European Accessibility Act: the checklist for a small website

The European Accessibility Act (Directive 2019/882) has been enforceable since 28 June 2025. If you sell products or services to consumers in the EU through a website, it very probably applies to you, wherever your business is based.

Who it covers

Businesses providing services to EU consumers in the sectors the Act names: e-commerce, banking and payments, transport, telecoms, e-books and audiovisual media, among others. In practice, any online shop that ships to an EU address is in scope.

The one exemption that matters to small sites: micro-enterprises (fewer than 10 staff and under EUR 2 million turnover) are exempt from the service requirements. Check both numbers; many small businesses are not as small as they think.

What it requires

The technical standard is EN 301 549, which for websites means WCAG 2.1 Level AA. Enforcement is by each member state, with fines set nationally. Services already on the market have transitional arrangements in some cases, but new content and new services must comply now.

The checklist

Work through these in order. The first three are usually template changes that fix every page at once.

1. Every image has alt text that describes it. Decorative images have an empty alt. File names are not alt text.
2. Every form field has a visible label, and errors are described in text, not colour alone.
3. Every link and button has a name. Icon-only controls need an accessible name; "click here" is not a description.
4. Text contrast is at least 4.5:1 (3:1 for large text). Measure it on the rendered page; the stylesheet does not tell you.
5. Everything works from the keyboard, with a visible focus indicator. Cookie banners are the usual trap.
6. The page reflows at 320 pixels with no sideways scrolling, and pinch-to-zoom is not disabled.
7. The page language is declared and matches the text.
8. Headings are real headings, in order, and there is a way to skip repeated navigation.
9. Video has captions. Muted animations do not need them; anything with speech does.
10. Linked PDFs are tagged, have a text layer, a title and a language. A scanned PDF is inaccessible to a screen reader entirely.
11. You publish an accessibility statement if you are a public sector body; it is good practice for everyone.

Check where you stand

Run your site through the free scan on this page. It finds items 1 to 3 and 7 to 8 automatically; the paid pack renders every page to measure 4 to 6 and opens your PDFs for item 10, then writes the fixes and tells you which law applies to your site and when.

This is our reading of the Act in 2026, not legal advice. For anything with legal consequences, have a qualified practitioner review it.