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European Accessibility Act: What Your Website Needs Now (and How to Fix It Without a Rebuild)

The European Accessibility Act now applies to online shops, booking sites and consumer apps that serve the EU — including non-EU companies. Here is who is in scope, what WCAG 2.1 AA requires and how to fix the common issues without a rebuild.

European Accessibility Act website compliance guide — WCAG 2.1 AA and how to fix it without a redesign

Since 28 June 2025, the European Accessibility Act (EAA) has required many websites, online shops and apps that serve consumers in the EU to be usable by people with disabilities. Enforcement is now picking up across member states, and the rule applies to non-EU companies too. If you run an e-commerce store, a booking site, a banking or telecom service, or a SaaS product sold to EU consumers, this guide explains what the European Accessibility Act means for your website, how to check where you stand, and how to fix the most common issues without rebuilding everything.

This article is practical guidance, not legal advice. For your specific obligations, confirm with a lawyer in the member state where you sell.

What is the European Accessibility Act?

The EAA is Directive (EU) 2019/882. Each member state turned it into national law (for example, Germany’s BFSG), and those laws have applied since 28 June 2025. It sets common accessibility requirements for a list of products and services sold to consumers in the EU.

For websites and apps, the reference standard is the harmonised European standard EN 301 549, which incorporates WCAG 2.1 Level AA. In practice, if your site meets WCAG 2.1 AA, you are meeting the core technical requirement.

Does the European Accessibility Act apply to your website?

The services in scope that most often involve websites and apps are:

  • E-commerce services — online shops and marketplaces selling to consumers
  • Consumer banking services
  • Electronic communications services (telecom)
  • Passenger transport services — websites, apps and e-ticketing for air, bus, rail and waterborne transport
  • Audiovisual media access services and e-books

Three details matter for most businesses:

  • Location does not exempt you. A US or Albanian company selling to consumers in the EU is in scope for those sales.
  • Microenterprises providing services are exempt — fewer than 10 employees and annual turnover or balance sheet of no more than €2 million.
  • B2B-only services are generally outside the scope, because the EAA targets consumer products and services. Many B2B SaaS buyers still ask for WCAG conformance in procurement, so the work rarely goes to waste.

What happens if you are not compliant?

Penalties are set nationally, so they vary. Germany’s implementing law allows fines of up to €100,000, and Italy’s can reach 5% of annual turnover. Authorities can also order a non-compliant service to be fixed or withdrawn. Beyond fines, accessibility complaints are a reputational risk, and an inaccessible checkout simply loses customers.

The most common accessibility problems on business websites

Most issues we see on audits come from the same short list:

  1. Low colour contrast — light grey text on white, or text over photos.
  2. Missing alternative text on product images, icons and buttons.
  3. Forms without labels — placeholders used as labels, error messages that only use colour.
  4. No keyboard access — menus, filters, sliders or cookie banners that cannot be used without a mouse, or invisible focus outlines.
  5. Broken heading structure — headings chosen for size instead of meaning.
  6. Inaccessible checkout and login — CAPTCHAs without alternatives, time limits, custom dropdowns that screen readers cannot read.
  7. Media without captions — product videos and tutorials with no subtitles or transcript.

European Accessibility Act compliance: a practical 5-step plan

1. Run an automated scan, then a manual review

Automated tools such as axe or WAVE catch a useful share of issues quickly, but not all of them. Follow up with manual checks: navigate the main journeys by keyboard only, test with a screen reader (NVDA or VoiceOver), and zoom to 200%.

2. Prioritize the critical user journeys

Fix the paths that make you money and that the law cares about most: home page → product or service page → cart → checkout → account and contact. A perfect blog is worth less than an accessible checkout.

3. Fix the theme and components, not page by page

Most problems live in shared components: the header, menu, product card, form fields and modal windows. Fixing these once in the theme or design system fixes hundreds of pages. On WordPress or WooCommerce this is usually a rebuild without a redesign: same look, cleaner code.

4. Publish an accessibility statement

The EAA requires service providers to provide information on how the service meets the accessibility requirements. A clear accessibility statement page — what standard you follow, known limitations and how users can report problems — covers this and builds trust.

5. Make accessibility part of every release

Add automated accessibility checks to your deployment pipeline and a short checklist for content editors (alt text, headings, link text). Compliance is not a one-time project; every new feature can break it.

Why overlays are not a shortcut

Accessibility overlay widgets promise compliance with one line of JavaScript. They do not fix the underlying code, they can interfere with the assistive technology people already use, and they do not make a site conform to WCAG on their own. Spend the budget on fixing components instead.

Accessibility also improves SEO and conversion

Many accessibility fixes overlap with good technical SEO: meaningful headings, descriptive alt text and link text, fast and clean HTML, and well-labelled forms. Search engines and AI assistants read your page structure much like a screen reader does. A checkout that works by keyboard also tends to work better on mobile.

Example: a WooCommerce store selling to Germany and Italy

A store with 400 products and a custom theme scanned with dozens of issue types. Instead of a full redesign, the work focused on six shared components: header and mega menu, product card, product gallery, filters, cart drawer and checkout fields. Contrast was adjusted within the brand palette, every form field got a real label, and the cookie banner was rebuilt to be keyboard-accessible. An accessibility statement was published and checks were added to the release process. The visual design stayed almost identical.

Frequently asked questions

Does the European Accessibility Act apply to US companies?

Yes, if they provide in-scope products or services to consumers in the EU. The obligation follows the market you sell into, not where your company is registered.

Is WCAG 2.1 AA enough?

For websites and apps, WCAG 2.1 AA (through EN 301 549) is the practical benchmark today. Meeting WCAG 2.2 AA is a sensible target for new builds, since it adds criteria that improve mobile and form usability.

Are small businesses exempt?

Microenterprises that provide services — fewer than 10 employees and no more than €2 million in annual turnover or balance sheet — are exempt from the service requirements. Everyone above that threshold should assume they are in scope.

How long does it take to fix a website?

For a typical business site or shop, an audit takes days and fixing the shared components takes a few weeks. Sites with heavily customized checkouts or legacy code take longer.

Get an accessibility review of your site

Shkulaku audits and fixes websites, WooCommerce stores and web apps for accessibility, performance and technical SEO, usually without changing your design. If you sell to EU consumers, send us your URL and we will tell you where your critical journeys stand and what a realistic fix looks like.

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