European Accessibility Act: What It Means for Websites

Since 28 June 2025, the European Accessibility Act (EAA) requires businesses across the EU to make many consumer-facing digital services accessible, including online shops, booking sites and subscription services. Microenterprises providing services are exempt, and each country enforces the rules through its own national law. Below we explain what that means for your website, using Austria’s implementation, the Barrierefreiheitsgesetz (BaFG), as a worked example.

A quick note: this article is general information based on publicly available sources as of October 2026. It is not legal advice. Whether and how the law applies to your business should be checked case by case with a lawyer or your local business association.

What is the European Accessibility Act?

The EAA is Directive (EU) 2019/882 on accessibility requirements for products and services. Its aim is simple: everyday products and services should be usable by people with disabilities, under one common set of rules across the EU single market. The European Commission lists online shopping alongside banking, e-books, computers and public transport.

Because it is a directive, every member state had to turn it into national law. Austria did so with the Barrierefreiheitsgesetz, which also took effect on 28 June 2025. The core rules are the same everywhere. Enforcement, authorities and fines differ by country.

Who has to comply?

The EAA lists exactly which products and services it covers. It applies to products placed on the market and services provided to consumers after 28 June 2025.

Products include:

• consumer computers and their operating systems
• self-service terminals such as ATMs, ticket machines, check-in kiosks and payment terminals
• smartphones and other consumer communication devices
• devices used to access audiovisual media, such as smart TVs
• e-readers

Services include:

• electronic communication services
• access to audiovisual media services
• elements of passenger transport services (websites, apps, e-tickets, real-time information)
• consumer banking services
• e-books and the software they need
• e-commerce services

E-commerce: the category that matters for websites

For most businesses, the last item is the important one. The directive defines e-commerce services as “services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract”.

Austria’s Chamber of Commerce (WKO) gives practical examples: online shops and apps, hotel and travel portals with booking, online appointment booking tools, digital publications, and sites selling memberships or subscriptions.

In practice:

• Purely informational sites with no way to conclude a contract online generally fall outside this definition.
• Pure B2B is not covered, because the rules are about consumers. A shop that sells to both businesses and private customers is.
• Location is not a loophole. The rules attach to services offered to consumers in the EU. A US or UK company selling to EU consumers should check the national laws of the countries it serves.

What is excluded

Some website and app content is out of scope. That includes pre-recorded audio and video and office documents published before 28 June 2025, archived content that has not been updated since, and third-party content that you neither fund, develop nor control.

Be careful with embedded services: a booking or payment widget that you pay for and build into your checkout is hard to describe as content you do not fund or control.

The microenterprise exemption

Article 4(5) of the directive is clear: microenterprises that provide services are exempt from the accessibility requirements and all related obligations. Austria adopted this one to one in § 6 BaFG.

A microenterprise has:

• fewer than 10 employees, and
• an annual turnover or balance sheet total of no more than 2 million euros.

Three points people often miss:

• The exemption covers services only. Manufacturers, importers and distributors of covered products still have to comply, with lighter documentation duties.
• Small and medium-sized enterprises are not exempt. In Austria they simply face lower maximum fines.
• If you grow, you lose the exemption. The WKO points out that retrofitting an online shop later is likely to cost more.

Quick check: does the accessibility law cover your website?

1. Can consumers book, order or subscribe to something on your website or app?

   NoInformation-only site – usually not covered

2. Is the offer aimed (also) at private individuals?

   NoPure B2B – not covered

3. Are you a microenterprise: fewer than 10 employees and at most €2m turnover or balance sheet total?

   YesExempt for services

4. Probably covered: make your website and checkout accessible (target: WCAG 2.2 AA) and meet the information duty.

Disproportionate burden

The requirements also apply only as far as they do not fundamentally alter the service or impose a disproportionate burden. This is not a free pass. Under the Austrian law, for example, you have to assess the burden against set criteria, document it, keep the documentation for five years and reassess services regularly. If you receive public or private funding to improve accessibility, you cannot rely on this exception.

