Website accessibility: who is actually obliged

Most articles about website accessibility open by telling small business owners they are now legally required to comply. For a large number of them, that is not true — and the scare is doing real damage, because it turns a reasonable thing into a compliance panic and then into nothing at all.

Here is who is actually covered, and what is worth doing regardless.

What the law actually says

The European Accessibility Act — Directive (EU) 2019/882 — has applied since 28 June 2025. It does not cover all websites. It covers a defined list of products and services, which the European Commission summarises as including computers and operating systems, ATMs, ticketing and check-in machines, smartphones, TV equipment, telephony services, audio-visual media services, air, bus, rail and waterborne passenger transport services, banking services, e-books and e-commerce.

The item on that list that matters to most readers is e-commerce. If you sell goods or services to consumers online, you are in scope. If your site explains what you do and lets someone contact you, it is not e-commerce.

The exemption most small businesses fall under

The directive exempts microenterprises providing services from the service accessibility requirements. A microenterprise, as the directive defines it, employs fewer than 10 people and has an annual turnover or balance sheet total of no more than €2 million.

Read that carefully, because two details catch people out. The exemption is for services, not for products — a microenterprise that manufactures or distributes a covered product does not get it. And if you are part of a larger group, you are unlikely to qualify on your own headcount.

So: a two-person consultancy with a brochure site is outside the scope of this law entirely. A five-person shop selling online is in scope but exempt as a microenterprise. A forty-person shop selling online is in scope and obliged.

Why you should not stop reading there

Being exempt from a directive is not the same as being usable. Roughly one in six people lives with some form of disability, and a site they cannot use is a customer you never hear from — there is no bounce report for "could not read the contrast".

Accessibility also overlaps almost entirely with things you want anyway: clear structure, readable text, labelled forms, working keyboard navigation. Nearly every accessibility fix is also a usability fix and often an SEO one.

The four principles, in plain terms

The W3C's Web Content Accessibility Guidelines rest on four principles. Content must be:

• Perceivable — people can take it in. Text alternatives for images, enough colour contrast, captions on video.
• Operable — people can use it. Everything reachable by keyboard, nothing that depends on a precise gesture, no time limits that cannot be extended.
• Understandable — people can follow it. Plain language, predictable navigation, errors explained in words.
• Robust — it works with the tools people use, including screen readers.

Six checks you can run today

None of these needs software.

What conformance involves if you are obliged

The six checks above are a first pass, not compliance. If you are in scope and not exempt, the work has a recognised shape and it is worth knowing before you buy anything.

A target level. WCAG defines three conformance levels — A, AA and AAA — and AA is the level normally required and normally achievable. AAA is not expected across a whole site, and a supplier promising it should be asked what they mean.

An audit against the success criteria, not an automated scan. Automated tools catch a useful minority: missing alt attributes, contrast failures, absent labels. They cannot tell whether your alt text is meaningful, whether your keyboard order makes sense, or whether an error message explains anything. The part that needs a person is the part that fails.

A remediation list with owners and dates, because an audit that produces only a score changes nothing.

A published accessibility statement, saying what conforms, what does not yet, and how someone can report a problem and reach a human.

Retrofitting is consistently more expensive than building it in, for the same reason that most of this list is structural. Ask about accessibility while choosing who builds your site, not after they have finished.

What to do with all this

If you are obliged: get a proper audit. An article is not one, and the difference between "mostly fine" and "conformant" is exactly the part that needs expertise.

If you are exempt — which, if you are reading this as a one-person business, you probably are — run the six checks above, fix what they find, and do not let anyone sell you a compliance package for a law that does not apply to you. Your motivation is that more people can buy from you. That is a better reason than a fine you were never going to receive.

Related: what customer data you may collect covers the other rule set that genuinely does apply to almost everyone, and a slow page excludes people too — test yours.

Sources

• Directive (EU) 2019/882 (European Accessibility Act) · EUR-Lex
• European accessibility act · European Commission
• Accessibility Principles · W3C Web Accessibility Initiative
• How to Meet WCAG (Quick Reference) · W3C Web Accessibility Initiative

Frequently asked

Does the European Accessibility Act apply to my brochure website?

If your site explains your services and offers a contact form, it is not e-commerce and falls outside the directive's list. That changes the moment you sell online, at which point scope applies and the microenterprise exemption becomes the question.

What is the difference between WCAG and the European Accessibility Act?

WCAG is a technical standard published by the W3C describing how to make content accessible. The European Accessibility Act is law that makes accessibility obligatory for certain products and services and points at standards to define what compliance means.