What the European Accessibility Act covers
The European Accessibility Act, or EAA, is Directive (EU) 2019/882. EU Member States were required to transpose it into national law, with the main accessibility requirements applying from 28 June 2025.
Its scope covers specified products and consumer services rather than every website simply because somebody in Europe can visit it. Covered areas include consumer banking, electronic communications, certain passenger transport services, ebooks and ecommerce services. The Directive defines an ecommerce service as a service provided at a distance through websites or mobile services, electronically and at the individual request of a consumer, with a view to concluding a consumer contract.
That makes online purchasing journeys particularly relevant. Product discovery, account creation, checkout, payment, authentication and customer information can all form part of the service rather than accessibility stopping at the visual design of the homepage.
A UK business should therefore look at what it sells, who it sells to and which EU markets it serves. The precise legal obligations and enforcement route arise through the national law implementing the Directive in the relevant Member State.
When UK businesses may be affected by the EAA
Brexit does not make EU accessibility requirements irrelevant to every UK seller. A UK company providing a covered consumer service into an EU market may need to satisfy the rules applicable in that market. By contrast, a business whose services are genuinely limited to the UK is not brought within the EAA simply because its website is publicly accessible from an EU country.
The first question is therefore scope, not the colour contrast of the website. Establish whether the activity is consumer-facing, falls within a category covered by the Directive and is actually supplied into the EU.
The distinction between B2C and B2B activity can matter. The EAA definition of ecommerce services is tied to concluding a consumer contract, so a business-to-business service should not automatically be treated as covered ecommerce merely because orders are accepted online.
There are also transitional provisions. For example, the Directive permits certain service contracts agreed before 28 June 2025 to continue without alteration until they expire, subject to a maximum period of five years from that date. Transitional rules are specific, so they should not be treated as a general postponement of the Act.
The EAA microenterprise exemption
The Directive exempts microenterprises providing services from its service accessibility requirements. Under the EU definition, a microenterprise employs fewer than 10 people and has annual turnover or an annual balance-sheet total not exceeding EUR 2 million.
This is a significant qualification because many descriptions of the EAA imply that every small online seller is automatically subject to the same requirements. The exemption is specifically relevant to microenterprises providing services. Product obligations are different, so businesses dealing with physical products should not assume that the same exemption removes every EAA duty.
Company structure can also affect SME calculations because EU rules contain provisions for linked and partner enterprises. A business close to the threshold should therefore check the formal definition rather than relying only on the headcount of one trading entity.
Being exempt from the EAA does not mean accessibility has no value or that other legal duties disappear. In Great Britain, service providers also need to consider the Equality Act 2010 and its reasonable-adjustment duties.
EAA website accessibility requirements in practice
The Directive sets accessibility requirements and requires service providers to make information available describing how a covered service meets the applicable requirements. Annex V says this information should cover the design and operation of the service and explain how relevant accessibility requirements are met.
For a website, practical work normally starts by checking the complete customer journey. Keyboard operation, labels and instructions, visible focus, error handling, colour contrast, document accessibility, authentication, payment steps and compatibility with assistive technology may all need examination depending on the service.
WCAG 2.2 AA is a useful technical benchmark for modern web accessibility work, but it is important not to rewrite the legislation inaccurately. The EAA itself contains functional accessibility requirements and a framework for harmonised standards and technical specifications. It does not simply contain a sentence saying that every covered website must obtain WCAG 2.2 AA certification.
Automated scanning alone is not enough for this work. A crawler can find many code-level problems, but it cannot reliably prove that a checkout can be completed by keyboard, that authentication works with assistive technology or that instructions make sense when read out of visual context. Our free accessibility checker is useful for an initial technical scan, while an accessibility audit adds manual testing.
Documenting EAA accessibility work
Accessibility remediation should leave evidence behind. For a covered service, that can include the audit findings, the changes made, manual test records, the published accessibility information and records showing how accessibility is monitored as the service changes.
This matters because accessibility is not static. A compliant component can be replaced, a checkout provider can change, a cookie layer can obscure keyboard focus, or a new account process can introduce inaccessible authentication. Testing should therefore cover production changes as well as the initial remediation project.
Our published £1,049 EAA Compliance Package includes a WCAG 2.2 AA audit, remediation of critical and serious issues, an accessibility statement, a staff briefing document, a compliance evidence pack and three months of monitoring. It is designed to address the website accessibility work and documentation included in the package, rather than to replace legal advice on whether a particular business or service falls within a Member State's legislation.
Businesses that need the individual components can also read about accessibility statements, accessibility remediation and ongoing accessibility monitoring.