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Does the European Accessibility Act apply to my website?
Start with the service, not the fact that it runs on the web. The EAA applies to specified products and services; a website or mobile service may be covered when it is how a covered service is provided. Calling a company a technology business, or describing a site as informational, does not settle the question. Map what users can do through the service and assess the relevant EAA category under the applicable national law.
Service categories that can bring a website or app into scope
- E-commerce: a service provided at a distance through a website or mobile service, by electronic means and at a consumer’s individual request, to conclude a consumer contract. The Directive’s recitals clarify that the accessibility obligations cover online sales of any product or service.
- Passenger transport: specified transport-related services and elements, which can include websites, mobile services, ticketing and travel information. Requirements have qualifications, including a distinct rule for urban, suburban and regional transport; do not assume every transit website is covered in the same way.
- Consumer banking, electronic communications, access to audiovisual media services, e-books and dedicated software, and answering emergency communications to 112.
The EAA also covers specified products, including consumer general-purpose computer hardware and operating systems, certain self-service terminals, some consumer communications and audiovisual terminal equipment, and e-readers. Product requirements are distinct from the service rules that may apply to a website or app.
Dates and national rules
Member States were required to transpose the Directive by 28 June 2022, and to apply the measures from 28 June 2025. Transitional arrangements may affect particular products or services: the Directive provides for certain continued use of products already used to provide services and possible transitions to 28 June 2030. Some self-service terminals may remain in use until the end of their economically useful life, subject to the Directive’s limit. These are not blanket extensions for all websites. Check the national implementing law and the relevant transition conditions before relying on an exception.
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What do developers need to make accessible?
For a covered service, Annex I requires accessible information about the service and its accessibility features. The website, related online applications and mobile services must be accessible in a consistent and adequate way. The Directive uses four functional principles: perceivable, operable, understandable and robust. It also addresses accessible support services where available.
Perceivable
Users must be able to perceive information and interface components through the ways they use the service. In engineering terms, consider whether essential information and controls are available to people who cannot use a particular sensory channel, and whether content works with relevant assistive technologies.
Operable
Users must be able to operate interface components and navigate the service. Review the complete task path—not just the landing page—including menus, forms, errors, account flows and any steps needed to complete a transaction.
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Understandable
Information and operation must be understandable. Check that instructions, labels, processes and feedback make sense as users move through the service, including when a task fails or requires correction.
Robust
Content must be robust enough to work with a variety of user agents, including assistive technologies. Test the service as an integrated experience rather than treating visual appearance in one browser as sufficient.
E-commerce tasks need particular attention
For covered e-commerce, accessibility is not limited to product pages. The Directive includes accessible identification, security and payment functionality. It also covers accessibility information about goods or services when that information is supplied by the responsible operator. Trace the full consumer journey from finding an offer to completing the contract, and include each relevant identity check, security step and payment control in design and testing.
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Is WCAG or EN 301 549 required?
The Directive specifies accessibility outcomes; a technical standard can help translate those outcomes into implementation criteria. The European Commission identifies EN 301 549 v3.2.1 as the technical criteria standard underpinning EU legal accessibility requirements. Under Article 15, conformity with a harmonised standard whose reference has been published in the Official Journal creates a presumption of conformity only to the extent that the standard covers the relevant requirements.
Do not treat a standard as a blanket safe harbour or infer that a particular checklist alone resolves legal coverage. Verify which standard and published references currently apply, which requirements they address, and how the relevant Member State has implemented the Directive. The national rules and the actual service remain central to a compliance assessment.
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What is excluded, exempt or subject to a limited exception?
The Directive contains specific exclusions and conditional exemptions. They are not a reason to assume an entire service is out of scope; assess the particular content, provider and requirement involved.
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Specified content exclusions
- Pre-recorded time-based media and office file formats published before 28 June 2025.
- Online maps, where essential information is provided accessibly for navigational maps.
- Third-party content that is not funded, developed or controlled by the relevant economic operator.
- Qualifying archived content that is not updated or edited after 28 June 2025.