What WCAG and EN 301 549 mean in practice

The law describes the requirements in general terms: websites and apps must be perceivable, operable, understandable and robust. Technical standards fill in the detail.

The key standard is EN 301 549. Austria’s market surveillance authority, the Sozialministeriumservice, notes that it references the Web Content Accessibility Guidelines (WCAG) 2.1, which are therefore used in its checks. In September 2026, version 4.1.1 of EN 301 549 was published. It aligns with WCAG 2.2 and, for the first time, maps its requirements explicitly to the EAA.

For your website, that means: aim for WCAG 2.2, level AA. The four principles behind it are easy to remember:

• Perceivable: Content does not rely on a single sense. Images have text alternatives, videos have captions.
• Operable: Everything works with a keyboard, and nobody is rushed by time limits.
• Understandable: Plain language, predictable navigation, helpful error messages.
• Robust: Clean code that screen readers and other assistive technology can read reliably.

The duty to inform

You also have to publish information on how your service meets the requirements, in an accessible format. In essence, that is a description of the service and its accessibility. Austrian law allows this to sit in your terms and conditions, but the WKO recommends a separate page that is easy to find.

Enforcement and penalties: the Austrian example

Under the directive, each country sets penalties that must be “effective, proportionate and dissuasive”. Here is how Austria does it.

The Sozialministeriumservice runs its own checks and follows up on reports. Consumers can report issues, as can the consumer association VKI, the Austrian Disability Council, the Federal Chamber of Labour and the Chamber of Commerce. The authority has eight weeks to say whether it will open proceedings.

If it finds problems, it first asks the business to fix them within a deadline, after giving at least ten working days to respond. If that does not work, it can order measures, up to informing the public or stopping the service. Decisions can be appealed to the Federal Administrative Court.

On top of that, § 36 BaFG sets administrative fines:

Violation (examples)	General maximum	Maximum for SMEs and microenterprises
Offering a non-accessible service	€80,000	€50,000
Missing or incorrect accessibility information	€40,000	€25,000
Breaching record-keeping, reporting or cooperation duties	€16,000	€10,000

The amount depends on factors such as the extent of the breach, the number of people affected and repeat offences. One more duty: if you find that your service does not comply, you must fix it and notify the authority without delay.

Other countries use different authorities and amounts, so check the rules in each market you serve.

A practical checklist for your website

1. Check whether you are covered: Can consumers conclude contracts on your site or app? Are you a microenterprise? Which EU countries do you serve?
2. Audit what you have: Automated tools such as axe or Lighthouse catch only part of the issues. Test manually with a keyboard and a screen reader too.
3. Structure: A logical heading hierarchy, landmark regions and the correct language set in the code.
4. Contrast: At least 4.5:1 for normal text and 3:1 for large text.
5. Keyboard: Every function reachable by keyboard, a visible focus indicator, no keyboard traps.
6. Images: Meaningful text alternatives; mark purely decorative images as such.
7. Forms: Visible labels, clear error messages, never colour alone as a signal.
8. Media: Captions for video, transcripts for audio.
9. Zoom and reflow: Text can be enlarged to 200 %, and the page works at 320 pixels wide without horizontal scrolling.
10. Motion: Auto-playing animation can be paused, and the system setting for reduced motion is respected.
11. Third parties: Test booking, payment and chat widgets, and ask vendors for their accessibility information.
12. Documents: Create new PDFs and office files accessibly as well.
13. Publish your accessibility information: On its own page that is easy to find, for example linked in the footer.
14. Keep it up: Build accessibility into editing and development. The law expects procedures that keep your service compliant over time.

The bottom line

The European Accessibility Act does not cover every website, but it does cover every site where consumers in the EU buy, book or subscribe online, unless you are a microenterprise providing services. With WCAG 2.2 AA as your target, an honest audit and a published accessibility statement, you are on solid ground. And your site gets better for every visitor.

If you want your website checked or rebuilt with accessibility in mind, our web design service page explains how we work with clients wherever they are. Or get in touch through the contact form; we reply within one business day.