The European Accessibility Act: what it means for your website

What is the European Accessibility Act?

The European Accessibility Act is Directive (EU) 2019/882. It sets accessibility requirements for a list of products and services sold in the EU, so that people with disabilities can use them. Every member state had to turn it into national law, and those laws have applied since 28 June 2025.

For websites and apps, the core requirement is one sentence in the Directive: make them accessible “in a consistent and adequate way by making them perceivable, operable, understandable and robust”. Those four words are the four principles of WCAG, the W3C’s Web Content Accessibility Guidelines, which is why WCAG is where almost every team starts.

TipThis guide summarises the Directive and the Dutch regulator’s published guidance. It is not legal advice. If your situation is borderline, ask a lawyer.

Does it apply to your website?

It applies to a fixed list of services provided to consumers: electronic communications (calling, messaging), access to audiovisual media, passenger transport by air, bus, rail and water, consumer banking, e-books, and e-commerce. For most companies the last one is the question.

The Directive defines e-commerce services as services provided at a distance, through websites and mobile apps, at the individual request of a consumer, with a view to concluding a consumer contract. In plain terms: if consumers can buy, book or sign up for something on your site or in your app, it is in scope.

• A webshop, a booking flow, a subscription sign-up or a paid app aimed at consumers: in scope.
• A site that only presents a business and sells nothing to consumers online: not an e-commerce service as the Directive defines it, though it may still fall under another category on the list.
• A purely business-to-business service: the Directive covers services to consumers, so B2B-only services sit outside it.

Microenterprises providing services are exempt. The Directive defines a microenterprise as employing fewer than 10 people with an annual turnover or balance sheet total of no more than 2 million euros. The Dutch regulator ACM puts it the other way round: the rules apply to businesses with 10 or more employees and/or more than 2 million euros in annual turnover.

What does it ask of a website or app?

The Directive describes outcomes, not techniques. For services it asks for:

• Websites and mobile apps that are perceivable, operable, understandable and robust.
• Information about how the service works, available through more than one sense, in text that assistive technology can read, with adequate font size, contrast and spacing, and an alternative for anything that is not text.
• For e-commerce: accessible identification, security and payment steps, and information about the accessibility of the products and services on sale, where their maker provides it.
• Help desks and support channels, where you have them, that can give information about accessibility in accessible ways.
• A description of how the service meets the requirements, included in your general terms and conditions or an equivalent document.

The Directive names no technical standard. It says that services meeting harmonised standards published in the EU’s Official Journal are presumed to comply. In practice that points to EN 301 549, the European accessibility standard, which uses WCAG level AA for web content. Our UX audit guide explains which WCAG version to test against.

What content is exempt?

The Directive does not apply to these kinds of content on websites and in apps:

• Pre-recorded audio and video published before 28 June 2025.
• Office files, such as PDFs and documents, published before 28 June 2025.
• Online maps, as long as essential information for navigation maps is also given in an accessible form.
• Third-party content you do not fund, develop or control, such as an embedded feed you have no say over.
• Archives: content that is not updated or edited after 28 June 2025.

Note the dates. A product video you upload today needs captions; the one from 2023 does not, until you edit it. A checkout widget from a payment provider is not “third-party content” in this sense if you chose it and put it in your checkout.

Is there a way out if compliance is too expensive?

Narrowly. A requirement does not apply where meeting it would fundamentally change the nature of the service, or would be a disproportionate burden. But you have to assess that yourself against the criteria in the Directive, write the assessment down, keep it for five years, and renew it at least every five years or when the service changes. Outside microenterprises, you also have to tell the authority that you are relying on it.

There is also a transition period until 28 June 2030 for products a provider already used lawfully to provide similar services before June 2025, and contracts agreed before that date can run unchanged until they expire, for at most five years. Read both narrowly. Neither is a general grace period for a website you keep developing.

Who checks it in the Netherlands?

ACM, the Netherlands Authority for Consumers and Markets, enforces the rules for e-commerce services, including websites and apps where people buy, take out or reserve products and services, and for electronic communications services. Other regulators cover the other sectors. ACM started enforcing on 28 June 2025.

ACM has said it will focus first on critical accessibility problems that seriously affect usability for people with disabilities, and that it takes a company’s attitude and efforts into account. Consumers can report problems through ConsuWijzer, ACM’s consumer information portal. ACM’s own advice to businesses is short: know the requirements, make a plan with steps, and make someone in the company responsible.

Where should you start?

Start with the tasks that make money, because those are the ones a consumer cannot finish without: finding a product, signing up, logging in, paying. Walk each one with these checks:

1. Put the mouse away and use only the keyboard. Can you reach every link, field and button, in a sensible order, and always see where the focus is?
2. Turn on a screen reader (VoiceOver on a Mac or iPhone, NVDA on Windows, TalkBack on Android). Do images, buttons and form fields announce what they are?
3. Zoom the page to 200% and narrow the window to phone width. Does everything still fit without scrolling sideways?
4. Check text and button colours for contrast. WCAG level AA asks for at least 4.5:1 for normal text.
5. Make a mistake in every form. Is the error explained in words, next to the field, without wiping what was typed?
6. Check the login, verification and payment steps, including anything from a third-party provider you chose.
7. Caption new videos and give new documents an accessible alternative.
8. Write the accessibility information into your terms, and keep it honest: what works, what does not yet, and how to get help.

Automated tools find part of the problems, not all of them. Google Lighthouse’s accessibility check is a useful first pass and our free website review includes its score when the test finishes in time. The keyboard and screen reader steps above are where most of the rest show up.

What should you do next?

Fix the problems on the money tasks first, then patterns: if one form loses input on an error, they all might. Put accessibility in the brief for anything new, because building it in costs far less than fixing it afterwards.

If the fixes add up to a rebuild, that is what our web design and development service does: sites designed and built from the content out, tested with a keyboard and a screen reader before they go live. If the problem is the flow itself, start with a UX audit or our UI/UX design service.

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