guide.

This is exactly what our service does automatically and under the studio's brand: the report is assembled from a library of explanations for each rule, translated into EU languages. See how it works on the how it works page.

Individual countries: what applies where

Each country transposes the directive into its own law, and the details differ:

  • Germany: BFSG, supervised by the MLBF, fines up to €100,000 under the law, plus separate Abmahnungen from competitors. See BFSG for online shops.
  • Poland: Act Dz.U. 2024 poz. 731, supervised by the Minister of Digital Affairs. See the EAA in Poland.
  • Czechia: Act 424/2023 Coll., supervised by ČOI, which is already inspecting online shops. See the EAA in Czechia.
  • Romania: Legea 232/2022, supervised by ADR. See the EAA in Romania.

Be careful when talking about sanctions: the laws provide for fines, but as of October 2026 we have not seen confirmed fines against online shops specifically under the EAA. There are inspections, complaints and court cases. That is enough for the topic to be real, and there is no need to exaggerate anything.

How a studio can earn from the EAA without becoming an auditor

For most studios of 5–25 people without a dedicated accessibility specialist, a realistic path looks like this:

  1. Check the sites of current EU clients and run the EAA filter for each one.
  2. Give clients who fall under the law a clear report and a fixing plan.
  3. Sell the fixes as regular studio work.
  4. Keep weekly monitoring so new releases don't bring back old errors.
  5. Hand a full manual audit to a certified specialist when needed.

Why not an "overlay" widget that promises to fix everything with one line of code is explained in the article why overlays don't work.

Answers to common questions

Does the EAA apply to every EU client's website? No. Only to B2C services in EAA sectors and only to companies that are not micro-enterprises.

Does the EAA apply to the studio itself? The requirements apply to the company that provides the service to consumers. But the question will come to the studio.

Is an automated check enough? No, it finds part of the issues. It is a starting point and monitoring, not an audit.

What should we give the client? A report for the business owner in their language, priorities, the trend and a draft of the accessibility information for their lawyer.

Want to see what this looks like for your clients? Look at the offer for studios and the partner programme terms.

Sources

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