The European Accessibility Act explained
Updated October 12, 2026 · 4 min read
The European Accessibility Act (EAA, Directive (EU) 2019/882) requires certain products and consumer services — including e-commerce — to be accessible to people with disabilities. Its service requirements apply since 28 June 2025, through national laws in each EU country. It does not cover every website: it targets specific B2C services and exempts micro-enterprises that provide services.
What the EAA is
The EAA is an EU directive. Each member state has written it into national law — for example the BFSG in Germany, the act of 26 April 2024 in Poland, zákon 424/2023 Sb. in Czechia and Legea 232/2022 in Romania. The core requirements are the same across the EU; supervision, fines and some details differ per country.
Key dates
| Date | What happens |
|---|---|
| 28 June 2025 | Requirements apply to covered products placed on the market and services provided to consumers |
| until 28 June 2030 | Service contracts concluded before 28 June 2025 may continue unchanged until they expire, at the latest until this date |
Which services are covered
The EAA lists specific service sectors (Article 2(2)):
- E-commerce services — selling goods or services to consumers online;
- consumer banking services;
- e-books and dedicated reading software;
- elements of passenger transport services (air, bus, rail, waterborne) such as websites, apps, e-tickets and travel information;
- electronic communications services;
- services providing access to audiovisual media services.
A company website that only presents a business, or a B2B-only shop, is generally not covered by the service requirements.
Who is exempt
Micro-enterprises that provide services are exempt (Article 4(5)). Under Article 3(23), a micro-enterprise has fewer than 10 employees and an annual turnover not exceeding €2 million or an annual balance sheet total not exceeding €2 million.
In practice: a business with 10 or more employees is covered (if it passes the other two questions). A business with fewer than 10 employees is exempt unless both turnover and balance sheet exceed €2 million. Walk through examples in who the EAA applies to.
What the requirements mean for a website
The EAA describes functional requirements; the technical yardstick is the harmonised standard EN 301 549, whose web chapter follows WCAG:
- EN 301 549 V3.2.1 (WCAG 2.1 AA) is the harmonised version cited in the Official Journal for now.
- EN 301 549 V4.1.1 (WCAG 2.2 AA) was published in September 2026 and is expected to be cited in late 2026. See what changes with V4.1.1.
Practically, this means: text alternatives for images, sufficient contrast, labelled forms, full keyboard operation, visible focus, clear error messages, a usable checkout and so on. Our WCAG 2.2 checklist lists them for shops.
The information on accessibility
Article 13 and Annex V require service providers to publish information on how the service meets the accessibility requirements, in the general terms and conditions or an equivalent document, in an accessible format. In Germany this is §14 and Annex 3 of the BFSG, often published as a "Barrierefreiheitserklärung". See the accessibility statement guide.
Enforcement
National market surveillance authorities check services, handle complaints and can order corrections; national laws provide for fines. Examples:
- Germany: fines up to €100,000 under BFSG §37; supervision by the MLBF in Magdeburg. See BFSG guide.
- Poland: fines up to 10 times the average monthly salary, capped at 10% of turnover. See Poland.
- Czechia: fines up to CZK 10 million; the ČOI inspected 47 online shops in Q2 2026 and found breaches in 10. See Czechia.
- Romania: fines of 5,000 to 15,000 lei. See Romania.
As of October 2026 we are not aware of confirmed EAA fines against online shops. What is happening is inspections, complaints and court cases — and in Germany, warning letters (Abmahnungen) from competitors are a further risk.
Five practical steps
- Check whether the EAA applies to your service with the three-question filter.
- Scan your key pages — home, category, product, cart, checkout, account. Our free check covers one page; it is an automated check, not a full audit, and not legal advice.
- Fix the highest-impact issues first: checkout forms, buttons, contrast, keyboard access.
- Test manually what automation cannot judge, or have an expert do it.
- Publish the information on accessibility and keep monitoring after every update.
FAQ
When did the EAA start to apply? On 28 June 2025 for services; older service contracts may continue until they end, but no longer than 28 June 2030.
Who is exempt? Micro-enterprises providing services — fewer than 10 employees and turnover or balance sheet of no more than €2 million.
Which standard is used for websites? EN 301 549, currently V3.2.1 (WCAG 2.1); V4.1.1 (WCAG 2.2) is expected to be cited in late 2026.
Does a non-EU company have to follow it? If it provides a covered service to consumers in the EU, yes, it can apply regardless of where the company is registered — the micro-enterprise exemption still applies. A step-by-step guide for shops: EAA for online shops.
Sources
- Directive (EU) 2019/882, EUR-Lex: https://eur-lex.europa.eu/eli/dir/2019/882/oj
- BFSG, gesetze-im-internet.de: https://www.gesetze-im-internet.de/bfsg/
- Polish act, Dz.U. 2024 poz. 731 (Sejm): https://api.sejm.gov.pl/eli/acts/DU/2024/731/text.html
- ČOI, online sales inspections Q2 2026: https://coi.gov.cz/wp-content/uploads/2026/08/2026-08-12-internetovy-prodej_2Q.docx
- W3C, WCAG 2.2: https://www.w3.org/TR/WCAG22/
This guide is general information, not legal advice.