Selling Into the EU? The European Accessibility Act Applies to You

Since 28 June 2025, the European Accessibility Act (Directive (EU) 2019/882, the “EAA”) has applied across the European Union. If you're based in the UK, or anywhere outside the EU, it's tempting to assume this is someone else's problem. It isn't. The EAA applies based on where your customers are, not where your business is registered. Sell to consumers in Ireland, Germany, France or any other EU country, and the same accessibility requirements that apply to an EU-based business apply to you too.

Brexit doesn't change this

Leaving the EU took the UK out of EU institutions, not out of EU consumer law that applies to anyone selling into the bloc. Manufacturers, distributors, importers and online sellers based outside the EU are covered the moment their products or services reach EU consumers, whether that's through your own website, an Etsy shop, a Shopify store, or a marketplace listing.

Who is actually covered

• You sell products online (through your own site, Etsy, Shopify or similar): you're covered, regardless of your company's size.
• You offer certain services to EU consumers (e-commerce, banking, travel and ticketing, telecoms, e-books and more): you're covered too, unless the microenterprise exemption applies.
• You're a microenterprise (fewer than 10 employees and annual turnover or balance sheet under €2 million) and you sell only services, with no goods involved: the EAA's own exemption may apply, and you're generally not obliged to comply.
• Pure B2B with no consumer contact: usually not covered.

The detail people miss most often: the microenterprise exemption only ever applies to service providers. A one-person shop selling handmade goods through Etsy is covered regardless of size, because it sells products, not a service.

The 5 mistakes we see most often

1. Weak contrast: light grey text on white, buttons that barely stand out from the background. It looks modern, but is hard to read for many users.
2. Missing alt text: product images with no description. A screen reader just announces “image”, leaving the user with no idea what's shown.
3. Not keyboard-operable: dropdown menus or cart icons that only respond to a mouse hover. Anyone who doesn't navigate with a mouse can't get in at all.
4. Form fields without real labels: a label that sits next to a field visually, but isn't technically linked to it. Screen readers then can't match the two up.
5. Videos without captions: explainer or brand videos with no captions or transcript, unreachable for deaf or hard-of-hearing visitors.

The 5-minute self-test

1. Tab test: click anywhere on the page and press only the Tab key. Can you see where focus is? Does it take you through the menu, buttons and form?
2. Zoom test: set your browser zoom to 200%. Does the text stay readable, or do elements start overlapping?
3. Alt text check: right-click a product image → “Inspect”. Is there a real description in the `alt` attribute, or is it empty?
4. Form test: click directly on a field's label (e.g. “Email”). Does the cursor jump into the matching field automatically?
5. Heading check: do the headings on the page (H1, H2, H3…) follow a logical order, with no jumps or gaps?

A self-test shows you the surface of the problem. Whether you're actually compliant comes down to details that are easy to miss without specialist knowledge.

When the self-test is enough, and when you need a full audit

The self-test is an honest first step, not a substitute for a real assessment. It surfaces obvious problems, but not whether your forms genuinely work with every screen reader, or whether hidden issues sit in your checkout. Automated scanning tools only catch part of the picture too, technical things like missing alt text or contrast failures, but not real operability or screen-reader logic. A professional audit is worth it once you clearly fall under the EAA (you sell products, or you're a larger service business), once your self-test already turns up several of the five common problems, or when you need a documented basis you can point to.

Enforcement is national, and the numbers vary a lot

Each of the 27 EU member states transposed the EAA into its own national law, with its own regulator and its own penalty scale, so there's no single EU-wide fine. To give you a sense of the range: France caps sanctions at €50,000 per non-compliant service, doubled for repeat breaches. The Netherlands' regulator can fine up to €900,000 or 1% of turnover. Italy's fines run from €5,000 to €40,000 per violation, rising to 5% of turnover for very large companies. Which figure would apply to you depends entirely on which EU country your customers are in and where enforcement action is brought; sanctions are defined by national law, not by the EAA itself.

The technical bar is the same everywhere

Whichever EU country enforces it, the underlying standard doesn't change: EN 301 549, which incorporates WCAG 2.1 at level AA. That's the target for your website, your checkout, and any customer-facing app, no matter which member state your buyers are in.

We offer a free initial check: tell us your shop or website address and which EU countries you sell into, and we'll give you an honest read on where you stand, even if the answer is “you're mostly fine already.” On request, we follow up with a full audit against WCAG 2.1 AA.