The European Accessibility Act for business websites: what applies to you

What the Accessibility Act means for a business website in practice, which services are covered, and the build decisions that satisfy it.

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The short answer

The European Accessibility Act extends accessibility requirements from the public sector to a defined list of products and services offered to consumers. For website owners the relevant service categories include e-commerce, consumer banking services, electronic communications, elements of passenger transport services, e-books and access to audiovisual media services. Obligations applied from 28 June 2025 for services placed on the market from that date, with transitional arrangements for certain existing service contracts and self-service terminals. Microenterprises providing services, meaning fewer than ten people and annual turnover or balance sheet total not exceeding two million euros, are exempted from the service obligations, though that exemption does not extend to products. Because the Act is implemented in national law, the definitive scope question is answered nationally. In practice, compliance for a website means conforming to the harmonised European standard, which aligns with the Web Content Accessibility Guidelines at level AA, and being able to show how. That is a build practice rather than a product, and it costs very little when designed in.

What compliance requires of the build

AreaWhat it meansHow it is checked
StructureReal headings in order, landmarks, lists, tables with headersAutomated checks plus a screen reader pass
KeyboardEverything operable without a mouse, visible focus, no traps, logical orderTen minutes of manual testing per key journey
ContrastText and interface components meet the ratiosAutomated contrast check on the palette
Text alternativesImages described or marked decorative; icons labelledReview with the page’s purpose in mind
FormsLabels bound to fields, instructions before input, errors identified in text with guidanceManual completion including error states
Colour and sensoryMeaning never conveyed by colour, shape or position aloneReview of states and charts
MotionReduced motion respected; nothing flashingTest with the setting on
Zoom and reflowUsable at high zoom and small viewports without horizontal scrollingResize testing
MediaCaptions for video, transcripts where relevantContent review
Time limitsAdjustable or absentCheck sessions and carousels
Status messagesAnnounced to assistive technologyScreen reader test of dynamic areas

What to do now

  1. Determine scope against your national implementation, considering what you offer to consumers and your size.
  2. Audit against level AA: automated checks across all templates, then manual keyboard, screen reader, contrast and forms testing on key journeys.
  3. Prioritise the failures that block tasks: keyboard operability, forms, focus, contrast.
  4. Fix in the components, so every page inherits the fix.
  5. Add checks to the pipeline so regressions cannot ship.
  6. Document conformance and publish a statement if you are in scope, or voluntarily.
  7. Include accessibility in the definition of done for new work.
  8. Retest annually and after significant changes.

Our position

We build to level AA on every site regardless of whether the client is in scope, because the cost of doing so is close to zero at build time, because procurement and enterprise clients ask for it, and because a meaningful share of every audience benefits. Where a client is in scope we document conformance and help write the statement. Where they are not, they have the same site and no exposure, which is the cheaper of the two ways to be outside the scope of a problem.

What this means for you

The Accessibility Act covers listed consumer services including e-commerce, from 28 June 2025, with a microenterprise exemption for services and scope determined nationally. Compliance means conforming to level AA and documenting it. Audit, fix in the components, put checks in the pipeline, and publish a statement where required. Build to AA regardless, because it is nearly free during a build and expensive afterwards. This is general information rather than legal advice.

Written by the CivSec S.M.A.R.T team

We build and run websites, software and AI systems for businesses. We write about what we see in that work, in plain language, and we update articles when things change.

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Frequently asked questions

Is our website covered?

It depends on what you offer to consumers. E-commerce services are listed, as are consumer banking, electronic communications, elements of passenger transport, e-books and access to audiovisual media services. A business-to-business site or a brochure site is generally outside the scope, and microenterprises providing services are exempted. Because the Act is implemented in national law, the definitive answer for your situation comes from your national implementation, and a borderline case deserves advice.

What does a compliant website look like?

The same as a well-built one: semantic structure with real headings and landmarks, everything operable by keyboard with visible focus, sufficient colour contrast, text alternatives for images, forms with proper labels and clear error messages, no reliance on colour alone, no keyboard traps, content that works when zoomed or with a screen reader, and captions for video. That is the level AA programme, and it is a build practice rather than a plugin.

Can an accessibility overlay make us compliant?

No. Overlays that inject a widget to adjust contrast and font size do not fix underlying markup, and accessibility organisations and users have been consistently critical of them. Some create new barriers for screen reader users. Conformance comes from the site's own structure and behaviour. Spend the budget on fixing the site, not on a widget that claims to fix it externally.

Sources

  1. European Commission: European accessibility act (accessed 2026-09-14)
  2. EUR-Lex: Directive (EU) 2019/882 (European Accessibility Act) (accessed 2026-09-12)
  3. W3C: Web Content Accessibility Guidelines (WCAG) 2.2 (accessed 2026-09-12)