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What the European Accessibility Act actually changes

Published 2025-07-14 · Updated 2026-02-09 · 9 min read · By the Europlabs team

A practical read of Directive (EU) 2019/882: who is in scope, which standard applies, what the June 2025 date meant, and how the microenterprise exemption works.

Who is actually in scope

Directive (EU) 2019/882 covers a defined list of products and services offered to consumers in the European Union. It is not a general “all websites” rule, and the distinction matters because plenty of teams have either panicked unnecessarily or relaxed when they should not have.

The service categories in Annex I that most digital teams encounter are e-commerce, consumer banking, electronic communications, access to audiovisual media services, elements of passenger transport, and e-books. Of these, e-commerce is the widest by far: it captures any website or app through which a consumer concludes a contract for goods or services. A B2B SaaS product sold only to companies is generally outside it. The same company's public marketing site, if it takes consumer sign-ups with a card, is generally inside it.

Two traps recur. First, establishment does not decide it — selling to consumers in the EU does, regardless of where you are based. Second, a company can be partly in scope: one consumer-facing checkout brings that service in even if the rest of the portfolio stays out.

Which standard applies

The directive itself is written in functional terms — information must be perceivable, operable, understandable and robust — and does not name WCAG. In practice the route to demonstrating conformance is the harmonised European standard EN 301 549, which incorporates WCAG level AA more or less wholesale for web content and adds requirements WCAG does not cover: hardware, biometrics, real-time text, two-way voice, and the accessibility of your support documentation and help channels.

For a normal web team, that means: target WCAG 2.2 level AA, then check the handful of EN 301 549 clauses that sit outside WCAG. Clause 12 catches people out most often — your help centre, your support chat and your PDF terms are in scope, and PDFs are usually the worst offenders in the estate.

What the June 2025 date meant

28 June 2025 was the date the national implementing laws became applicable. It was not a grace period expiring on a fixed cliff for every existing thing: service contracts concluded before that date can continue under transitional arrangements until mid-2030 in some Member States, and self-service terminals have their own lifecycle-based transition.

The practical read is less dramatic than the countdown marketing suggested and more serious than “nothing happened”. Enforcement is complaint-led and market-surveillance driven rather than a sweep of automated scans. What triggers attention is a consumer complaint, a competitor, or an enterprise customer's procurement questionnaire. The risk is not that a regulator scans you tomorrow; it is that you cannot answer when someone asks.

The microenterprise exemption

Microenterprises — fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million — are exempt from the service obligations. Three things about that exemption are routinely misread:

• It applies to services, not products. A microenterprise placing a product on the market still carries the product obligations.
• Both limbs must hold. Nine staff and €5 million turnover is not a microenterprise.
• Member States are encouraged to provide guidance and incentives for microenterprises to comply anyway, and some national laws are drafted more tightly than the directive floor. Check your implementing statute, not the directive.

Disproportionate burden

The directive lets an economic operator argue that a specific requirement would impose a disproportionate burden. This is real and legitimate, and it is also the most commonly abused provision in the whole instrument.

It is not a general opt-out. It applies per requirement, must be assessed against the criteria in Annex VI, must be documented, must be re-assessed when circumstances change, and must be notified to the relevant authority on request. Critically, you cannot claim it on the basis that you chose to spend the budget elsewhere — lack of priority is expressly not a valid ground.

In our experience a written, reasoned burden assessment for two or three genuinely expensive requirements reads far better than a compliance claim that quietly ignores them. An undocumented claim is worse than no claim at all.

The accessibility statement

Service providers must make information available on how the service meets the accessibility requirements. The public-sector web accessibility directive established the model statement structure — conformance status, non-accessible content with reasons, a feedback mechanism, and the enforcement procedure — and that structure is the sensible template here too.

Say “partially conformant” when that is true. A statement claiming full conformance while a keyboard user cannot complete checkout is a misleading commercial statement in addition to an accessibility failure, and it is trivially disprovable by anyone who cares to check.

Where to start this quarter

If you are starting from nothing, the sequence that wastes the least money:

1. Write down your scope determination. Which services, which categories, and the reasoning. One page. This is the document everything else hangs from.
2. Test your highest-value journey end to end with a keyboard only. Not the homepage — the checkout or the sign-up. You will learn more in forty minutes than from any scanning dashboard.
3. Fix blockers before auditing everything. If checkout cannot be completed without a mouse, that is the whole project this month.
4. Then get a full audit to find what you cannot see yourself, and to have an independent record.
5. Publish an honest statement with a remediation timetable, and keep to the timetable.

None of this requires a compliance platform subscription. It requires someone to own it and a plan with dates.

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