The European Accessibility Act, or EAA, is a law that took effect on June 28, 2025. 2026 is the first full year that EU countries are enforcing it. If you sell to customers in Europe, it may apply to you even if your business is based in the United States.
The short version
- The EAA requires many products and services sold to EU consumers to be accessible to people with disabilities. Websites and online stores are included.
- It applies based on where your customers are, not where your business is. A US company selling to EU shoppers can be covered.
- The technical standard is WCAG 2.1 Level AA, a widely used checklist for web accessibility.
- Very small service businesses are exempt: fewer than 10 employees and under 2 million euros in yearly revenue. That exemption does not cover businesses that sell physical products.
What “accessible” means in practice
Accessibility means a person with a disability can use your site as well as anyone else. That includes people who cannot see the screen and use a screen reader, people who cannot use a mouse and rely on a keyboard, people with low vision, and people who are colorblind.
The EAA points to a standard called WCAG 2.1 Level AA. WCAG stands for Web Content Accessibility Guidelines. In plain terms, meeting it means things like:
- Every image that carries meaning has alt text, a short written description.
- Text has enough contrast against its background to be read easily.
- The whole site can be operated with a keyboard alone.
- Form fields have labels, and error messages explain what went wrong.
- Text can be resized without the layout breaking.
- Video has captions, and content does not rely on color alone to make a point.
It also covers the parts of your site you might forget: PDFs you ask people to download, a booking or scheduling widget from another company, checkout, and any customer portal. If a customer uses it, it counts.
Does it apply to your business?
Ask yourself three questions.
Do you sell to consumers in the EU? The EAA covers business-to-consumer sales. This includes online shops, banking, e-books, ticketing, travel booking, and similar services aimed at the public. If you only sell to other businesses, or you have no EU customers, the law is not aimed at you. Selling occasionally to an EU customer is a gray area worth a real legal opinion if it is a meaningful part of your revenue.
Are you big enough to be covered? If you provide a service and you have fewer than 10 employees and less than 2 million euros in annual revenue, you are exempt from the service rules. Both conditions have to be true, and the employee count is for the whole company, not one location. This exemption is for services only. If you make or sell physical products covered by the Act, the size exemption does not apply.
Could you grow past the line? There is no grace period. The day your business crosses 10 employees or 2 million euros, the exemption is gone and the requirements apply. If you are close to that line, it is smart to build toward compliance now rather than scramble later.
There is also a “disproportionate burden” clause. A business can claim that full compliance would cost too much relative to its size and resources. It is not a free pass. You have to document the assessment, and regulators can challenge it.
What enforcement looks like
Each EU country runs its own enforcement and sets its own penalties. Fines range widely, from around 60,000 euros in Ireland to roughly 900,000 euros in Sweden. Enforcement started fast. Within days of the deadline, disability groups in France sent formal legal notices to four large grocery chains over their online stores.
For a small business, the more likely path is not a court case. It is a customer complaint to a national regulator, a partner or platform asking you to prove your site is accessible, or a bigger client requiring it in a contract. Accessibility is quickly becoming a normal thing buyers check before they sign.
A sensible plan this quarter
- Decide clearly whether the EAA applies to you. Write down the reasoning.
- If it does, get an audit against WCAG 2.1 Level AA. Automated scans catch maybe a third of issues, so the audit needs a person doing keyboard and screen reader testing too.
- Fix the common failures first: contrast, alt text, form labels, keyboard access, heading structure.
- Publish an accessibility statement. It should say what standard you follow, which parts of the site are not there yet, how someone reports a problem, and when you last reviewed it.
- Add accessibility to your process for new content and any redesign, so you do not slide back.
The upside nobody mentions
An accessible site is a better site for everyone. Good contrast helps people reading on a phone in the sun. Clear labels and keyboard support make forms faster to fill. Captions help people watching video with the sound off. Alt text and clean structure also help search engines understand your pages. The work you do for compliance pays off in plain usability, and often in search.
How this differs from the US approach
In the United States, website accessibility is enforced mostly through private lawsuits under the Americans with Disabilities Act. You often find out you have a problem when a demand letter arrives. The EU model is more upfront: the law names a standard, sets a date, and gives national regulators the job of checking. If you sell on both sides of the Atlantic, the practical answer is the same either way. Build to WCAG, keep a record of the work, and publish a statement. One accessible site satisfies both.
One more note for US businesses: the EAA can still reach you. If a meaningful share of your customers are EU consumers, “we are a US company” is not a defense. The test is where the buyers are.
How I can help
A free website health check includes an accessibility review against WCAG 2.1 Level AA. I test your site with a keyboard and a screen reader, run automated checks, and give you a plain list of what fails and how serious each item is.
Most sites fail on a handful of common issues that are quick to fix: contrast, alt text, form labels, and heading structure. If your site has deeper problems, we plan a redesign that builds accessibility in from the start rather than bolting it on later. Every site I build is designed to meet WCAG 2.2 Level AA as standard, and I can write your accessibility statement to match.
Sources
- European Commission, “European accessibility act”
- W3C Web Accessibility Initiative, “Web Accessibility Laws & Policies: European Union”
- W3C, “Web Content Accessibility Guidelines (WCAG) Overview”
- European Commission, “SME definition” (the 10-employee / 2 million euro thresholds, from Recommendation 2003/361/EC)