The European Accessibility Act and Your Website

For years accessibility was the thing everybody agreed was important and nobody budgeted for. That changed on 28 June 2025, when the European Accessibility Act started to apply across all 27 member states. It is now a legal requirement, with supervisory authorities and fines behind it.

This is not a scare piece. Most of what the law asks for is unglamorous and cheap to do when a site is built, and expensive to retrofit later. Here is what actually applies to you.

Does it apply to my business?

The Act covers products and services sold to consumers, and that explicitly includes e-commerce, banking, transport, e-books and telecoms. If your website sells something to a consumer, takes bookings, or is the way people become your customers, assume you are in scope.

There is one exemption worth knowing: microenterprises providing services — fewer than 10 people and under 2 million euros turnover — are outside the services obligations. Note the "and". A company of eight people turning over three million is not a microenterprise.

Two more things people get wrong. First, the exemption covers services, not products. Second, being outside the Act does not put you outside everything else: public sector bodies have had their own accessibility rules for years, and if you sell to them, they will ask.

What it actually requires

The Act itself is written in outcomes: digital services must be perceivable, operable, understandable and robust. Those four words come straight from the Web Content Accessibility Guidelines, and the technical standard the EU points to, EN 301 549, is built on WCAG 2.1 level AA.

In practice, AA is a list of things that are mostly obvious once someone says them out loud:

Text has to be readable. Body text needs a contrast ratio of at least 4.5 to 1 against its background; large text needs 3 to 1. Pale grey on white fails, and so does white on a light brand colour, which is the one that catches most companies out.
Everything works with a keyboard. Every link, button, form field, menu and overlay must be reachable with Tab and usable with Enter or Space, and you must always be able to see where the focus is.
Images carry alt text. Descriptive when the image means something, empty when it is decoration.
Forms have real labels. A placeholder is not a label: it disappears the moment someone types, and a screen reader announces the field as unnamed.
Video has captions, and audio has a transcript.
The page has structure. One h1, headings in order, landmarks, a page language declared in the markup.
Nothing depends on colour alone. A required field marked only in red says nothing to someone who cannot distinguish red.

None of this stops you having a good-looking site. Most of it is invisible to people who do not need it.

Who checks, and what happens

Each country appoints its own market surveillance authority. In the Netherlands that is the Autoriteit Consument en Markt, which can impose fines up to 900,000 euros. Spain enforces through its consumer protection framework, with its own penalty regime.

What happens in practice is less dramatic than the number suggests. Authorities generally act on complaints, and the first contact is usually a notice with a deadline rather than an invoice. Companies that respond with a plan and a timetable almost always resolve it without a fine. Companies that ignore the letter are the ones that end up paying.

There is a second deadline that gets forgotten: from 28 June 2030, existing content has to comply too, not just what you publish from now on. If you have a large archive, that is a project worth starting early rather than discovering in 2029.

The bit almost everyone misses

Your cookie banner is part of your website, so it falls under the Act like everything else. It has to be operable by keyboard, announced properly to a screen reader, and it cannot trap focus. A great many banners — including plenty sold as compliance products — fail on all three.

The same goes for chat widgets, booking overlays and anything else a third-party script drops onto the page. You are responsible for what your site does, including the parts you did not write.

How to find out where you stand

You can get a useful picture in an afternoon, without buying anything:

Run an automated check. Free tools based on the axe engine will find contrast failures, missing alt text and unlabelled fields in seconds. They catch perhaps a third of real problems, but it is the cheapest third.
Put the mouse away. Load your homepage and reach the contact form using only Tab, Shift+Tab and Enter. If you get stuck, or lose track of where you are, so does everybody who navigates that way.
Zoom to 200 percent. Text should reflow, not disappear behind other elements or force sideways scrolling.
Turn on the screen reader you already own — VoiceOver on a Mac, Narrator on Windows — and listen to your own homepage for two minutes.

That last one is uncomfortable and it is the most useful thing on the list.

What it costs

Building accessibility in from the start adds very little to a project: it is mostly a matter of choosing readable colours, writing proper labels and testing with a keyboard. Nobody should be charging a premium for it in 2026.

Retrofitting is a different matter, and the cost depends almost entirely on how the site was built. A site with clean, semantic HTML can usually be brought to AA in days. A site built out of nested divs with click handlers, or assembled from a page builder that generates its own markup, can take weeks — and sometimes rebuilding is genuinely cheaper than patching.

One thing worth being blunt about: the overlay widgets that promise instant compliance for a monthly fee do not work. They have been the subject of lawsuits, disability organisations advise against them, and they do not make a keyboard trap go away. There is no button that fixes this.

The honest summary

If your site was built in the last couple of years with clean markup and someone thought about contrast, you are probably close and the gap is a day or two of work. If it was assembled from a template with a low-contrast palette and a bolted-on cookie banner, you have a real project.

Either way the useful first step is the same: find out where you stand. An accessibility audit tells you what needs doing and how long it will take, and it turns a vague legal worry into a list you can price.

This is a practical summary, not legal advice. For your specific obligations, check with a lawyer or your national supervisory authority.