These exclusions relate to specified content. They do not automatically exempt every other part of a website or mobile service on which that content appears.
Microenterprises providing services
The EAA exempts microenterprises providing services from the service accessibility requirements. The Directive defines a microenterprise as an enterprise that employs fewer than 10 people and has annual turnover or an annual balance sheet total not exceeding EUR 2 million. Confirm the definition against the business’s circumstances and applicable national implementation before relying on this exemption.
Fundamental alteration or disproportionate burden
Requirements need not apply where meeting them would cause a fundamental alteration or disproportionate burden, but the Directive provides a documented assessment process. This is not a general opt-out. AccessibleEU guidance says lack of priority, time or knowledge is not a legitimate reason for claiming disproportionate burden. Identify the affected requirement, document the relevant assessment and check the national process rather than treating resource pressure alone as an exemption.
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How should a development team turn the requirements into work?
Use the Directive’s outcomes to shape a service-level engineering workflow. This is a practical way to organize work, not a substitute for checking every applicable legal requirement or the national implementation.
- Map coverage and journeys. Identify the service category that may apply, the countries served and the user tasks that deliver the service. For e-commerce, include the route through identification, security and payment.
- Inventory the service surface. Include the website, related online applications and mobile services, plus information and support services where relevant. Record third-party components and content, and determine who funds, develops or controls them.
- Review information and interactions against the four principles. For each important task, assess whether information and controls can be perceived, navigation and actions operated, instructions and processes understood, and the experience used robustly with assistive technologies.
- Fix issues in the service itself. The Commission recommends addressing accessibility issues at source rather than relying on an overlay or other tool that does not ensure the website itself meets detailed standard criteria.
- Test with users and assistive technologies. Include people with disabilities in testing, as the Commission recommends. Automated checks can form part of an engineering workflow, but they do not by themselves establish that the service meets its legal obligations.
- Document decisions that depend on exceptions or standards. Keep the basis for any claimed exclusion, exemption or burden assessment clear, and verify applicable national rules and current standards references.
Are accessibility overlays or automated scans enough?
No. The Commission says overlays, or other tools that do not ensure the website itself meets detailed standard criteria, are not an appropriate solution; it recommends fixing issues at source. An overlay may change what a user sees without correcting the underlying information, interface or functionality required by the service.
Automated testing can help teams identify some issues and monitor changes, but a scan is only one input. It cannot replace assessment of the full task flow, robust operation with assistive technologies, or testing that involves people with disabilities. A screenshot can help inspect a rendered page or compare visual changes, but it cannot establish that a page is perceivable, operable, understandable or robust.
Where does the EAA fit with the Web Accessibility Directive?
The Web Accessibility Directive (Directive (EU) 2016/2102) covers websites and mobile applications of public-sector bodies. The Commission says it requires public-sector accessibility statements, a user feedback mechanism and regular Member State monitoring. The EAA addresses specified products and services, including parts of the private sector, and complements the WAD. A public-sector site can therefore have WAD duties and also fall within the EAA for a covered activity such as e-commerce or passenger transport. One directive does not make the other irrelevant.
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For a rendered-page capture to include in a visual review workflow, ScreenshotNeo can return a screenshot with one GET request. A screenshot is not an accessibility audit or proof of EAA compliance; use it only as a visual artifact alongside accessibility testing and evaluation.
curl -G "https://api.screenshotneo.com/v1/shot" -d access_key=YOUR_API_KEY --data-urlencode url=https://stripe.com -o shot.webpSee the ScreenshotNeo API documentation for request options. ScreenshotNeo accepts cookie or consent banners like a visitor and removes more than 60 known consent platforms, newsletter popups and chat widgets before capture; each step can be turned off. Bot checks, blank pages, timeouts, failed loads and cache hits are not billed, and the response indicates the page verdict and billing status. Its MCP server provides screenshot and PDF tools for AI agents. The free plan includes 1,000 screenshots per month with no card; paid plans start at $5 for 3,000 screenshots.
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