European Accessibility Act Website Accessibility Requirements

Yes, if your website accepts orders from EU consumers. The EAA applies based on market presence, not company location. Any business placing covered services on the EU market must comply, regardless of where it is headquartered. If you sell to customers in France, Germany, or any other EU member state, your digital services fall under EAA jurisdiction.

The EAA references EN 301 549, the harmonized European standard for ICT accessibility. EN 301 549 incorporates WCAG 2.1 Level AA for web content. Organizations achieving WCAG 2.1 AA conformance satisfy the core web accessibility requirements. EN 301 549 also includes additional criteria for mobile applications, software, and documents that may apply depending on your digital services.

Penalties vary by member state since each country sets its own enforcement framework. Fines range from €5,000 to €500,000 depending on the country and severity. Germany imposes up to €100,000 per violation. France applies €5,000-€250,000 plus annual penalties for missing accessibility statements. Several countries impose daily fines up to €1,000 for ongoing non-compliance. Authorities can also order products removed from market or services suspended.

Only microenterprises have limited exemptions. A microenterprise is defined as employing fewer than 10 people and having annual turnover or balance sheet total not exceeding €2 million. Small and medium enterprises above this threshold must comply with EAA requirements for covered products and services. Member states may have variations in how exemptions apply, so verify requirements in each market you serve.

Yes. Service providers must publish accessibility statements indicating how their services meet EAA requirements. The statement should describe the conformance status of your digital service, identify known accessibility limitations, and provide contact information for users to report barriers. Missing or inaccurate accessibility statements can trigger separate penalties in some member states, including fines up to €25,000 per year in France.

The EU Web Accessibility Directive (2016) applies to public sector websites and mobile applications. The EAA (2019) extends accessibility requirements to the private sector, covering e-commerce, banking, transportation, telecommunications, and other consumer-facing services. Both reference EN 301 549 as the technical standard. Organizations serving EU consumers through commercial digital services are primarily concerned with EAA compliance rather than the Web Accessibility Directive.

The EAA allows economic operators to invoke disproportionate burden if compliance would require significant changes that fundamentally alter the nature of the product or service, or impose excessive cost relative to the estimated benefit. This is not a blanket exemption. Organizations must document their assessment and may still need to provide alternative accessible means. Incorrectly invoking disproportionate burden can itself trigger penalties.

Products and services placed on the EU market after June 28, 2025 must comply immediately. Existing services that were on the market before this date have a transition period until June 28, 2030. However, service providers must still provide accessibility statements for existing services during this period and should demonstrate progress toward compliance. Self-service terminals installed before June 2025 may remain in use until the end of their economic life.