The European Accessibility Act for US companies
American companies tend to think about web accessibility through the ADA and the demand letters that come with it. If you sell online to consumers in the European Union, a second law has applied since June 28, 2025: the European Accessibility Act, Directive (EU) 2019/882. It reaches past EU borders, it names e-commerce explicitly, and each member state enforces it with its own penalties. Here is what it asks of a US business and how to tell whether yours is in scope.
This is a practitioner's guide, not legal advice. For a specific market or a complaint, talk to counsel in that country.
On this page
Who it covers
The directive defines a service provider as anyone who provides a service on the Union market or makes offers to provide one to consumers in the EU. Location isn't the test. A Delaware company with a Shopify store that ships to France and takes euros is making offers to consumers in the Union.
The services listed in Article 2 include e-commerce services, consumer banking, e-books and the software for reading them, telephony, audiovisual media services, and the websites, apps, and electronic tickets of air, bus, rail, and water passenger transport. E-commerce is defined broadly: services provided at a distance, through websites and mobile apps, by electronic means, at a consumer's request, with a view to concluding a consumer contract. In plain terms, if a European shopper can buy from you online, your storefront is in scope.
The act also covers products, such as computers, smartphones, e-readers, ATMs, and ticket machines, placed on the market after June 28, 2025. Most of my clients are affected by the services side.
The microenterprise exemption
Microenterprises that provide services are exempt from the accessibility requirements. The directive defines a microenterprise as one employing fewer than 10 people with annual turnover or an annual balance sheet total of no more than 2 million euros. Both parts apply: a nine-person company with 5 million euros in turnover and a 5 million euro balance sheet is not a microenterprise. The exemption covers services only, so a tiny company making a covered product still has to comply.
A company that grows past ten people loses the exemption, and the directive gives no grace period for crossing the line. If you're near it, plan the accessibility work before the hire that tips you over.
What the standard looks like in practice
The directive's annex sets out functional requirements: content that can be perceived, operated, understood, and used with assistive technology. The annex itself never names WCAG. The European harmonised standard for digital accessibility, EN 301 549, is the usual benchmark, and its web requirements follow WCAG 2.1 at Level AA. Meeting WCAG 2.2 AA, the current W3C version, covers that and a little more.
For an online store, the failures I find most often are the same ones behind US lawsuits:
- Product images with no text alternative, or alternatives that say "image."
- Text with too little contrast against its background, especially prices and buttons.
- Form fields at checkout without labels, so screen readers announce "edit text" and nothing more.
- Menus, filters, and size pickers that can't be used with a keyboard.
- Error messages shown only in red, or not announced at all.
- Pop-ups and cookie banners that trap keyboard focus.
Beyond the website
The act asks for accessible information about the service itself, not only an accessible interface. Providers are expected to explain in their terms or a similar document how the service meets the requirements. A short accessibility statement, linked from the footer, that says what standard you work to, what's known to be incomplete, and how a customer can get help or report a barrier, does that job and is a sensible habit in any market.
Transitional periods
Article 32 lets member states allow service providers to keep using products they lawfully used before the deadline to deliver similar services until June 28, 2030. It also lets them keep self-service terminals in use to the end of their useful life, up to 20 years. A website gets no five-year pass from either provision. A store that launches or redesigns today should meet the requirements now.
Enforcement
Each member state wrote the directive into national law and chose its own enforcement body and penalties, so the consequences differ between Germany, France, Ireland, and the rest. Market surveillance authorities can require fixes and, in some countries, restrict a non-compliant service. Consumers and disability organizations can also complain. A US business with a meaningful share of EU sales should know which countries matter most and how each one enforces.
Where to start
- Confirm whether you sell to EU consumers and whether the microenterprise exemption applies.
- Test your checkout from product page to confirmation with a keyboard and a screen reader.
- Fix the templates first, because one fixed product template fixes every product page.
- Publish an accessibility statement with a contact route.
- Skip overlay widgets; they don't change the underlying code that the standard measures.
The US side of the same work is in my guide to ADA website compliance. For a store that needs the fixes made, see accessibility remediation.