European Accessibility Act: who does it apply to and what should you do?
Since 28 June 2025, the European Accessibility Act requires many digital products and services aimed at consumers to be accessible, including most online shops. Here is who it applies to, who is exempt, what to do and what is at stake.
What the law says
The European Accessibility Act is Directive (EU) 2019/882 of 17 April 2019. Each member state transposed it into national law. In France, this was done by a law of 9 March 2023, then decree no. 2023-931 and an order of 9 October 2023. It has applied since 28 June 2025, and the DGCCRF enforces it in France.
Which services are in scope?
On the services side, the directive covers those provided to consumers:
- e-commerce: online shops, bookings, ticket sales;
- consumer banking services;
- websites, apps, e-tickets and travel information for air, rail, bus and waterborne transport;
- telephony and electronic communications services;
- access to audiovisual media services;
- e-books and the software used to read them;
- emergency communications to 112.
It also covers products: computers, smartphones, payment terminals, self-service kiosks, e-readers and TV equipment. A showcase website that sells nothing and takes no bookings is in principle out of scope.
Who is exempt?
- Microenterprises providing services: fewer than 10 employees and an annual turnover or balance sheet total under €2M.
- Services reserved for businesses: the directive protects consumers.
- Cases of disproportionate burden or fundamental alteration of the service, provided this is documented and the enforcement authority is notified.
A website or app is not a “product” under the directive: a site already online before 28 June 2025 gets no grace period. Only service contracts signed before that date may continue unchanged until they end, at the latest on 28 June 2030.
What you need to do
- Make the service accessible. The technical reference is EN 301 549, which includes WCAG 2.1 level AA.
- Publish information about the service’s accessibility: how it meets the requirements, and what does not yet.
- Monitor compliance over time, fix gaps and notify the authority of any non-compliance.
What are the penalties?
Penalties are set by each member state. In France, each breach is a 5th-class offence: up to €7,500 for a company, and fines add up. The DGCCRF can also order compliance, with a daily penalty and publication of the decision. Since 28 June 2025, checks mostly follow complaints.
Where to start
- 1Check whether your website is in scope with the four-question EAA check.
- 2Test the pages that matter: home, product list and page, cart, checkout, account creation.
- 3Fix what blocks a purchase first: unnamed buttons, unlabelled fields, contrast, keyboard navigation.
- 4Publish the accessibility information, then monitor the site after each update.
Frequently asked questions
- Does the EAA apply to B2B websites?
- No. It covers products and services aimed at consumers. A website genuinely closed to consumers is out of scope.
- Is my showcase website in scope?
- In principle no, as long as it does not let visitors order, book or access one of the listed services. It is in scope as soon as it sells online.
- Are mobile apps covered?
- Yes. Services in scope are covered whatever the channel: website, mobile app or kiosk.
- How does it relate to the French RGAA?
- The RGAA applies to French public bodies and very large companies. The EAA covers businesses providing certain services to consumers. Both rest on WCAG 2.1 AA.
Does it apply to your website?
Four questions to find out whether the European Accessibility Act applies to your website.
Take the EAA checkFurther reading
- Does the EAA apply to your website?Four questions to find out.
- RGAA vs WCAG: what’s the difference?WCAG sets the rules; the French RGAA is the method used to check them.
- Test a page’s accessibilityFree test on desktop and mobile, no account needed.
- Audits with your agency’s brandingA PDF report with your logo, ready for your clients.