The Tool Desk
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The EAA is Directive (EU) 2019/882. Its general application date was 28 June 2025, but national implementation and transition provisions affect how particular services are treated. This guide explains how to prepare; it is not a country-specific legal determination.
Does the European Accessibility Act apply to my website?
The EAA applies to specified products and services, not automatically to every website. The European Commission lists e-commerce among the covered service categories. EU business guidance gives online shops and ticketing platforms as examples. The key question is what service the website provides, rather than simply whether a business has a website.
The directive’s e-commerce provisions address accessibility of services provided through websites and mobile-device-based services for the online sale of products or services. A general informational site is not established as covered merely because it is online. If your site supports transactions, bookings, ticket sales, or another service that may fall within a listed category, assess the service and its customer journey, then check the law transposed in every Member State where you offer it. Cross-border operations can mean more than one national law is relevant.
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Covered sectors identified by the Commission also include computers and operating systems, smartphones, digital television equipment, telephony, passenger transport, banking, and e-books. The EAA is distinct from the Web Accessibility Directive, which addresses websites and mobile apps of public-sector bodies.
Check the service and the market
- Describe what customers can do through the site, including purchases, bookings, account services, and customer support.
- Identify the countries in which the service is offered and the applicable national transposition of the directive.
- Record why you consider the service in or out of scope. Ask qualified counsel or the relevant national authority about uncertain cases; EU-level guidance does not settle every national procedure or edge case.
What does accessible service use mean in practice?
Accessibility is about whether people with different disabilities can find, understand, operate, and get help with a service. EU business guidance describes usability for people with cognitive disabilities, compatibility with assistive technologies such as screen readers and voice control, more than one way to input and receive information, consistent and logical navigation, sufficient time to complete tasks, and avoiding visual content that may trigger seizures.
For an online shop, translate those principles into real tasks: finding an item, understanding its price and terms, choosing options, entering delivery details, correcting an error, paying, receiving confirmation, managing an account, and getting support. Consider each task with different input methods and assistive technology—not only the path that works with a mouse and a large screen.
Use EN 301 549 as a technical reference
The Commission identifies EN 301 549 v3.2.1 as the harmonised standard underpinning EU web accessibility requirements and says that version draws heavily on WCAG 2.1. A WCAG 2.1 Level AA evaluation is a useful technical starting point for web content, but it is not safe to treat the phrase “WCAG compliant” by itself as proof that every EAA duty has been met. The EAA also concerns aspects of the service, such as information and support, and EN 301 549 contains requirements beyond web content.
Standards and harmonised references can change. Check the Commission’s current standards guidance and the national law applicable to your service before setting a conformance target or making a compliance claim. The Commission guidance cited here identifies EN 301 549 v3.2.1; do not assume that a later WCAG version has automatically become the applicable harmonised reference.
How to prepare your website: a practical sequence
1. Scope the service and countries
Write down the services the website provides and the markets it serves. Determine whether any are covered by the EAA, then identify the relevant national implementing laws and any transition rules. Keep the reasoning and have legal counsel review ambiguous cases. Member States were required to transpose the directive by June 2022, while its general application date is 28 June 2025; those dates do not erase the directive’s transition provisions or make every pre-existing service subject to identical treatment.
2. Map the complete customer journey
Follow a customer from discovery through completion and support. Include landing pages, search and filters, product or service details, registration and guest checkout, forms, consent and payment interfaces, confirmation, account management, and help channels. Add any third-party interface that customers must use to complete the service. A usable homepage does not compensate for an inaccessible checkout or support route.
3. Audit templates, components, and content
Review the elements shared across pages as well as the content placed inside them. Include navigation, headings, links, buttons, forms and error messages, text resizing and contrast, image alternatives, media, documents, time limits, and third-party components. Check whether essential tasks work with keyboard-only operation and whether screen-reader and voice interactions communicate the information and available actions. This is a practical audit checklist; the exact requirements depend on the applicable standard and law.
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4. Prioritize barriers by their effect on users
Fix issues that stop people from discovering, understanding, selecting, buying, or getting help before lower-impact visual refinements. Assign each issue an owner and due date. Add accessibility acceptance criteria to reusable components and release reviews so that a corrected form, dialog, or navigation pattern does not regress when reused.
