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Does the European Accessibility Act apply to you? The three-question test

The obligation has applied since 28 June 2025 and most businesses still do not know whether it targets them. The threshold is precise, it fits in three questions, and getting it wrong is not a theoretical risk.

By Robin MonteiroAugust 20, 20263 min · 595 mots
AccessibilityEuropean Accessibility ActComplianceWCAG2026
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Does the European Accessibility Act apply to you? The three-question test

Since 28 June 2025, digital accessibility has stopped being good practice and become an obligation. Most businesses still do not know whether it targets them.

The confusion is understandable. The text is European, each country transposed it into its own law, and most of what is written about accessibility addresses the public sector. But the obligation reaches private companies too. Here is how to find out, in three questions.

The text, in one sentence

The European Accessibility Act is Directive (EU) 2019/882. It has applied since 28 June 2025, and each member state has transposed it into national law: the Barrierefreiheitsstärkungsgesetz in Germany, Ley 11/2023 in Spain, legislative decree 82/2022 in Italy, an implementation act of April 2024 in the Netherlands, an act of 26 April 2024 in Poland, Decreto-Lei 82/2022 in Portugal, and law 2023-171 in France.

Question 1: are you in scope?

The text names specific sectors. E-commerce is one of them, which covers a large share of sites selling to consumers. So are banking services, transport ticketing, telecommunications and audiovisual media.

If you sell online to consumers, assume you are in scope and move to the next question.

Question 2: are you a microenterprise under the text?

This is where it is decided, and where mistakes happen. The exemption requires both conditions together: fewer than 10 employees and an annual turnover or balance sheet total of 2 million euros or less.

One alone is not enough. A six-person company turning over 3 million is not exempt. A fourteen-person company turning over 900,000 is not exempt either.

Second trap: the exemption covers services only. If you place products on the EU market, it does not protect you for those products.

Third trap, and the most expensive for a growing company: there is no grace period. The day you cross the threshold, the obligation applies. No transition window is provided.

Question 3: what do you actually have to do?

The applicable standard is EN 301 549, which for the web references WCAG 2.1 level AA. It is a list of checkable criteria rather than an intention: sufficient contrast, navigation possible with a keyboard alone, text alternatives on meaningful images, a coherent heading structure, form fields that are labelled, captions on video.

The practical consequence is useful. Because the criteria are checkable, the work can be measured, scoped and priced. You are not buying a promise, you are closing a list.

Why the deadline already passing is not good news

Businesses often read a passed deadline as a sign that nothing happened. The opposite reading is more prudent: the transition period is over, which means enforcement is now the phase we are in rather than the phase ahead. Countries differ in how actively they enforce and in the penalties they apply, so the specific exposure depends on where you operate.

What does not depend on the country is the commercial argument. An inaccessible checkout excludes customers who would have bought. Accessibility work overlaps heavily with things that help everyone: clearer structure, faster keyboard paths, readable contrast, properly labelled forms.

Where to start

With a measurement, not a quote. Our free online audit tool checks several accessibility-related points on your page, including text alternatives on images and the declared page language, with no signup and no email address.

It is not a full accessibility audit and we will not present it as one. It is a factual starting point that tells you whether the subject is open or quiet. If you want to go further, describe your situation and we reply in writing.

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About the author

Robin Monteiro

Co-fondateur de Go To Agency

Développeur full-stack et co-fondateur de Go To Agency, Robin conçoit des solutions web performantes avec Next.js, React et les dernières technologies.

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Go To Agency: digital agency, Dijon (France)

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Questions fréquentes

Does the European Accessibility Act apply to my business?+

Ask three questions. First, do you sell online to consumers, or operate in banking, transport ticketing, telecommunications or audiovisual media? If so, you are in scope. Second, do you have fewer than 10 employees AND a turnover or balance sheet total of 2 million euros or less? Both conditions must hold together for the microenterprise exemption, and that exemption covers services only. Third, do you place products on the EU market? If you do, the exemption does not protect you for those products, regardless of your size.

What happens when my company grows past the threshold?+

The obligation applies from that point, with no grace period. This is what growing companies discover latest: nothing provides for a transition window between crossing the threshold and the obligations taking effect. In practice, a business that hires its tenth employee or passes 2 million euros in turnover moves into scope, and its website should be compliant from then on. That is a strong argument for treating accessibility before you are legally required to, since retrofitting under deadline pressure costs more than building it in.

Which technical standard do I actually have to meet?+

European standard EN 301 549, which for web and mobile content references WCAG 2.1 level AA. That is good news in substance: it is not a vague aspiration but a list of checkable criteria. Sufficient colour contrast, full keyboard navigation, text alternatives on meaningful images, a coherent heading structure, form fields that are properly labelled, captions on video. An audit tells you precisely which criteria pass and which do not, which also means the work can be scoped and priced rather than guessed at.

Is this only about the public sector?+

No, and that is the most common misunderstanding. Public sector accessibility obligations came earlier and are covered by a separate directive, which is why most of what is written on the subject addresses public bodies. The European Accessibility Act extends obligations to private businesses in specific sectors, e-commerce prominently among them. If you sell online to consumers and you are above the microenterprise threshold, the fact that you are a private company changes nothing.

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