The European Accessibility Act covers your website when consumers can buy through it

Since 28 June 2025 you have probably had emails about the European Accessibility Act, most of them selling a scan or a widget. Under all of them sits one simple question. Does the European Accessibility Act cover your website, and if it does, what does it ask for? The answer depends on who buys from you and how. Having a website is not enough to bring you in.

This is how I read the directive and the national rules in October 2026. It is not legal advice, and where your business sits close to a line, ask a lawyer in the country where you sell.

The Act covers a website where consumers buy, not every website

The European Accessibility Act is an EU directive, Directive (EU) 2019/882. Article 2 lists the services it covers when they are provided to consumers after 28 June 2025. They are phone and internet services, access to TV and video services, parts of passenger transport, consumer banking, e-books, and e-commerce services. A consumer, as the directive defines one, is a person who buys for purposes outside their trade or business.

E-commerce services are services provided at a distance, through websites and apps, at a consumer’s request, “with a view to concluding a consumer contract”. The directive’s recitals add that this applies to the online sale of any product or service. The Dutch regulator, the ACM, puts it in plainer terms on its page for businesses. It means sites and apps where consumers buy, rent, order, take out or reserve something, such as online shops, booking platforms and subscription sites.

Where an ordinary business website sits, as I read it:

Your website does this	Covered as e-commerce?
Consumers buy and pay for products	Yes
Consumers book and pay for appointments, classes or rooms	Yes
Consumers sign up to a subscription	Yes
Only businesses can buy from you	No, this part of the Act is about consumers
It describes your services and takes enquiries; the contract is agreed later, by email, phone or in person	As I read the definition, no, because no contract is concluded through the site

The Act also reaches beyond the EU’s borders. It defines a service provider as anyone who provides a service on the EU market or offers it to consumers in the EU. A UK shop that sells to customers in Ireland, France or Germany is in scope for those sales, even though the UK itself has no such law.

Small businesses that provide services are exempt, and the line is ten people

Article 4(5) exempts microenterprises that provide services from the accessibility requirements for those services. A microenterprise employs fewer than 10 people. It also has an annual turnover of EUR 2 million or less, or a balance sheet total of EUR 2 million or less. Germany’s law repeats the exemption in section 3 of the BFSG, and the ACM gives the same line for the Netherlands.

Two things the exemption does not do:

• It does not cover products. A microenterprise that makes or imports a covered product, such as a payment terminal or an e-reader, still has to make that product comply.
• It does not stay put. A shop that grows to ten people, or past the turnover line, is in scope from that point. Building the next version of the site to the standard costs less than fixing the current one later.

What the Act asks of a website comes down to WCAG level AA and a statement

Annex I of the directive says a service’s websites and apps must be accessible “by making them perceivable, operable, understandable and robust”. Those four words are the four principles of the Web Content Accessibility Guidelines, or WCAG. They are the W3C’s checklist for accessible websites. For an online shop, the annex adds two things. The identification, security and payment steps must meet the same four principles. And when a maker provides accessibility information about a product you sell, you must pass it on.

The level that counts is AA. The European standard that turns the Act into tests is EN 301 549. The version in force, 3.2.1, is built on WCAG 2.1 level AA. Version 4.1.1, published in September 2026, moves to WCAG 2.2. The EU’s accessibility centre notes that it is not yet the legal reference, and it will not be until the Commission cites it in the Official Journal. The ACM already points businesses to WCAG 2.2 AA. Build to 2.2 AA and you meet 2.1 AA as well.

Three more duties come with the code:

• An accessibility statement. Article 13 and Annex V ask a service provider to explain how the service meets the requirements. The explanation goes in its terms and conditions or an equivalent document, in a form people with disabilities can use, and the provider keeps it for as long as the service runs.
• Staying compliant. Every change to the site is a chance to break something that worked. The Act asks for procedures that keep the service in line as it changes.
• Telling the regulator. Where a service does not comply, the provider must fix it and inform the authority. In the Netherlands, the ACM asks for that report within one week for critical or serious problems, and within one month for moderate or minor ones.

The Act has an escape clause, and it is narrower than it sounds. Article 14 lets a business skip a requirement that would be a disproportionate burden. It needs a written assessment first, renewed at least every five years and shown to the authority on request. The transition to 2030 in Article 32 covers equipment and service contracts already in place in June 2025. Ireland’s consumer authority, the CCPC, says plainly in its guidance that the transition does not cover websites or apps.

Each country enforces the Act through its own law and its own regulator

A directive works through national law, so you meet the rules of the country where your customer is.

• Germany: the Barrierefreiheitsstärkungsgesetz (BFSG). The German states set up a joint authority for it, the MLBF in Magdeburg, which has been fully in charge of enforcement since 26 September 2025. Section 37 sets fines of up to EUR 100,000 for offering a service that does not comply.
• The Netherlands: the ACM supervises online shops and communication services. In March 2026 it tested about 100 of the largest Dutch online shops, along with the largest telecom and energy companies. On 61% of them, a customer using assistive technology could not place an order at all, and another 33% had serious problems. Its examples were an order button that does not work with the keyboard, and a CAPTCHA that blocks the order.
• Ireland: S.I. No. 636 of 2023, with guidance from the CCPC.
• The UK: the Act is not UK law. It applies to a UK business only for what it sells to consumers in the EU.

My own forms stop bots without a CAPTCHA

My own site is not in scope, because it sells to businesses and BespokeForge is a microenterprise. I built it to WCAG AA anyway. A buyer with a disability is a buyer, and a check that already exists costs almost nothing to run again.

• No CAPTCHA anywhere. The contact form, the order form, the booking calendar, the checklist form and the cost calculator’s email form all stop bots the same way. Each has a hidden field that people never see, a token the page’s own script writes, and a minimum time on the page. A person has nothing to solve.
• Focus you can see. A test tabs through every component on the site. It fails any focus ring with less than 3:1 contrast against what is behind it, in the light theme and the dark one.
• Text you can read. Every text colour is at least 5.0:1 against its background in both themes, above the 4.5:1 that WCAG level AA asks for body text.
• Taps you can hit. On a phone, links and small buttons take a 44-pixel tap, above the 24 pixels that WCAG 2.2 level AA asks for.

None of this needed a widget or an overlay. It needed the site’s own code to be written that way, and a test that fails when someone breaks it.

One test this week: buy something on your own site without a mouse

The ACM’s two blockers are the easiest problems to find yourself, and you need no tools to do it.

1. Put the mouse away, open your site and click once into the address bar.
2. Use only Tab and Shift+Tab to move, Enter and Space to press, and the arrow keys inside menus and lists.
3. Find a product or a service, add it to the basket or start the booking, and go as far as the payment page.
4. At every step, check that you can see where you are on the page. If the focus disappears, or gets stuck in a menu or a pop-up, write down where.
5. Note any CAPTCHA, any button that does nothing on Enter, and any form field that does not say what it wants.

If you cannot finish, a customer who uses a keyboard or a screen reader cannot finish either. In the Netherlands, that was the case on 61% of the largest shops. An automated checker in your browser finds more, such as missing image descriptions and low contrast, but it cannot buy something for you. This test can.

Finding and fixing these problems, and writing the statement from the results, is what my accessibility baseline is for. If you want a written record of where your site stands before you decide anything, start with the audit. Pricing has the rest.