5. Test with multiple methods and people
Automated checks can identify some detectable problems consistently, but they cannot by themselves establish whether a person can complete a service journey. Combine them with manual keyboard review, assistive-technology checks, and representative user testing. The Commission recommends involving people with disabilities; an official Commission portal accessibility statement describes review of a representative sample using both automated and manual tests. Neither one scanner run nor one testing method guarantees that every barrier has been found.
| Testing approach | Useful for | What it cannot establish alone |
|---|---|---|
| Automated checks | Repeatedly flagging certain detectable issues across pages or components and checking for regressions. | Whether all content is meaningful, a task is understandable, or a customer can complete a full journey. |
| Manual review | Checking keyboard operation, focus, reading order, labels, error handling, and behavior with selected assistive technologies. | Coverage of every page, technology combination, or lived user experience from a limited sample. |
| Testing with people with disabilities | Learning where real users encounter friction or cannot complete essential tasks in the tested journeys. | Proof that every requirement or every user need has been covered by the sample. |
Plan the sample around the service’s important journeys and the assistive technologies and browsers your customers use. Record what was tested, by whom, with which methods, and what issues remain; repeat checks when a flow or shared component changes.
6. Fix the underlying service, not just the appearance
Remediate markup, content, design-system components, and the steps customers must take. The Commission advises fixing accessibility issues at their source. It also warns that overlays which do not ensure the underlying site meets the standard’s detailed criteria are not an appropriate solution. A widget may alter some presentation, but it does not replace correcting inaccessible controls, structure, content, or service flows.
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7. Document decisions and maintain the service
Keep a practical record of your scope assessment, applicable law and standard version, test sample and methods, findings, remediation decisions, unresolved barriers, owners, and review dates. EU business guidance says service providers should describe how the service meets accessibility requirements and the technical and design procedures used. Provide a usable way for customers to report barriers, route reports to someone able to act, and re-test changed journeys.
Are small businesses exempt?
EU business guidance describes a microenterprise service-provider exemption for a business with fewer than 10 employees and annual turnover below €2 million. It also describes a disproportionate-burden claim, which must be supported by evidence and reviewed every five years. These are distinct provisions, not general permissions to ignore accessibility work.
Check the exact national law and process before relying on either. The exemption is service-based, and the applicable national rules determine how an exception is assessed and documented. Do not assume that being a small company, having a limited budget, or using a third-party platform automatically qualifies.
Do I need an accessibility statement?
Do not automatically transfer public-sector website rules to a private business covered by the EAA. The Web Accessibility Directive applies to websites and mobile apps of public-sector bodies; the EAA covers specified products and services, including private-sector e-commerce. EU business guidance calls for service providers to describe how their service meets accessibility requirements and the technical and design procedures used, but that does not establish that every private EAA provider must publish the same statement in the same format as a public-sector body.
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Check your national transposition for the exact information, publication, and reporting duties that apply. Even where a particular public statement format is not required, clear information about accessibility and a working channel for feedback can help customers and your team identify barriers.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Use screenshots for visual review, not as an accessibility test
A screenshot can help a team compare page layouts or review visual changes, but a static image cannot tell you whether a screen reader announces a button correctly, whether keyboard focus is visible and logical, or whether a customer can complete checkout. Keep screenshot capture as one small part of visual quality assurance, alongside the manual, automated, and user testing above.
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Common preparation mistakes to avoid
- Assuming every website has the same EAA obligations: classify the service and markets first, then verify the applicable national law.
- Checking only the homepage: include the complete customer journey, particularly forms, payment, account tasks, and support.
- Treating an automated score as proof: combine automated checks with manual review and testing with people with disabilities.
- Buying an overlay instead of repairing barriers: correct the underlying content, components, and service flow.
- Promising that WCAG alone settles compliance: use the relevant harmonised technical reference and consider service-level duties and national implementation.
- Assuming small-business status without checking the criteria: verify the service-based exemption or evidenced disproportionate-burden process in local law.
- Copying a public-sector statement format without checking: verify private EAA disclosure duties under the applicable national transposition.
Keep accessibility part of normal product work
Make accessibility criteria part of design, content, development, testing, and support rather than a one-time audit. When a barrier is found, fix the source, check the relevant journey again, and retain a record of what changed and what remains unresolved. The legal starting point is service scope and national implementation; the practical starting point is whether people can complete the tasks your service offers.
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